Exhibit 1.01

CONFLICT MINERALS REPORT
For the Reporting Period from January 1 to December 31, 2025
Introduction
This Conflict Minerals Report of Avnet, Inc. for the calendar year 2025 (“Report”) is filed May 28, 2026, as an exhibit to the Company’s Form SD, as required under Rule 13p-1 of the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”). The Report is posted on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals. Other information available through the Company’s website is not part of this Report.
References to “the Company,” “Avnet,” “we,” “our,” or “us” means Avnet, Inc. and its subsidiaries, except where the context otherwise requires.
Applicability of the Conflict Minerals Rule to Avnet
Avnet is a global distributor of electronic components. It markets, sells, and distributes electronic components from the world’s leading electronic component manufacturers, including semiconductors, IP&E components (interconnect, passive and electromechanical), and other integrated and embedded components; and distributes a comprehensive portfolio of kits, tools, industrial automation components, and test and measurement products. It also provides embedded solutions, such as technical design, integration and assembly of embedded products, systems, and solutions; provides integrated solutions for embedded display solutions, such as touch and passive displays; and develops and produces standard board, industrial subsystems, and application-specific devices.
The Conflict Minerals Rule requires that the Company disclose information regarding any conflict minerals that are “necessary to the functionality or production” of any product that it manufactures or contracts to be manufactured. The Securities and Exchange Commission (“SEC”) defines conflict minerals as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, “CMs”). CMs are used in many electronic components and computer products. The Democratic Republic of Congo and its adjoining countries have extensive reserves of CMs, some of which are illegally sourced and traded by armed groups who are responsible for significant human rights violations. The purpose of the Conflict Minerals Rule is to encourage companies whose products contain CMs to source from suppliers who do not directly or indirectly support such armed groups through their purchasing decisions. The term CM refers to the named minerals and their derivatives and does not imply that the procurement of such minerals or derivatives directly or indirectly financed or benefitted armed groups in the Democratic Republic of Congo or an adjoining country.
Avnet’s revenues for 2025 were largely from distribution and other services that were not in-scope for purposes of compliance with the Conflict Minerals Rule. However, during 2025, it manufactured or contracted to manufacture certain products that include CMs (collectively, “Covered Products”). Therefore, the Company conducted a reasonable country of origin inquiry (“RCOI”), in good faith, to determine whether any of the CMs in the Covered Products: (1) originated in the Democratic Republic of Congo or an adjoining country, including Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia (collectively, the “Covered Countries”); or (2) are from recycled or scrap sources. Please see “Conflict Minerals Program – Reasonable Country of Origin Inquiry” for more information on the RCOI.
The Company conducted further due diligence on the source and chain of custody of such CMs that conformed, in all material respects, to an internationally recognized due diligence framework as required by the Conflict Minerals Rule. Please see “Conflict Minerals Program – Design of Conflict Minerals Program” for more information on the design of the due diligence program and “Conflict Minerals Program – Due Diligence Efforts” for more information on the due diligence conducted.
Avnet is a downstream consumer of CMs. It does not purchase the CMs contained in its Covered Products directly from mines, smelters, or refiners and is generally many levels removed from such market participants. Through the efforts described in this Report, Avnet seeks to ensure that its sourcing practices are consistent with its Responsible Minerals Sourcing Policy and to encourage conflict-free sourcing in its supply chain.
Responsible Minerals Sourcing Policy
Avnet is committed to responsible sourcing of CMs and promotes traceability of CMs and transparency of its global supply chain. It supports the efforts of the Responsible Business Alliance’s (“RBA”) due diligence and reporting processes that seek to ensure supply-chain transparency, including through its engagement of Assent, a third-party service provider that is a member of RBA’s Responsible Minerals Initiative (“RMI”). In addition, the Company has actively engaged with its customers and suppliers for several years with respect to the use of CMs. It has also adopted a Responsible Minerals Sourcing Policy, which has been communicated to Avnet’s suppliers and the public. The Responsible Minerals Sourcing Policy is below:
Avnet, Inc., including its subsidiaries (collectively “Avnet”), is committed to source minerals responsibly and avoid sourcing minerals that contribute to armed conflict or human rights abuses in conflict affected and high-risk areas (CAHRAs), including the Democratic Republic of Congo (DRC) or adjoining countries. Avnet’s approach is to promote the traceability and transparency of supply chains and move towards a conflict-free global supply chain.
Avnet supports the aims of the Responsible Business Alliance’s Responsible Minerals Initiative (RMI) to identify, reduce and eventually eliminate the use of conflict minerals that finance or benefit conflict or human rights violations, and the Responsible Minerals Assurance Process (RMAP) to validate responsible sources. Avnet encourages its suppliers to likewise support such efforts. “Conflict minerals” include tantalum, tin, tungsten and gold, which are used in many electronic components and computer products.
Under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the U.S. Securities and Exchange Commission (“SEC”) rules, Avnet is required to annually report on Form SD whether products it manufactures or contracts to manufacture contain conflict minerals necessary to the functionality or production of the products, which have been sourced from mines in the DRC or adjoining countries (“covered products”). Revenue from the mining and trade of conflict minerals from the DRC or adjoining countries is believed to finance or benefit armed groups that are responsible for human rights violations.
Avnet is a global technology distributor and solutions provider. To a very limited extent Avnet manufactures or contracts to manufacture products, some of which are covered products. However, Avnet is a downstream consumer of conflict minerals. It does not purchase directly from mines, smelters or refiners and is many levels removed from such market participants. Avnet endeavors to avoid purchasing products containing conflict minerals sourced from CAHRAs that directly or indirectly finance or benefit armed groups, while minimizing unintended consequences of de facto embargoes for conflict-free mines. Avnet also expects its suppliers to source minerals only from responsible sources.
Avnet annually conducts a reasonable country of origin inquiry (RCOI) and due diligence that aligns with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Framework). As a downstream consumer, Avnet expects its suppliers to provide proper verification of the country of origin and source of the conflict minerals used in the products they supply to Avnet, utilizing the most current Conflict Minerals Reporting Template (CMRT) developed by RMI. Avnet also encourages its suppliers to adopt similar policies, due diligence frameworks, and management systems with respect to responsible minerals sourcing to drive those efforts throughout their supply chain.
This policy is available at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals.
Conflict Minerals Program
Design of Conflict Minerals Program
Avnet’s 2025 Conflict Minerals Program (“2025 Program”) utilized the internationally recognized framework to identify the country of origin and chain of custody of the CMs. The framework (which includes supplements for gold, tin, tantalum, and tungsten) is called The Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Framework”).
Avnet’s supply chain with respect to the CMs in our Covered Products is highly complex. We do not purchase CMs directly from any mine, refiner, or smelter and there are many parties in the supply chain between Avnet’s direct supplier and the mine from which the CM originated. Due to the Company’s “downstream” position in the supply chain, it followed the principles outlined in the OECD Framework for downstream companies with no direct relationships to smelters or refiners. Therefore, Avnet must rely, in good faith, on its direct suppliers to provide information regarding the country of origin and chain of custody of the CMs included in the Covered Products and on third-party audit programs. It is likely that years of engagement and propagation of expectations through many tiers of the supply chain will be necessary before information returned to downstream companies, such as Avnet, may be considered accurate and complete.
Covered Products
Avnet determined that the following products it manufactured or contracted to manufacture in 2025 contained CMs necessary to the functionality or production of those products:
| ● | Semi-conductor electronic devices designed and contracted to be manufactured by Avnet per customer specifications. |
| ● | Electronic boards, electronic devices, display solutions, and Human-Machine Interface (HMI) solutions manufactured or contracted to be manufactured by Avnet Embedded GmbH. |
| ● | Control boards and HMIs contracted to be manufactured. |
| ● | Server based products integrated from customer designed or off-the-shelf components by Avnet Integrated. |
| ● | Design kits and modules manufactured or contracted to be manufactured by Avnet. |
| ● | Development boards and accessories contracted to be manufactured by Avnet. |
| ● | Printed circuit board assembly (PCBA) designed by customer and contracted to be manufactured by Farnell. |
| ● | PCBA and high-level integration of customer products. |
| ● | Avnet Guardian products manufactured or contracted to be manufactured by Avnet. |
| ● | Cables and electromechanical assembled products manufactured or contracted to be manufactured by Avnet. |
Pursuant to the Conflict Minerals Rule, Covered Products do not include products (i) that were not entered into the stream of commerce in 2025, and (ii) that were manufactured or contracted to be manufactured by entities that Avnet acquired after April 2025.
Reasonable Country of Origin Inquiry
Pursuant to the Conflict Minerals Rule, Avnet conducted a RCOI on the source and chain of custody of CMs in its Covered Products to determine whether any they originated in any of the Covered Countries and may not have come from recycled or scrap sources. To the extent applicable, Avnet conducted its RCOI utilizing the same processes and procedures that it established for conducting its due diligence, in particular Steps 1 and 2 of the OECD Framework, which are described under “Due Diligence Efforts” below.
The 2025 RCOI included 505 suppliers that Avnet identified as possibly providing it with components, parts or products that contained CMs for its Covered Products. These suppliers identified smelters and refiners that may have processed the CMs contained in the Covered Products. Such smelters and refiners were compared against the Smelter Look-up tab of the Conflict Minerals Reporting Template (“CMRT”), as well as the list of “conformant” smelters and refiners and country of origin information published by the RBA’s Responsible Minerals Initiative (“RMI”), to validate the smelters and refiners (validated facilities are listed in Appendix A) and to determine the countries from where such validated
facilities may have obtained CMs (countries are listed in Appendix B). For this process, Avnet used the data its Suppliers provided on their CMRTs version 6.4 or higher along with RMI’s due diligence of smelters and refiners and audits under the Responsible Minerals Assurance Process (“RMAP”) standard. The RMAP uses an independent third-party audit of smelter and refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards.
The Company retained Assent, a third-party service provider, to assist in the collection and review of supplier CMRTs and the identification of risks in the supply chain. During the 2025 RCOI, Avnet contacted suppliers via Assent Sustainability Manager (“ASM”), a software-as-a-service platform that enables users to manage and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform. ASM’s functionality meets the OECD Framework process expectations by evaluating the quality of each supplier’s response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the results provided in this Report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through ASM.
Avnet requested that all suppliers complete a CMRT. On Avnet’s behalf, Assent offered training and educational resources to Suppliers to guide them on best practices, completing a CMRT, and using the ASM platform. Avnet monitored and tracked all communications in ASM for future reporting and transparency. Avnet may directly follow up with a supplier that does not respond after three requests through ASM.
Supplier CMRTs undergo an automated data validation process to increase the completeness and accuracy of submissions and to identify any contradictory answers. This data validation process is based on questions within the declaration tab of the CMRT, which helps to identify areas that require further classification or risk assessment, as well as to understand the due diligence efforts of the Suppliers. Data validation contributes to the health assessment of Avnet’s Conflict Minerals Program, and the results are shared with suppliers regarding areas that require clarification or improvement.
Supplier CMRTs are accepted and classified as either valid or invalid. If a supplier’s CMRT is invalid, the supplier receives feedback and guidance on how to correct the validation errors and is asked to submit a valid CMRT. In addition, suppliers are provided with training courses and direct engagement help through Assent’s multilingual Supplier Experience team.
Due Diligence Efforts
Based on the findings of the 2025 RCOI, pursuant to the Conflict Minerals Rule, Avnet conducted further due diligence on the source and chain of custody of the CMs in its Covered Products. The Company designed its due diligence measures to conform, in all material respects, with the OECD Framework, which contains a five-step structure for due diligence.
1.Establish strong company management systems
| ● | Avnet has a governance team and a working team to carry out its Conflict Minerals Program. The governance team is made up of senior management and is responsible for ensuring that the program meets regulatory requirements and enterprise goals and provides direction to the working team. The working team is responsible for the day-to-day implementation of the program, diligence efforts, and risk mitigation strategy. It also informs the governance team about the results of the due diligence and risk mitigation efforts. |
| ● | Avnet uses a third-party service provider, Assent, to assist with collecting and evaluating supply chain information, identifying potential risks, and developing additional due diligence steps. Please see “Conflict Minerals Program – Reasonable Country of Origin Inquiry” for more information on the use of Assent and its software platform ASM. Avnet also leverages Assent’s managed services to work with dedicated program specialists who support Avnet’s CM program and provide Avnet updates on program status. |
| ● | Avnet has a Responsible Minerals Sourcing Policy, as discussed earlier in this Report. Pursuant to this policy, Avnet expects its suppliers to source CMs only from responsible sources and to provide proper verification of the country of origin and source of the materials used in the products they supply to Avnet. Suppliers either receive a copy of the policy or are notified of this policy. In addition, the policy is posted on Avnet’s website. This policy is reviewed annually by the governance team. |
| ● | Avnet’s Global Supplier Quality Handbook further discloses its expectations for suppliers, including an expectation that suppliers only source materials from environmentally and socially responsible suppliers. |
| ● | Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products. Its current form of supplier agreement contains a CM provision that requires a supplier to warrant that any products it supplies containing CMs either does not finance or benefit armed groups in the Covered Countries or are from recycled or scrap sources. |
| ● | Avnet uses the current CMRT version developed by RMI to identify smelters and refiners in its supply chain. The CMRT requires Suppliers to provide information concerning the usage and source of CMs in their components, parts, and products, as well as information concerning their related compliance efforts, including whether they have a policy on conflict-free sourcing and require their own suppliers to source CMs from responsible sources. |
| ● | By using Assent, Avnet provides its suppliers access to a free platform to upload their CMRTs, help desk support, educational resources on how to properly complete and submit a CMRT, and other multilingual resources. |
| ● | Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet. Violations or grievances at the industry level can be reported to the RMI directly at http://responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. |
| ● | Avnet has a document retention policy to retain CM related documents, including supplier responses to CMRTs and the sources identified within each reporting period, for at least five years. |
2.Identify and assess risk in the supply chain
| ● | Avnet identifies the business segments that manufacture or contract to manufacture products reasonably believed to contain CMs and determine the Covered Products subject to the Conflict Minerals Rule. As a global value-added distributor, a substantial majority of Avnet’s operations are out of scope of the Conflict Minerals Rule. |
| ● | Avnet identifies the active suppliers of materials, components, parts, and products that may contain CMs for the Covered Products, and each supplier is requested to complete the then latest revision of the CMRT. Avnet expects its direct suppliers to survey their suppliers. |
| ● | Supplier level risks include non-responsive suppliers. Avnet tracks receipt of Supplier CMRTs. Avnet may directly follow-up with Suppliers that do not respond after three requests through the ASM platform. Follow-up with non-responsive suppliers continued into 2025. |
| ● | Supplier level risks include weak or undeveloped Supplier CM programs. Based on a supplier’s submitted CMRT, the strength of a supplier’s related compliance efforts, including whether it has a conflict minerals sourcing policy or implements due diligence measures for conflict free sourcing, is evaluated, tracked, and rated as either weak or strong. |
| ● | Supplier level risks include supplier CMRTs that are based on company-level information versus Covered Product-level information. Suppliers may have been over-inclusive if their suppliers provide information on a company-level basis and under-inclusive if suppliers experience non-responsive suppliers or incomplete supplier CMRTs. Therefore, the Company is unable to determine if the smelters and refiners listed in Appendix A were all used or is a complete list of smelters and refiners utilized for CMs in the Covered Products. |
| ● | Supplier level risks include suppliers with problematic smelters and refiners in its supply chain. The CMRT data validation process evaluates responses for predetermined red flag indicators defined in the OECD Framework to identify risks in the supply chain posed by smelters and refiners. |
| o | Smelters and refiners identified in the CMRTs are compared against the Smelter Look-up tab of the CMRT and the list of Conformant smelters and refiners and country of origin information published by the RMI to determine if the smelter had been audited against a standard in conformance with the OECD Framework, such as RMAP. |
| o | If a smelter’s due diligence practices have not been audited against the RMAP standard or the smelter is considered non-conformant by RMAP, follow-ups may be conducted with Suppliers reporting those facilities and the facilities are assessed for potential sourcing risks. |
| o | The process uses multiple factors to determine the level of risk that each smelter and refiner poses to the supply chain. Factors include: RMAP audit status, geographic proximity to Conflict-Affected and High Risk Areas, known mineral source country of origin, credible evidence of unethical or conflict sourcing, peer assessments conducted by credible third-party sources, and sanction risks. |
3.Design and implementation of a strategy to respond to identified risks
| ● | Avnet has a risk management plan through which the Conflict Minerals Program is implemented, managed, and monitored. The plan includes processes to assess and respond to the risks identified in the supply chain, which are described in more detail under “Due Diligence Efforts – 2. Identify and assess risk in the supply chain.” Feedback on Supplier CMRTs is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. |
| ● | Avnet works with Suppliers on an as-needed basis to assist them with understanding the requirements of the Conflict Minerals Rule. Through Assent, Avnet also offers training and educational resources to suppliers to guide them on best practices, completing a CMRT, and using the ASM platform. |
| ● | Avnet participates in Assent’s smelter outreach initiative, where letters are sent twice a year to each smelter and refiner not conformant or not enrolled in RMAP to encourage participation in a cross-recognized industry audit program. The initiative also includes letters to smelters and refiners who are conformant to RMAP to reflect appreciation for their efforts. |
| ● | Working team leaders monitor risks and share the CM Program results, risk assessments, and draft Form SD filings with the governance team to ensure transparency within Avnet. |
| ● | Avnet’s Responsible Minerals Sourcing Policy publicly announces its expectations that suppliers participate in Avnet’s due diligence process by providing proper verification of the country of origin and source of the materials used in the Covered Products they supply to Avnet. The policy and the Global Supplier Quality Handbook also state that Suppliers are expected to source CMs only from responsible sources. |
| ● | Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products and include CM related due diligence in acquisition activities. |
| ● | Avnet has processes in place for new product introductions and changes to the bill of materials for the Covered Products to help ensure compliance with the Conflict Minerals Program. |
| ● | Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet. |
4.Carry out independent third-party audit of supply chain due diligence
5.Report annually on supply chain due diligence
Results of 2025 Conflict Minerals Program
As a downstream purchaser of components, parts and products that may contain CMs, Avnet’s 2025 Program can provide only reasonable, but not absolute, assurance regarding the country of origin and chain of custody of the necessary CMs in its Covered Products.
The due diligence process includes Avnet requesting information from its direct suppliers, with those suppliers requesting similar information from their suppliers and so on, up the supply chain, to eventually identify the original sources of the necessary CMs. However, those who purchase CMs directly from smelters or refiners may not be able to discern which of its product lines include specific CMs from each smelter or refiner, and so it is common practice for such purchasers to list all smelters and refiners they may purchase from within the reporting period. Likewise, suppliers’ CMRTs primarily provided information at the company level, with few at the product level, and suppliers may have
received similar information from their suppliers and so on. Finally, not all suppliers completed CMRTs or completed CMRTs in full for the 2025 Program.
For the 2025 Program, 505 Suppliers were identified, of which 356 (or 70.5%) submitted a completed CMRT.
Supplier CMRT Results | |||||
Year of Program | # Suppliers in Scope | # Completed CMRTs | % Completed CMRTs | # Valid CMRTs | % Valid CMRTs |
2025 | 505 | 356 | 70.5% | 346 | 68.5% |
2024 | 447 | 346 | 77.4% | 340 | 76.1% |
2023 | 484 | 333 | 68.8% | 329 | 68.0% |
Strength of Supplier CM Program Results | |||||
Year of Program | # Completed CMRTS | # Suppliers with CM programs and policies rated as strong | # Suppliers with no CMs in their products | Total Suppliers with strong CM programs/policies or no CMs in products | % of such Suppliers |
2025 | 356 | 216 | 53 | 269 | 75.6% |
2024 | 346 | 261 | 51 | 312 | 90.2% |
2023 | 333 | 267 | 39 | 306 | 91.9% |
The 341 legitimate smelters and refiners identified by Suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are listed in Appendix A. Based on the limitations explained above, this list may be incomplete or more comprehensive than the smelters and refiners that actually processed the CMs contained in the Covered Products. The table below summarizes the number of legitimate smelters and refiners that have been audited, are in the process of being audited, or not enrolled to be audited by RMI utilizing the RMAP standard as well as audit results.
RMI Audit Status | Legitimate Smelters and Refiners | |
Conformant | 209 | 61.3% |
Active | 9 | 2.6% |
Non-Conformant | 38 | 11.1% |
Not Enrolled (roll up of the statuses below) | 85 | 24.9% |
Total | 341 | 100.00% |
Not Enrolled subcategories | Count |
Communication Suspended – Not Interested | 5 |
In Communication | 3 |
Outreach Required | 58 |
RMI Due Diligence Review – Unable to Proceed | 19 |
The compliance status information provided in the table above is based solely on information made available by RMI, without independent verification by the Company. Following are definitions of certain terms used in the chart:
| ● | “Conformant” means that the smelter or refiner has completed the independent annual audit process and been found to be in conformance with the relevant RMAP standard, whereby verified to have conflict-free sources. |
| ● | “Active” means that the smelter or refiner is in the process of being independently audited or has committed to begin the audit process but has not yet been determined to be in conformance with the relevant RMAP standard. |
| ● | “Non-Conformant” means that the smelter or refiner has been independently assessed but found not to be in conformance with the relevant RMAP standard. |
| ● | “Communication Suspended – Not Interested” means the smelter or refiner has strongly communicated a lack of interest in participating in the audit program. |
| ● | “Due Diligence Vetting Process” means the smelter or refiner does not meet RMI’s requirements for participation in the audit program according to the Due Diligence Vetting Process. |
| ● | “In Communication” means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company. |
| ● | “Outreach Required” means RMI member companies need to contact entity to encourage their participation in audit program. |
| ● | “RMI Due Diligence Review – Unable to Proceed” means the smelter or refiner has not met the thresholds for the Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted. |
The aggregated list of countries of origin from which the reported smelters and refiners may have collectively sourced CMs, based on information provided through the CMRT data collection process and RMAP audits, is provided in Appendix B. Based on the limitations explained above, this list may be incomplete or more comprehensive than the list of countries from which CMs contained in the Covered Products were actually sourced.
After conducting its 2025 Program, and in light of the limitations explained above, Avnet concludes that it is unable to determine the origin of the CMs contained in its Covered Products and unable to determine whether its Covered Products are DRC conflict free.
Steps to be taken in Calendar 2026
As Avnet endeavors not to purchase products that contain CMs that directly or indirectly finance or benefit armed groups in the Covered Countries, and to mitigate the risk of purchasing such products, it has continued with its Conflict Minerals Program discussed above during calendar year 2025 and specifically plans to pursue the following steps and improvements:
| ● | Continue to engage with Suppliers that provided incomplete responses or no responses for 2025 to help encourage them to provide requested information for 2026. |
| ● | Continue to encourage suppliers to improve their efforts and policies, particular with suppliers whose conflict minerals compliance programs and policies are deemed weak. |
| ● | For new in-scope suppliers: (i) communicate Avnet’s sourcing expectations, including through the dissemination of the Responsible Minerals Sourcing Policy and Global Supplier Quality Handbook and inclusion of CM sourcing requirements in supplier agreements; and (ii) provide access to training and educational resources on the requirements of the Conflict Minerals Rule and to guide them on best practices, completion of a CMRT and the use of the ASM platform. |
| ● | Proactively analyze whether any CMs are present in future products that it develops or in existing products to the extent the materials included in such existing products are revised. |
| ● | Proactively seek to include CM related provisions in new or amended supplier agreements with respect to the Covered Products. |
| ● | Continue to monitor its Ethics Alertline for issues related to the Company’s conflict minerals program. |
Cautionary Statement about Forward-Looking Statements
Certain statements in this Report may be “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. Words such as “expects,” “intends,” “plans,” “believes,” “anticipates” and similar expressions, or the use of future tense, are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to the
Company’s future plans, additional steps it intends to take to mitigate the risk that the Company’s necessary CMs benefit armed groups, and other statements that do not relate to historical or current facts.
Forward-looking statements are based on the Company’s current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict, including: (1) the continued implementation of satisfactory traceability and other compliance measures by Avnet’s direct and indirect suppliers on a timely basis or at all, (2) whether smelters, refiners, and other market participants responsibly source CMs, and (3) political and regulatory developments regarding CMs. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and the Company undertakes no obligation to update or revise any forward-looking statement, except as required by federal securities law.
APPENDIX A
List of Smelters and Refiners
Avnet used data its Suppliers provided on their CMRTs for the 2025 Program along with RBA’s RMI due diligence of smelters and refiners to prepare the below list. The list (1) may not include all smelters and refiners that processed CMs in the Covered Products, and (2) may include smelters and refiners that processed CMs which were not contained in the products provided by the Suppliers for the Covered Products.
For RMI Audit Status:
| ● | Active – engaged in the program with a scheduled or in-progress RMI assessment but not yet conformant |
| ● | Communication Suspended - Not Interested – facility has strongly communicated a lack of interest in participation |
| ● | Communication Suspended - Temporarily Ceased Operations – facility has temporarily ceased operations |
| ● | Conformant – independently assessed and found conformant with the relevant RMI Due Diligence standard (RMAP DD or DAP) |
| ● | Due Diligence Vetting Process – facility is undergoing due diligence vetting process and the RMI requires additional information/documentation to make eligibility determination |
| ● | Facility Standard Assessed - Facility has been assessed against Facility Standard for Social, Environmental, OHS and Governance Risks, however decided not to participate in any other due diligence assessments |
| ● | In Communication – not yet active but in communication with the RMI and/or member company |
| ● | Non-Conformant – independently assessed and found non-conformant with the relevant RMI standard |
| ● | Not Applicable – not eligible for an RMI assessment |
| ● | Outreach Required – outreach needed by RMI member companies to contact entity and encourage their participation to undergo an RMI assessment |
| ● | RMI Due Diligence Review – Unable to Proceed – for facilities that have not met the threshold for Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted |
| ● | Third Party Assessed – facility is participating in a third-party assessment program outside of the RMI |
Mineral | Smelter / Refiner CID | Smelter / Refiner Name | Smelter / Refiner Location | RMI Audit Status |
Tungsten | CID000004 | A.L.M.T. Corp. | Japan | Conformant |
Gold | CID000015 | Advanced Chemical Company | United States Of America | Conformant |
Gold | CID000019 | Aida Chemical Industries Co., Ltd. | Japan | Conformant |
Gold | CID000035 | Agosi AG | Germany | Conformant |
Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Conformant |
Gold | CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Conformant |
Gold | CID000077 | Argor-Heraeus S.A. | Switzerland | Conformant |
Gold | CID000082 | Asahi Pretec Corp. | Japan | Conformant |
Gold | CID000090 | Asaka Riken Co., Ltd. | Japan | Conformant |
Tungsten | CID000105 | Kennametal Huntsville | United States Of America | Conformant |
Gold | CID000113 | Aurubis AG | Germany | Conformant |
Gold | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Conformant |
Gold | CID000157 | Boliden Ronnskar | Sweden | Conformant |
Gold | CID000176 | C. Hafner GmbH + Co. KG | Germany | Conformant |
Gold | CID000180 | Caridad | Mexico | Outreach Required |
Gold | CID000185 | CCR Refinery - Glencore Canada Corporation | Canada | Conformant |
Gold | CID000189 | Cendres + Metaux S.A. | Switzerland | Non Conformant |
Gold | CID000197 | Yunnan Copper Industry Co., Ltd. | China | Outreach Required |
Tungsten | CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant |
Tin | CID000228 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Conformant |
Gold | CID000233 | Chimet S.p.A. | Italy | Conformant |
Tungsten | CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant |
Gold | CID000264 | Chugai Mining | Japan | Conformant |
Tantalum | CID000291 | Guangdong Rising Rare Metals-EO Materials Ltd. | China | Conformant |
Tin | CID000292 | Alpha Assembly Solutions Inc | United States Of America | Conformant |
Tin | CID000313 | PT Premium Tin Indonesia | Indonesia | Conformant |
Gold | CID000343 | Daye Non-Ferrous Metals Mining Ltd. | China | Outreach Required |
Gold | CID000359 | DSC (Do Sung Corporation) | Korea, Republic Of | Conformant |
Tin | CID000377 | Dongguan Best Alloys Co., Ltd. | China | Conformant |
Gold | CID000401 | Dowa | Japan | Conformant |
Tin | CID000402 | Dowa | Japan | Conformant |
Gold | CID000425 | Eco-System Recycling Co., Ltd. East Plant | Japan | Conformant |
Tin | CID000438 | EM Vinto | Bolivia (Plurinational State Of) | Conformant |
Tin | CID000448 | Estanho de Rondonia S.A. | Brazil | Conformant |
Tantalum | CID000460 | F&X Electro-Materials Ltd. | China | Conformant |
Tin | CID000468 | Fenix Metals | Poland | Conformant |
Gold | CID000493 | JSC Novosibirsk Refinery | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Tin | CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant |
Tin | CID000555 | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Non Conformant |
Tungsten | CID000568 | Global Tungsten & Powders LLC | United States Of America | Conformant |
Tantalum | CID000616 | XIMEI RESOURCES (GUANGDONG) LIMITED | China | Conformant |
Gold | CID000671 | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Outreach Required |
Gold | CID000689 | LT Metal Ltd. | Korea, Republic Of | Conformant |
Gold | CID000694 | Heimerle + Meule GmbH | Germany | Conformant |
Gold | CID000707 | Heraeus Metals Hong Kong Ltd. | China | Conformant |
Gold | CID000711 | Heraeus Germany GmbH Co. KG | Germany | Conformant |
Gold | CID000767 | Hunan Chenzhou Mining Co., Ltd. | China | Outreach Required |
Tungsten | CID000769 | Hunan Jintai New Material Co., Ltd. | China | Non Conformant |
Gold | CID000773 | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | Outreach Required |
Gold | CID000778 | HwaSeong CJ CO., LTD. | Korea, Republic Of | Communication Suspended - Not Interested |
Gold | CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Conformant |
Gold | CID000807 | Ishifuku Metal Industry Co., Ltd. | Japan | Conformant |
Gold | CID000814 | Istanbul Gold Refinery | Turkey | Conformant |
Gold | CID000823 | Japan Mint | Japan | Conformant |
Tungsten | CID000825 | Japan New Metals Co., Ltd. | Japan | Conformant |
Gold | CID000855 | Jiangxi Copper Co., Ltd. | China | Conformant |
Tantalum | CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant |
Tantalum | CID000917 | Jiujiang Tanbre Co., Ltd. | China | Conformant |
Gold | CID000920 | Asahi Refining USA Inc. | United States Of America | Conformant |
Gold | CID000924 | Asahi Refining Canada Ltd. | Canada | Conformant |
Gold | CID000927 | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID000929 | JSC Uralelectromed | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID000937 | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant |
Tin | CID000942 | Gejiu Kai Meng Industry and Trade LLC | China | Non Conformant |
Gold | CID000956 | Kazakhmys Smelting LLC | Kazakhstan | Outreach Required |
Gold | CID000957 | Kazzinc | Kazakhstan | Conformant |
Tungsten | CID000966 | Kennametal Fallon | United States Of America | Conformant |
Gold | CID000969 | Kennecott Utah Copper LLC | United States Of America | Conformant |
Gold | CID000981 | Kojima Chemicals Co., Ltd. | Japan | Conformant |
Gold | CID001029 | Kyrgyzaltyn JSC | Kyrgyzstan | Non Conformant |
Gold | CID001056 | Lingbao Gold Co., Ltd. | China | Outreach Required |
Tin | CID001070 | China Tin Group Co., Ltd. | China | Conformant |
Tantalum | CID001076 | AMG Brasil | Brazil | Conformant |
Gold | CID001078 | LS MnM Inc. | Korea, Republic Of | Conformant |
Gold | CID001093 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Outreach Required |
Gold | CID001113 | Materion | United States Of America | Conformant |
Gold | CID001119 | Matsuda Sangyo Co., Ltd. | Japan | Conformant |
Tin | CID001142 | Metallic Resources, Inc. | United States Of America | Conformant |
Gold | CID001147 | Metalor Technologies (Suzhou) Ltd. | China | Conformant |
Gold | CID001149 | Metalor Technologies (Hong Kong) Ltd. | China | Conformant |
Gold | CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Conformant |
Gold | CID001153 | Metalor Technologies S.A. | Switzerland | Conformant |
Gold | CID001157 | Metalor USA Refining Corporation | United States Of America | Conformant |
Gold | CID001161 | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | Conformant |
Tantalum | CID001163 | Metallurgical Products India Pvt., Ltd. | India | Conformant |
Tin | CID001173 | Mineracao Taboca S.A. | Brazil | Conformant |
Tantalum | CID001175 | Mineracao Taboca S.A. | Brazil | Conformant |
Tin | CID001182 | Minsur | Peru | Conformant |
Gold | CID001188 | Mitsubishi Materials Corporation | Japan | Conformant |
Tin | CID001191 | Mitsubishi Materials Corporation | Japan | Conformant |
Tantalum | CID001192 | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
Gold | CID001193 | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
Tantalum | CID001200 | NPM Silmet AS | Estonia | Conformant |
Gold | CID001204 | Moscow Special Alloys Processing Plant | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID001220 | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Conformant |
Tin | CID001231 | Jiangxi New Nanshan Technology Ltd. | China | Active |
Gold | CID001236 | Navoi Mining and Metallurgical Combinat | Uzbekistan | Conformant |
Gold | CID001259 | Nihon Material Co., Ltd. | Japan | Conformant |
Tantalum | CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant |
Tin | CID001305 | Novosibirsk Tin Combine | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Tin | CID001314 | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Conformant |
Gold | CID001325 | Ohura Precious Metal Industry Co., Ltd. | Japan | Conformant |
Gold | CID001326 | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Tin | CID001337 | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | Conformant |
Gold | CID001352 | MKS PAMP SA | Switzerland | Conformant |
Gold | CID001362 | Penglai Penggang Gold Industry Co., Ltd. | China | Outreach Required |
Gold | CID001386 | Prioksky Plant of Non-Ferrous Metals | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID001397 | PT Aneka Tambang (Persero) Tbk | Indonesia | Conformant |
Tin | CID001453 | PT Mitra Stania Prima | Indonesia | Conformant |
Tin | CID001458 | PT Prima Timah Utama | Indonesia | Conformant |
Tin | CID001477 | PT Timah Tbk Kundur | Indonesia | Conformant |
Tin | CID001482 | PT Timah Tbk Mentok | Indonesia | Conformant |
Gold | CID001498 | PX Precinox S.A. | Switzerland | Conformant |
Gold | CID001512 | Rand Refinery (Pty) Ltd. | South Africa | Conformant |
Tantalum | CID001522 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
Gold | CID001534 | Royal Canadian Mint | Canada | Conformant |
Tin | CID001539 | Rui Da Hung | Taiwan, Province Of China | Conformant |
Gold | CID001546 | Sabin Metal Corp. | United States Of America | Communication Suspended - Not Interested |
Gold | CID001555 | Samduck Precious Metals | Korea, Republic Of | Non Conformant |
Gold | CID001562 | Samwon Metals Corp. | Korea, Republic Of | Communication Suspended - Not Interested |
Gold | CID001585 | SEMPSA Joyeria Plateria S.A. | Spain | Conformant |
Gold | CID001619 | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Outreach Required |
Gold | CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Conformant |
Gold | CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | China | Conformant |
Gold | CID001756 | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID001761 | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | Conformant |
Tantalum | CID001769 | Solikamsk Magnesium Works OAO | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID001798 | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant |
Gold | CID001810 | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China | Outreach Required |
Tantalum | CID001869 | Taki Chemical Co., Ltd. | Japan | Conformant |
Gold | CID001875 | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant |
Tantalum | CID001891 | Telex Metals | United States Of America | Conformant |
Tin | CID001898 | Thaisarco | Thailand | Conformant |
Tin | CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Non Conformant |
Gold | CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | China | Outreach Required |
Gold | CID001916 | Shandong Gold Smelting Co., Ltd. | China | Conformant |
Gold | CID001938 | Tokuriki Honten Co., Ltd. | Japan | Conformant |
Gold | CID001947 | Tongling Nonferrous Metals Group Co., Ltd. | China | Outreach Required |
Gold | CID001955 | Torecom | Korea, Republic Of | Non Conformant |
Tantalum | CID001969 | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant |
Gold | CID001980 | Umicore S.A. Business Unit Precious Metals Refining | Belgium | Conformant |
Gold | CID001993 | United Precious Metal Refining, Inc. | United States Of America | Conformant |
Gold | CID002003 | Valcambi S.A. | Switzerland | Conformant |
Tin | CID002015 | VQB Mineral and Trading Group JSC | Viet Nam | Outreach Required |
Gold | CID002030 | Western Australian Mint (T/a The Perth Mint) | Australia | Conformant |
Tin | CID002036 | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant |
Tungsten | CID002044 | Wolfram Bergbau und Hutten AG | Austria | Conformant |
Tungsten | CID002082 | Xiamen Tungsten Co., Ltd. | China | Conformant |
Gold | CID002100 | Yamakin Co., Ltd. | Japan | Conformant |
Gold | CID002129 | Yokohama Metal Co., Ltd. | Japan | Conformant |
Tin | CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Non Conformant |
Tin | CID002180 | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | Conformant |
Gold | CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conformant |
Gold | CID002243 | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Conformant |
Gold | CID002282 | Morris and Watson | New Zealand | Outreach Required |
Gold | CID002290 | SAFINA A.S. | Czechia | Conformant |
Tungsten | CID002313 | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | Communication Suspended - Not Interested |
Gold | CID002314 | Umicore Precious Metals Thailand | Thailand | Non Conformant |
Tungsten | CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Active |
Tungsten | CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant |
Tungsten | CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant |
Tungsten | CID002319 | Malipo Haiyu Tungsten Co., Ltd. | China | Conformant |
Tungsten | CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conformant |
Tungsten | CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant |
Tin | CID002468 | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Conformant |
Tantalum | CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant |
Tungsten | CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conformant |
Tin | CID002500 | Melt Metais e Ligas S.A. | Brazil | Non Conformant |
Tungsten | CID002502 | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant |
Tin | CID002503 | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant |
Tantalum | CID002504 | D Block Metals, LLC | United States Of America | Conformant |
Tantalum | CID002505 | FIR Metals & Resource Ltd. | China | Conformant |
Tantalum | CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant |
Tantalum | CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | China | Conformant |
Gold | CID002509 | MMTC-PAMP India Pvt., Ltd. | India | Conformant |
Gold | CID002511 | KGHM Polska Miedz Spolka Akcyjna | Poland | Conformant |
Tantalum | CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant |
Tungsten | CID002513 | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | Non Conformant |
Gold | CID002515 | Fidelity Printers and Refiners Ltd. | Zimbabwe | RMI Due Diligence Review - Unable to Proceed |
Gold | CID002516 | Singway Technology Co., Ltd. | Taiwan, Province Of China | Non Conformant |
Tin | CID002517 | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant |
Gold | CID002525 | Shandong Humon Smelting Co., Ltd. | China | Outreach Required |
Gold | CID002527 | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | Outreach Required |
Tantalum | CID002539 | KEMET de Mexico | Mexico | Conformant |
Tungsten | CID002541 | H.C. Starck Tungsten GmbH | Germany | Conformant |
Tungsten | CID002542 | TANIOBIS Smelting GmbH & Co. KG | Germany | Conformant |
Tungsten | CID002543 | Masan High-Tech Materials | Viet Nam | Conformant |
Tantalum | CID002544 | TANIOBIS Co., Ltd. | Thailand | Conformant |
Tantalum | CID002545 | TANIOBIS GmbH | Germany | Conformant |
Tantalum | CID002548 | Materion Newton Inc. | United States Of America | Conformant |
Tantalum | CID002549 | TANIOBIS Japan Co., Ltd. | Japan | Conformant |
Tantalum | CID002550 | TANIOBIS Smelting GmbH & Co. KG | Germany | Conformant |
Tungsten | CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Conformant |
Tantalum | CID002557 | Global Advanced Metals Boyertown | United States Of America | Conformant |
Tantalum | CID002558 | Global Advanced Metals Aizu | Japan | Conformant |
Gold | CID002560 | Al Etihad Gold Refinery DMCC | United Arab Emirates | Non Conformant |
Gold | CID002561 | Emirates Gold DMCC | United Arab Emirates | Non Conformant |
Gold | CID002562 | International Precious Metal Refiners | United Arab Emirates | Outreach Required |
Tin | CID002570 | CV Ayi Jaya | Indonesia | Conformant |
Tin | CID002572 | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Non Conformant |
Tin | CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | Outreach Required |
Gold | CID002580 | T.C.A S.p.A | Italy | Conformant |
Gold | CID002582 | REMONDIS PMR B.V. | Netherlands | Conformant |
Gold | CID002584 | Fujairah Gold FZC | United Arab Emirates | Outreach Required |
Gold | CID002588 | Shirpur Gold Refinery Ltd. | India | Outreach Required |
Tungsten | CID002589 | Niagara Refining LLC | United States Of America | Conformant |
Tin | CID002593 | PT Rajehan Ariq | Indonesia | Conformant |
Gold | CID002605 | Korea Zinc Co., Ltd. | Korea, Republic Of | Conformant |
Gold | CID002606 | Marsam Metals | Brazil | Non Conformant |
Gold | CID002615 | TOO Tau-Ken-Altyn | Kazakhstan | Conformant |
Tungsten | CID002641 | China Molybdenum Tungsten Co., Ltd. | China | Conformant |
Tungsten | CID002649 | Hydrometallurg, JSC | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Tin | CID002696 | PT Cipta Persada Mulia | Indonesia | Conformant |
Tin | CID002703 | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Outreach Required |
Tin | CID002706 | Resind Industria e Comercio Ltda. | Brazil | Conformant |
Tantalum | CID002707 | Resind Industria e Comercio Ltda. | Brazil | Conformant |
Gold | CID002708 | Abington Reldan Metals, LLC | United States Of America | Conformant |
Tungsten | CID002724 | Unecha Refractory metals plant | Russian Federation | Non Conformant |
Gold | CID002750 | Shenzhen CuiLu Gold Co., Ltd. | China | Outreach Required |
Tin | CID002756 | Super Ligas | Brazil | Conformant |
Gold | CID002760 | Albino Mountinho Lda. | Portugal | Outreach Required |
Gold | CID002761 | SAAMP | France | Non Conformant |
Gold | CID002762 | L'Orfebre S.A. | Andorra | Non Conformant |
Gold | CID002763 | 8853 S.p.A. | Italy | Non Conformant |
Gold | CID002765 | Italpreziosi | Italy | Conformant |
Tin | CID002773 | Aurubis Beerse | Belgium | Conformant |
Tin | CID002774 | Aurubis Berango | Spain | Conformant |
Tin | CID002776 | PT Bangka Prima Tin | Indonesia | Conformant |
Gold | CID002778 | WIELAND Edelmetalle GmbH | Germany | Conformant |
Gold | CID002779 | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Conformant |
Tantalum | CID002842 | Jiangxi Tuohong New Raw Material | China | Conformant |
Tungsten | CID002845 | Moliren Ltd. | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID002850 | AU Traders and Refiners | South Africa | Non Conformant |
Gold | CID002852 | GGC Gujrat Gold Centre Pvt. Ltd. | India | Non Conformant |
Gold | CID002857 | Modeltech Sdn Bhd | Malaysia | Non Conformant |
Tin | CID002858 | Modeltech Sdn Bhd | Malaysia | Non Conformant |
Gold | CID002863 | Bangalore Refinery | India | Conformant |
Gold | CID002865 | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID002867 | Degussa Sonne / Mond Goldhandel GmbH | Germany | Outreach Required |
Gold | CID002872 | Pease & Curren | United States Of America | Communication Suspended - Not Interested |
Gold | CID002893 | JALAN & Company | India | Outreach Required |
Gold | CID002918 | SungEel HiMetal Co., Ltd. | Korea, Republic Of | Conformant |
Gold | CID002919 | Planta Recuperadora de Metales SpA | Chile | Conformant |
Gold | CID002920 | ABC Refinery Pty Ltd. | Australia | Outreach Required |
Gold | CID002973 | Safimet S.p.A | Italy | Non Conformant |
Tin | CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant |
Gold | CID003153 | State Research Institute Center for Physical Sciences and Technology | Lithuania | Outreach Required |
Gold | CID003185 | African Gold Refinery | Uganda | RMI Due Diligence Review - Unable to Proceed |
Gold | CID003186 | Gold Coast Refinery | Ghana | Outreach Required |
Gold | CID003189 | NH Recytech Company | Korea, Republic Of | Conformant |
Tin | CID003190 | Chifeng Dajingzi Tin Industry Co., Ltd. | China | Conformant |
Gold | CID003324 | QG Refining, LLC | United States Of America | Outreach Required |
Tin | CID003325 | Tin Technology & Refining | United States Of America | Conformant |
Gold | CID003348 | Dijllah Gold Refinery FZC | United Arab Emirates | Outreach Required |
Tin | CID003356 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | Non Conformant |
Tin | CID003379 | Ma'anshan Weitai Tin Co., Ltd. | China | Non Conformant |
Tin | CID003380 | PT Masbro Alam Stania | Indonesia | Non Conformant |
Gold | CID003382 | CGR Metalloys Pvt Ltd. | India | Outreach Required |
Gold | CID003383 | Sovereign Metals | India | Outreach Required |
Tin | CID003387 | Luna Smelter, Ltd. | Rwanda | Conformant |
Tin | CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Conformant |
Tungsten | CID003407 | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | Conformant |
Tungsten | CID003408 | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Tin | CID003409 | Precious Minerals and Smelting Limited | India | Non Conformant |
Tin | CID003410 | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | Outreach Required |
Tungsten | CID003416 | NPP Tyazhmetprom LLC | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Tungsten | CID003417 | Hubei Green Tungsten Co., Ltd. | China | Conformant |
Gold | CID003424 | Eco-System Recycling Co., Ltd. North Plant | Japan | Conformant |
Gold | CID003425 | Eco-System Recycling Co., Ltd. West Plant | Japan | Conformant |
Tungsten | CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | Non Conformant |
Tin | CID003449 | PT Mitra Sukses Globalindo | Indonesia | Conformant |
Gold | CID003461 | Augmont Enterprises Private Limited | India | Non Conformant |
Gold | CID003463 | Kundan Care Products Ltd. | India | Outreach Required |
Tungsten | CID003468 | Cronimet Brasil Ltda | Brazil | Conformant |
Tin | CID003486 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | Active |
Gold | CID003487 | Emerald Jewel Industry India Limited (Unit 1) | India | Outreach Required |
Gold | CID003488 | Emerald Jewel Industry India Limited (Unit 2) | India | Outreach Required |
Gold | CID003489 | Emerald Jewel Industry India Limited (Unit 3) | India | Outreach Required |
Gold | CID003490 | Emerald Jewel Industry India Limited (Unit 4) | India | Outreach Required |
Gold | CID003497 | K.A. Rasmussen | Norway | Outreach Required |
Gold | CID003500 | Alexy Metals | United States Of America | Non Conformant |
Tin | CID003524 | CRM Synergies | Spain | Conformant |
Gold | CID003548 | MD Overseas | India | Outreach Required |
Gold | CID003557 | Metallix Refining Inc. | United States Of America | Outreach Required |
Gold | CID003575 | Metal Concentrators SA (Pty) Ltd. | South Africa | Conformant |
Tin | CID003582 | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | Conformant |
Tungsten | CID003609 | Fujian Xinlu Tungsten Co., Ltd. | China | Non Conformant |
Tungsten | CID003612 | OOO “Technolom” 2 | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Tungsten | CID003614 | OOO “Technolom” 1 | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
Gold | CID003615 | WEEEREFINING | France | Non Conformant |
Gold | CID003641 | Gold by Gold Colombia | Colombia | Conformant |
Tungsten | CID003662 | YUDU ANSHENG TUNGSTEN CO., LTD. | China | Outreach Required |
Gold | CID003663 | Dongwu Gold Group | China | Outreach Required |
Gold | CID003666 | Sam Precious Metals | United Arab Emirates | Outreach Required |
Gold | CID003690 | NOBLE METAL SERVICES | United States Of America | Outreach Required |
Tin | CID003868 | PT Putera Sarana Shakti (PT PSS) | Indonesia | Conformant |
Tantalum | CID003926 | 5D Production OU | Estonia | Outreach Required |
Tungsten | CID003993 | Tungsten Vietnam Joint Stock Company | Viet Nam | Conformant |
Gold | CID004010 | Coimpa Industrial LTDA | Brazil | Conformant |
Tungsten | CID004034 | Nam Viet Cromit Joint Stock Company | Viet Nam | Outreach Required |
Tantalum | CID004054 | PowerX Ltd. | Rwanda | Conformant |
Tin | CID004065 | Mining Minerals Resources SARL | Congo, Democratic Republic Of The | Conformant |
Tungsten | CID004397 | Lianyou Resources Co., Ltd. | Taiwan, Province Of China | Conformant |
Tin | CID004403 | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan | Conformant |
Tungsten | CID004430 | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | Conformant |
Tin | CID004434 | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | Conformant |
Gold | CID004435 | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | China | Outreach Required |
Tungsten | CID004438 | Philippine Carreytech Metal Corp. | Philippines | Non Conformant |
Gold | CID004491 | TITAN COMPANY LIMITED, JEWELLERY DIVISION | India | Non Conformant |
Gold | CID004506 | GG Refinery Ltd. | Tanzania, United Republic Of | Conformant |
Tungsten | CID004619 | KENEE MINING VIETNAM COMPANY LIMITED | Viet Nam | Conformant |
Tin | CID004692 | RIKAYAA GREENTECH PRIVATE LIMITED | India | Outreach Required |
Gold | CID004697 | Attero Recycling Pvt Ltd | India | Outreach Required |
Gold | CID004714 | Impala Platinum - Platinum Metals Refinery (PMR) | South Africa | Conformant |
Tin | CID004724 | Woodcross Smelting Company Limited | Uganda | Conformant |
Tin | CID004754 | Global Advanced Metals Greenbushes Pty Ltd. | Australia | Conformant |
Gold | CID004755 | Elite Industech Co., Ltd. | Taiwan, Province Of China | Conformant |
Tin | CID004796 | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | China | Outreach Required |
Tungsten | CID004797 | Philippine Bonway Manufacturing Industrial Corporation | Philippines | Conformant |
Tantalum | CID004813 | Jiangxi Sanshi Nonferrous Metals Co., Ltd | China | Active |
Gold | CID005006 | Gasabo Gold Refinery Ltd | Rwanda | RMI Due Diligence Review - Unable to Proceed |
Gold | CID005014 | Minera Titán del Perú SRL (MTP) - Belen Plant | Peru | Non Conformant |
Tin | CID005189 | P Kay Metal, Inc | United States Of America | Conformant |
Tin | CID000309 | PT Aries Kencana Sejahtera | Indonesia | In Communication |
Tin | CID001399 | PT Artha Cipta Langgeng | Indonesia | Active |
Gold | CID004704 | SOLEIL METALS (Chala One Plant) | Peru | Active |
Gold | CID004705 | SOLEIL METALS (YAKARI Plant) | Peru | Active |
Tungsten | CID005012 | Jing Yuan Tungsten Technology Co., Ltd. | Taiwan, Province Of China | Conformant |
Tungsten | CID002660 | Uzbek Refractory and Heat-Resistant Metals | Uzbekistan | Active |
Tin | CID003504 | Conecsus LLC | 0 | Active |
Tungsten | CID005068 | S.P.T. spol.s r.o. | 0 | Conformant |
Tungsten | CID005248 | Tungamoy Metals Inc. | Korea, Republic Of | Conformant |
Tin | CID004685 | PT Mitra Graha Raya | Indonesia | In Communication |
Gold | CID003350 | Atlantic Copper | Spain | Outreach Required |
Tungsten | CID005373 | Geo Enterprise | Georgia | Outreach Required |
Gold | CID005396 | Naoshima Smelter & Refinery | Japan | Outreach Required |
Gold | CID005401 | KGHM Polska Miedz S.A. Oddzial Huta Miedzi, Glogow | Poland | Outreach Required |
Gold | CID005476 | Aurubis AG, Hamburg | Germany | Outreach Required |
Gold | CID005522 | ARGET SAC | Peru | In Communication |
Gold | CID005589 | Boliden Harjavalta Oy | Finland | Conformant |
Gold | CID005614 | Glencore Nikkelverk AS | Norway | Conformant |
APPENDIX B
Countries of Origin
Avnet utilized data its suppliers provided on their CMRTs for the 2025 Program and relied on information provided by RBA’s RMI due diligence of smelters and refiners regarding the countries of origin and mines or locations of origin to prepare the below list. The list (1) may not include all countries that ultimately sourced the CMs in the Covered Products, and (2) may include countries that did not ultimately source CMs contained in the Covered Products.
Country of Origin (Material) | ||||
Albania | Dominican Republic | Kyrgyzstan | Rwanda | |
Andorra | Ecuador | Liberia | Saudi Arabia | |
Angola | Egypt | Liechtenstein | Senegal | |
Argentina | El Salvador | Lithuania | Serbia | |
Armenia | Eritrea | Luxembourg | Sierra Leone | |
Australia | Estonia | Madagascar | Singapore | |
Austria | Ethiopia | Malaysia | Slovakia | |
Azerbaijan | Fiji | Mali | Solomon Islands | |
Belarus | Finland | Mauritania | South Africa | |
Belgium | France | Mexico | South Sudan | |
Benin | Georgia | Mongolia | Spain | |
Bermuda | Germany | Morocco | Sudan | |
Bolivia (Plurinational State of) | Ghana | Mozambique | Suriname | |
Botswana | Guatemala | Myanmar | Sweden | |
Brazil | Guinea | Namibia | Switzerland | |
Bulgaria | Guyana | Netherlands | Taiwan | |
Burkina Faso | Honduras | New Zealand | Tajikistan | |
Burundi | Hong Kong | Nicaragua | Tanzania | |
Cambodia | Hungary | Niger | Thailand | |
Canada | India | Nigeria | Turkey | |
Central African Republic | Indonesia | Norway | Uganda | |
Chile | Ireland | Oman | United Arab Emirates | |
China | Israel | Panama | United Kingdom | |
Colombia | Italy | Papua New Guinea | United States | |
Congo | Japan | Peru | Uruguay | |
Cyprus | Jersey | Philippines | Uzbekistan | |
Democratic Republic of Congo | Kazakhstan | Poland | Viet Nam | |
Djibouti | Kenya | Portugal | Zambia | |
Dominica | Korea | Russian Federation | Zimbabwe | |