UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Zebra Technologies Corporation
(Exact name of the registrant as specified in its charter)
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| Delaware | | 000-19406 | | 36-2675536 |
(State or other jurisdiction
of incorporation or organization) | | (Commission
File Number) | | (IRS Employer
Identification No.) |
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| 3 Overlook Point, Lincolnshire, Illinois | | 60069 |
| (Address of principal executive offices) | | (Zip code) |
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| Cristen Kogl | | 847-793-5512 |
(Name and telephone number, including area code, of the
person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
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| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2024, to December 31, 2024 |
Introduction
Effective for the year ending December 31, 2024, Zebra Technologies Corporation (“Zebra”) must disclose whether any conflict minerals necessary to the functionality or production of a product manufactured by Zebra (or contracted by Zebra to be manufactured) originated in the Democratic Republic of the Congo (“DRC”) or a country adjoining the DRC [Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia, together the “Covered Countries”], or whether the conflict minerals are from recycled or scrap sources. The disclosure requirement arose from Congress’s determination that trade in conflict minerals in a DRC country is financing conflict in those areas, contributing to a humanitarian crisis.
The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the DRC or Covered Countries (“Conflict Minerals”).
Section 1 – Conflict Minerals Disclosures
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (‘Rule 13p-1”), Zebra Technologies Corporation (“Zebra”) has filed this Specialized Disclosure Form (“Form SD”) and the associated Exhibit 1.01 Conflict Minerals Report for the reporting period January 1, 2024, to December 31, 2024 and is publicly available on Zebra’s website under “Company Information”/“Compliance”/“Products and Materials Compliance” found on Zebra’s website at https://www.zebra.com/us/en/about-zebra/company-information/compliance/products-and-materials-compliance.html.
After conducting a reasonable country of origin inquiry and our supply chain due diligence inquiry, Zebra has been unable to determine that certain of its conflict minerals did not originate in the Covered Countries or come from recycled or scrap sources, or that such conflict minerals did not directly or indirectly finance or benefit armed groups in the Covered Countries.
Item 1.02 – Exhibits
The Zebra Technologies Corporation Conflict Minerals Report is attached to this report as Exhibit 1.01.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report of Zebra Technologies Corporation for the period January 1, 2024, to December 31, 2024, as required by Items 1.01 and 1.02 of this Form SD.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
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| | | | ZEBRA TECHNOLOGIES CORPORATION |
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| Dated: May 28, 2025 | | | | By: | | /s/ Cristen Kogl |
| | | | | | Name: Cristen Kogl |
| | | | | | Title: Chief Legal Officer,
General Counsel and Corporate Secretary |
EXHIBIT INDEX
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Exhibit
Number | | Description of Exhibits | | |
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| 1.01 | |
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CONFLICT MINERALS REPORT OF
ZEBRA TECHNOLOGIES CORPORATION
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FOR THE REPORTING PERIOD FROM JANUARY 1 TO DECEMBER 31, 2024 |
I.Introduction
In accordance in all material respects with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”), Zebra undertook efforts to determine whether the necessary Conflict Minerals1 in our products were or were not “DRC conflict free”, as defined in Rule 13p-1. This is the Conflict Minerals Report of Zebra Technologies Corporation (“Zebra,” the “Company,” “our” or “we”) for calendar year 2024 (excepting Conflict Minerals that, prior to January 31, 2024, were located outside of the supply chain) in accordance in all material respects with Rule 13p-1 (the “Report”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Specialized Disclosure Form (“Form SD”) and the reader is referred to those sources, as well as, to Release No. 34-67716 (August 22, 2012) of the Act (the “Adopting Release”) for such definitions.
The statements below are based on the due diligence activities performed to date and in good faith by Zebra and are based on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters in responding to information requests, incomplete information from industry or other third-party sources.
II. Zebra’s Manufacturing and Outsourcing Description
We are a global leader in the Automatic Identification and Data Capture (“AIDC”) industry. The AIDC market consists of mobile computing, data capture, radio frequency identification devices (“RFID”), thermal barcode printing, and other workflow automation products and services. The Company’s products, services, and software solutions (“offerings”) are proven to help our customers and end-users digitize and automate their workflows to achieve their critical business objectives, including improved productivity and operational efficiency, optimized regulatory compliance, and better customer experiences.
We design, manufacture, and sell a broad range of AIDC offerings, including: mobile computers, barcode scanners and imagers, RFID readers, specialty printers for barcode labeling and personal identification, real-time location systems (“RTLS”), related accessories and supplies, such as labels and other consumables, and related software applications. We also provide machine vision and robotics automation solutions; a full range of services, including maintenance, technical support, repair, managed and professional services; as well as cloud-based software subscriptions. End-users of our offerings include those in retail and e-commerce, manufacturing, transportation and logistics, healthcare, public sector, and other industries. We operate in 114 facilities with approximately 9,900 employees worldwide. We provide our offerings globally through a direct sales force and an extensive network of over 10,000 channel partners, operating in approximately 176 countries.
Final assembly of our hardware products is performed by third parties, including electronics manufacturing services companies (“EMSs”) and joint design manufacturers (“JDMs”). Our products are currently produced in facilities primarily located in the Asia-Pacific region, including China, Taiwan, Vietnam, Malaysia, and Mexico. The EMSs and JDMs produce our products to our design specifications. We maintain control over portions of the supply chain,
1 The term “Conflict Mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives (collectively referred to as “3TG”).
including supplier selection and price negotiations for key components. The manufacturers generally purchase all the components and subassemblies used in the production of our products. Our products are shipped to regional distribution centers, operated by third-party logistics providers or the Company. A portion of products are reconfigured at the distribution centers through firmware downloads, packaging, and customer specific customization before they are shipped to customers. In addition, certain products are manufactured in accordance with procurement regulations and various international trade agreements and remain eligible for sale to the U.S. government.
Production facilities for our supplies products are located in the U.S. and Europe. We also supplement our in-house supplies production capabilities with third-party manufacturers, principally located in Asia-Pacific.
III.Zebra’s Product Description
Acquisitions
Photoneo: On February 28, 2025, the Company acquired Photoneo, a leading developer and manufacturer of 3D machine vision offerings. The acquisition complements and expands our machine vision offerings across several industries.
Matrox: On June 3, 2022, the Company acquired Matrox Electronic Systems Ltd. (“Matrox”). Matrox is a leading provider of advanced machine vision components and software serving multiple end-markets. Through its acquisition, the Company significantly expands machine vision products and software offerings.
Antuit: On October 7, 2021, the Company acquired Antuit Holdings Pte. Ltd. (“Antuit”). Antuit is a provider of demand-sensing and pricing optimization software solutions for retail and consumer products companies. Through this acquisition, the Company expands its portfolio of software solution offerings to customers in these industries by combining Antuit’s platform with its existing software solutions and EVM products.
Fetch: On August 9, 2021, the Company acquired Fetch Robotics, Inc. (“Fetch”). Fetch is a provider of autonomous mobile robot solutions for customers who operate in the manufacturing, distribution, and fulfillment industries, enabling customers to optimize workflows through robotic automation. Through this acquisition, the Company intends to expand its automation solution offerings within these industries.
Adaptive Vision: On May 17, 2021, the Company acquired Adaptive Vision Sp. z o.o. (“Adaptive Vision”). Adaptive Vision is a provider of graphical machine vision software with applications in the manufacturing industry, as well as a provider of libraries and other offerings for machine vision developers.
Reflexis: On September 1, 2020, the Company acquired Reflexis Systems, Inc. (“Reflexis”). Reflexis is a provider of task and workforce management, execution, and communication software solutions for customers in the retail, food service, hospitality, and banking industries. Through this acquisition, the Company intends to enhance its solution offerings to customers in those industries by combining Reflexis’ platform with its existing software solutions and EVM products.
Cortexica: On November 5, 2019, the Company acquired Cortexica Vision Systems Limited (“Cortexica”). Cortexica is a provider of computer vision-based artificial intelligence solutions primarily serving the retail industry.
Profitect: On May 31, 2019, the Company acquired Profitect, Inc. (“Profitect”). Profitect is a provider of prescriptive analytics software primarily serving the retail industry. Through this acquisition, the Company
enhanced its existing software solutions within the retail industry by combining Profitect’s platform with its existing software solutions and EVM products.
Temptime: On February 21, 2019, the Company acquired Temptime Corporation (“Temptime”). Temptime is a developer and manufacturer of temperature-monitoring labels and devices. Through this acquisition, the Company expanded its product offerings within the healthcare industry, with possible future applications in other industries involving temperature-sensitive products.
Xplore: On August 14, 2018, the Company acquired all outstanding equity interests of Xplore Technologies Corporation (“Xplore”). The Xplore business designs, integrates, markets and sells rugged tablets that are primarily used by industrial, government, and field service organizations. The acquisition of Xplore is intended to expand the Company’s portfolio of mobile computing devices to serve a wider range of customers.
Enterprise Business: In October of 2014, Zebra acquired the Enterprise business (“Enterprise”) from Motorola Solutions, Inc. (“MSI”), excluding its iDEN, or Integrated Digital Enhanced Network Business. The Enterprise products include rugged and enterprise-grade mobile computers, barcode scanners and RFID readers, WLAN solutions, and accessories, software and services that are associated with these products.
Operations and Technologies
Our operations consist of two reportable segments: Asset Intelligence & Tracking (“AIT”), which includes barcode and card printing, RFID and RTLS offerings, supplies, and services; and Enterprise Visibility & Mobility (“EVM”), which includes mobile computing, data capture, fixed industrial scanning and machine vision, services and workflow optimization solutions. We believe that the offerings across these segments collectively elevate Zebra’s positioning with our customers, enabling us to better transform workflows.
Asset Intelligence & Tracking
Barcode and Card Printing: We design, manufacture, and sell printers, which produce high-quality labels, wristbands, tickets, receipts, and plastic cards on demand. Our customers use our printers in a wide range of applications, including routing and tracking, patient safety, transaction processing, personal identification, product authentication, ticketing and receipts. These applications require high levels of data accuracy, speed, and reliability.
Our printers use thermal printing technology, which creates images by heating certain pixels of an electrical printhead to selectively image a ribbon or heat-sensitive substrate. Our printers integrate company-designed mechanisms, electrical systems, and firmware that supports serial, parallel, Ethernet, USB, Bluetooth, or 802.11 wireless communications with appropriate security protocols. Enclosures of metal or high-impact plastic help ensure durability of our printers. Printing instructions can be received as a proprietary language such as Zebra Programming Language II, as a print driver-provided image, or as user-defined Extensible Markup Language. These features make our printers easy to integrate into most computer systems.
We also provide dye-sublimination thermal card printers that produce high quality images and are used for secure, reliable personal identification (e.g. state identification cards, drivers’ licenses, and healthcare identification cards), access control (e.g. employee or student building access), and financial transactions (e.g. credit, debit and ATM cards). Additionally, we provide RFID printers that encode data into passive RFID transponders embedded in a label or card. We offer a wide range of accessories and options for our printers, including carrying cases, vehicle mounts and battery chargers.
RFID and RTLS Offerings: We provide a range of hardware and software options for capturing location data to satisfy a large variety of requirements for range, accuracy, and precision. Our active and passive RFID products include fixed readers, RFID enabled mobile computers, and RFID sleds that utilize passive ultra-high frequency to provide high-speed, data capture from hundreds or thousands of RFID tags in near real-time without line of sight, complementing the barcode. Using the Electronic Product Code (“EPC”) standard, end-users across multiple industries use our RFID technology to track high-value assets, monitor shipments, and drive increased retail sales through improved inventory accuracy. Our location solutions offerings include a range of RTLS offerings that generate precise, on-demand information about the physical location and status of high-value assets, equipment, and people. These offerings incorporate active and passive RFID technologies, beacons, and other tracking technologies to enable users to locate, track, manage, and optimize the utilization of enterprise assets and personnel. We provide substantially all elements of the location solution, including tags, sensors, exciters, middleware software, and application software. We also foster a highly specialized ecosystem of location and tracking partners who complement our offerings and help integrate them into our joint customers’ operations.
Supplies: We produce and sell stock and customized thermal labels, wristbands, receipts, ribbons, plastic cards, and RFID tags suitable for use with our printers, as well as wristbands for use in laser printers. We support our printing products, resellers, and end-users with an extensive line of superior quality, high-performance supplies optimized to a particular end-user’s needs, such as chemical or abrasion resistance, extreme temperature environments, exceptional image quality, or long life. We promote the use of supplies with our printing equipment. Our supplies business also includes electronic sensors and temperature-monitoring labels which incorporate chemical indicators designed to change color upon exceeding predefined time and/or temperature thresholds, used in vaccine distribution and other use cases in healthcare and food safety.
Services: We provide a full range of maintenance, technical support, and repair services. We also provide managed and professional services, including those which help customers manage their devices and related software applications. Our offerings include cloud-based subscriptions and multiple service levels. They are typically contracted through multi-year service agreements. We provide our services directly and through our global network of partners.
Enterprise Visibility & Mobility
Mobile Computing: We design, manufacture, and sell rugged and enterprise-grade mobile computing products and accessories in a variety of specialized form factors and designs to meet a wide array of enterprise applications. Purpose-built handheld and wearable mobile computers, vehicle mounted computers, tablets and kiosks ensure reliable operations for targeted use cases, surviving years of rough handling and harsh environments. Industrial applications include inventory management in warehouses and distribution centers; field mobility applications include field service, post and parcel, and direct store delivery; and retail and customer facing applications include e-commerce, omnichannel, mobile point of sale, inventory look-up, staff collaboration, and analytics. Our mobile computing products primarily incorporate the Android™ operating system with software extensions for the enterprise and support local-area and wide-area voice and data communications. Our products include software tools and services that enable secure data transmission while also supporting application development, device configuration, and field support to facilitate seamless, rapid deployment and maximum customer return on investment. Our products often incorporate barcode scanning, global position system and RFID features, and other sensory capabilities. Additionally, specialized features, such as advanced data capture technologies, data analytics technologies, voice and video collaboration tools, and advanced battery technologies, enable our customers to work more efficiently and better serve their own customers.
Data Capture, Fixed Industrial Scanning, and Machine Vision: We design, manufacture, and sell barcode scanners, industrial machine vision cameras, and fixed industrial scanners. Our portfolio of scanners includes laser scanning and imager products in a variety of form factors, including fixed, handheld, and embedded original equipment
manufacturer (“OEM”) modules. Our scanners incorporate a range of technologies including area imagers, linear imagers, and lasers, as well as read linear and two-dimensional barcodes. They are used in a broad range of applications, ranging from supermarket checkouts to industrial warehouse optimization to patient management in hospitals. The design of these offerings reflects the diverse needs of these markets, with different ergonomics, multiple communication protocols, and varying levels of ruggedness. In 2021 we introduced fixed industrial scanning and machine vision offerings, and in 2022, we significantly expanded our machine vision offerings through the acquisition of Matrox Imaging. Our fixed industrial scanning products automatically track and trace items that move from production through distribution. Our industrial machine vision platform-independent software, software development kits, smart cameras, vision controllers, frame grabbers, input/output cards, and 3D sensors capture, inspect, assess, and record data from industrial vision systems in factory automation, semiconductor inspection, pharmaceutical packaging, food & beverage, among other use cases. We also provide related software and accessories for these offerings.
Services: We provide a full range of maintenance, technical support, and repair services. We also provide managed and professional services that, among other things, help customers design, test, and deploy our offerings as well as manage their mobility devices, software applications and workflows. Our offerings include cloud-based subscriptions with multiple service levels, which are typically contracted through multi-year service agreements. We provide our services directly and through our global network of partners.
Workflow optimization solutions: We provide a portfolio of offerings that help our customers improve the agility and productivity of key workflows by analyzing and acting on operational data in real-time. Our primary focus is on frontline workers in Zebra’s end markets, including retail, transportation and logistics, manufacturing, and healthcare. Our workflow optimization solutions include:
•Software-based offerings, which include workforce management, workflow execution and task management, demand-sensing, price optimization, and prescriptive analytics, as well as communication and collaboration-based offerings. These offerings are typically delivered through cloud-based software subscriptions and leverage big data, artificial intelligence, and mobile and web applications to provide customers with real-time visibility and actionable insights about their business. By analyzing labor, inventory, transactional and real-time situational data, these offerings are able to forecast demand, prescribe actions, schedule workers, and enhance collaboration. Our software-based offerings are available with multiple service levels, and are often contracted through multi-year service agreements;
•Managed service offerings comprised of software and hardware bundled together, which include a range of physical inventory management offerings for retail, including offerings for full store physical inventories, cycle counts, and analytics; and
•Robotic automation offerings, which include software-powered autonomous robots that enable customers to orchestrate workflows alongside frontline workers, improving productivity and operational efficiency. Our robotic automation offerings are available in a variety of form factors to accommodate many use cases, from e-commerce fulfillment to material movement.
IV.Zebra’s Due Diligence Process
Zebra’s Conflict Minerals Report relates to the diligence process undertaken for Zebra products that were manufactured, or contracted to be manufactured on behalf of Zebra, during 2024. Zebra’s process to exercise due diligence and to determine country of origin was based on the following approach:
1)Identification of Zebra products that contain 3TG metals necessary to the functionality or production of said products;
2)Collection and review of supplier conflict minerals reports for completeness and accuracy;
3)Evaluation and verification of the collected data, including smelter information reported from each source; and
4)Review and report results.
Zebra supports an industry initiative which audits the due diligence activities of the smelters and refiners: that industry initiative is the Responsible Minerals Initiative (the “RMI”), which was formerly known as the Conflict-Free Sourcing Initiative (“CFSI”), organized and operating under the auspices of the Responsible Business Alliance (“RBA”) [formerly known as Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”)].
The RMI provides companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas. The RMI designed and manages the Responsible Minerals Assurance Process (“RMAP”), formerly the Conflict-Free Smelter Program (“CFSP”), to identify the smelters that process 3TG and to independently audit those smelters to certify those whose operations are conformant with the RMI RMAP audit protocol. The data on which we relied for certain statements in our Conflict Minerals Report was obtained through our membership in RMI using the Reasonable Country of Origin Inquiry report for members. Zebra’s RMI member code for 2024 reporting is ZKXB.
The Zebra collection and diligence process utilized the RMI Conflict Minerals Reporting Template (“CMRT”), which is the standardized reporting tool that facilitates the collection and transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. Throughout the data collection process for the 2024 reporting year, Zebra continued to utilize the latest version of the CMRT, CMRT v6.4 released on April 26, 2024, during our due diligence process.
The following steps were taken as part of our overall risk assessment process:
•Identify in-scope products: Zebra utilized a cross-functional team of employees to review the categories of products that we sell to determine the products that are in-scope as described in the Adopting Release. Through this analysis, Zebra identified 165 active suppliers comprising approximately 99.77% of Zebra’s 2024 spend on component parts supplied and used in the manufacture of Zebra products during 2024.
•Conduct Reasonable Country of Origin Inquiry (“RCOI”): Zebra procures its components from a variety of suppliers around the world, and we rely on our direct suppliers to provide information on the source of the 3TG materials contained in components and products supplied to Zebra - including sources of 3TG that are supplied to them from upstream suppliers. As part of the RCOI, Zebra utilized the industry developed CMRT survey tool, which requests suppliers to identify the 3TG in their products; report information about the sources of the 3TG; and provide other information that is used to assess whether they are potentially sourcing from smelters or refiners known to directly or indirectly support conflict in the Covered Countries, as defined under Rule 13p-1.
We conducted our data collection by approaching suppliers directly to request completion of the currently available CMRT and asked them to submit the data to us by the 2024 year-end. In total, Zebra collected and reviewed 3TG information for 134 unique suppliers representing 99% of our total spend during 2024 [ten (10) suppliers failed to respond to Zebra’s direct request; twenty-one (21) suppliers were submitted via Tier 1]. We have reviewed CMRT declarations for completeness and consistency and used the RMI smelter/refinery database tool (RBA SOR Master, formerly known as CM Master), updated monthly, for smelter validation. Additionally, we used independent research of public domain information to determine non-certified smelters’ potential risk.
•Identify smelters/refiners: For 2024, Zebra’s suppliers identified 357 (8 smelters provide 2 metals, resulting in a total of 365 smelters when broken down by metal) smelters or refiners in their CMRT survey responses. In finalizing our data analysis, we relied upon the RMI RCOI table for RMI members-only data for certified conflict-free smelters or refiners; RMI due diligence library; RBA SOR Master, which was updated monthly; and our independent research of NGO sites and publicly available information for smelter
validation. We evaluated the reported smelters and refiners against the list of smelters and refiners listed on the RMI’s Standard Smelter List as having valid smelting or refining operations, and against the list of smelter facilities designated as “conformant” by the RMI’s independent third-party smelter audit program or the equivalent certifying bodies such as London Bullion Market Association (the “LBMA”) and the Responsible Jewelry Council (the “RJC”); and based upon these reviews, 238 or 65.2% of reported smelters or refiners are either certified as conformant or are engaged in the RMI RMAP, and a total of 127 smelters or refiners are not considered “conformant.”
Based on the information received from our suppliers through Zebra’s diligence process, some information provided by our suppliers was unverifiable or incomplete, and as such, we were unable to verify with certainty the source and chain of custody of all 3TGs used in our products. Please see the facilities listed in Table 1 to this Report for the list of facilities that have been reported as the source of 3TGs used in the manufacturing of Zebra products during the 2024 reporting year.
We have consolidated the results of Zebra’s due diligence on the 3TG used in Zebra’s in-scope products, and said results are summarized in the below table:
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Smelters* | Tantalum | Tin | Tungsten | Gold | Totals |
| Number of smelters reported | 37 | 93 | 56 | 179 | 365 |
Number of smelters listed as conformant (passed Audit by RMI, LBMA, RJC) | 35 | 72 | 37 |
94 |
238 |
* The table represents those smelters and refiners disclosed by our suppliers that are listed on the RMI’s Standard Smelter List as having valid smelting or refining operations in 2024, and those which are listed as being certified as conformant or engaged in RMAP, based upon the information available on the RMI’s website (http://www.responsiblemineralsinitiative.org/ ).
V. Conflict Minerals Report
After conducting a reasonable country of origin inquiry and our supply chain due diligence assessment, Zebra has been unable to determine whether sourcing of 3TG metals used in its products directly or indirectly contributed to armed conflicts in the Covered Countries. Accordingly, this Conflict Minerals Report has been filed with the SEC and is publicly available on Zebra’s website under “About Zebra” / “Compliance” / “Conflict Minerals Disclosure Report” found on Zebra’s website at https://www.zebra.com/us/en/about-zebra/company-information/compliance/products-and-materials-compliance.html.
•Product Determination
As a result of Zebra’s diligence efforts, we have concluded that as of December 31, 2024, our products are not considered to be “DRC conflict free” (as defined). Zebra is making this determination because we have concluded in good faith that during 2024, we do not have sufficient information from suppliers or other sources to conclude at this time whether the necessary conflict minerals for in-scope products are in fact DRC conflict free.
VI. Steps to Improve Due Diligence
Zebra expects that the amount of information globally on the traceability and sourcing of Conflict Minerals will continue to increase and this will enable Zebra to continue to make informed decisions regarding its supply chain. Zebra will continue to evaluate its diligence process and work to improve the diligence conducted to help reduce the risk that our necessary Conflict Minerals do not directly or indirectly benefit armed groups in the DRC and Covered Countries.
Zebra’s diligence of its suppliers remains ongoing, and we continue to work to collect accurate and complete responses from our suppliers through the continued use of tools like the Conflict Minerals Reporting Template. Zebra will also review and test its supplier responses against the information collected via independent conflict free smelter validation programs such as the Responsible Minerals Initiative.
Finally, Zebra will continue to monitor changes in circumstances that may impact our determination under the Act.
VII. Independent Private Sector Audit
As Zebra has not described any of its products as “DRC conflict free” in this Report, and pursuant to the Act, an audit is not required for calendar year 2024.
Table 1
SMELTERS CURRENTLY CERTIFIED AS CONFORMANT BY RMI OR EQUIVALENT ORGANIZATIONS (LBMA, RJC)
This list contains certified conformant smelters reported by Zebra suppliers using 2024 RMI Conflict Minerals Reporting Template v6.4.
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| Metal | Smelter | RMI Smelter Id | Country |
| Gold | Sam Precious Metals | CID003666 | UNITED ARAB EMIRATES |
| Gold | WEEEREFINING | CID003615 | FRANCE |
| Gold | Gold by Gold Colombia | CID003641 | COLOMBIA |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 | AUSTRALIA |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | AUSTRIA |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | BELGIUM |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 | BRAZIL |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 | CANADA |
| Gold | Royal Canadian Mint | CID001534 | CANADA |
| Gold | Asahi Refining Canada Ltd. | CID000924 | CANADA |
| Gold | Planta Recuperadora de Metales SpA | CID002919 | CHILE |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | CHINA |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | CHINA |
| Gold | Shandong Gold Smelting Co., Ltd. | CID001916 | CHINA |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | CHINA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | CHINA |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 | CHINA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | CHINA |
| Gold | SAFINA A.S. | CID002290 | CZECHIA |
| Gold | Heraeus Germany GmbH Co. KG | CID000711 | GERMANY |
| Gold | Aurubis AG | CID000113 | GERMANY |
| Gold | Agosi AG | CID000035 | GERMANY |
| Gold | C. Hafner GmbH + Co. KG | CID000176 | GERMANY |
| Gold | WIELAND Edelmetalle GmbH | CID002778 | GERMANY |
| Gold | Heimerle + Meule GmbH | CID000694 | GERMANY |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | INDIA |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | INDONESIA |
| Gold | Italpreziosi | CID002765 | ITALY |
| Gold | T.C.A S.p.A | CID002580 | ITALY |
| Gold | Chimet S.p.A. | CID000233 | ITALY |
| Gold | Mitsubishi Materials Corporation | CID001188 | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 | JAPAN |
| | | | | | | | | | | |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | JAPAN |
| Gold | Dowa | CID000401 | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | JAPAN |
| Gold | Chugai Mining | CID000264 | JAPAN |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | JAPAN |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | CID002129 | JAPAN |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 | JAPAN |
| Gold | Asahi Pretec Corp. | CID000082 | JAPAN |
| Gold | Yamakin Co., Ltd. | CID002100 | JAPAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | JAPAN |
| Gold | Nihon Material Co., Ltd. | CID001259 | JAPAN |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | JAPAN |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | JAPAN |
| Gold | Japan Mint | CID000823 | JAPAN |
| Gold | Asaka Riken Co., Ltd. | CID000090 | JAPAN |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 | JAPAN |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 | JAPAN |
| Gold | Kazzinc | CID000957 | KAZAKHSTAN |
| Gold | TOO Tau-Ken-Altyn | CID002615 | KAZAKHSTAN |
| Gold | DSC (Do Sung Corporation) | CID000359 | KOREA, REPUBLIC OF |
| Gold | Korea Zinc Co., Ltd. | CID002605 | KOREA, REPUBLIC OF |
| Gold | LS MnM Inc. | CID001078 | KOREA, REPUBLIC OF |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 | KOREA, REPUBLIC OF |
| Gold | NH Recytech Company | CID003189 | KOREA, REPUBLIC OF |
| Gold | LT Metal Ltd. | CID000689 | KOREA, REPUBLIC OF |
| Gold | REMONDIS PMR B.V. | CID002582 | NETHERLANDS |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 | MEXICO |
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 | POLAND |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | PHILIPPINES |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | SINGAPORE |
| Gold | SEMPSA Joyeria Plateria S.A. | CID001585 | SPAIN |
| Gold | Coimpa Industrial LTDA | CID004010 | BRAZIL |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 | SOUTH AFRICA |
| Gold | Boliden Ronnskar | CID000157 | SWEDEN |
| Gold | PX Precinox S.A. | CID001498 | SWITZERLAND |
| Gold | Metalor Technologies S.A. | CID001153 | SWITZERLAND |
| Gold | Argor-Heraeus S.A. | CID000077 | SWITZERLAND |
| Gold | Valcambi S.A. | CID002003 | SWITZERLAND |
| | | | | | | | | | | |
| Gold | MKS PAMP SA | CID001352 | SWITZERLAND |
| Gold | Solar Applied Materials Technology Corp. | CID001761 | TAIWAN, PROVINCE OF CHINA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 | TURKEY |
| Gold | Istanbul Gold Refinery | CID000814 | TURKEY |
| Gold | Metalor USA Refining Corporation | CID001157 | UNITED STATES OF AMERICA |
| Gold | Asahi Refining USA Inc. | CID000920 | UNITED STATES OF AMERICA |
| Gold | United Precious Metal Refining, Inc. | CID001993 | UNITED STATES OF AMERICA |
| Gold | Kennecott Utah Copper LLC | CID000969 | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company | CID000015 | UNITED STATES OF AMERICA |
| Gold | Abington Reldan Metals, LLC | CID002708 | UNITED STATES OF AMERICA |
| Gold | Materion | CID001113 | UNITED STATES OF AMERICA |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 | UZBEKISTAN |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | UZBEKISTAN |
| Gold | Bangalore Refinery | CID002863 | INDIA |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) | CID004714 | SOUTH AFRICA |
| Gold | Metal Concentrators SA (Pty) Ltd. | CID003575 | SOUTH AFRICA |
| Gold | GG Refinery Ltd. | CID004506 | TANZANIA, UNITED REPUBLIC OF |
| Gold | Elite Industech Co., Ltd. | CID004755 | TAIWAN, PROVINCE OF CHINA |
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 | BRAZIL |
| Tantalum | AMG Brasil | CID001076 | BRAZIL |
| Tantalum | Mineracao Taboca S.A. | CID001175 | BRAZIL |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | CHINA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CID000291 | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | CHINA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | CHINA |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | CHINA |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CID000616 | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | CHINA |
| Tantalum | PowerX Ltd. | CID004054 | RWANDA |
| Tantalum | NPM Silmet AS | CID001200 | ESTONIA |
| Tantalum | TANIOBIS GmbH | CID002545 | GERMANY |
| | | | | | | | | | | |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | CID002550 | GERMANY |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | INDIA |
| Tantalum | TANIOBIS Japan Co., Ltd. | CID002549 | JAPAN |
| Tantalum | Global Advanced Metals Aizu | CID002558 | JAPAN |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 | JAPAN |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 | JAPAN |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 | KAZAKHSTAN |
| Tantalum | KEMET de Mexico | CID002539 | MEXICO |
| Tantalum | TANIOBIS Co., Ltd. | CID002544 | THAILAND |
| Tantalum | Global Advanced Metals Boyertown | CID002557 | UNITED STATES OF AMERICA |
| Tantalum | QuantumClean | CID001508 | UNITED STATES OF AMERICA |
| Tantalum | Materion Newton Inc. | CID002548 | UNITED STATES OF AMERICA |
| Tantalum | D Block Metals, LLC | CID002504 | UNITED STATES OF AMERICA |
| Tantalum | Telex Metals | CID001891 | UNITED STATES OF AMERICA |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CID003583 | CHINA |
| Tantalum | Jiangxi Sanshi Nonferrous Metals Co., Ltd | CID004813 | CHINA |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | CID004434 | MALAYSIA |
| Tin | Alpha | CID000292 | UNITED STATES OF AMERICA |
| Tin | Tin Technology & Refining | CID003325 | UNITED STATES OF AMERICA |
| Tin | Metallic Resources, Inc. | CID001142 | UNITED STATES OF AMERICA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | THAILAND |
| Tin | Thaisarco | CID001898 | THAILAND |
| Tin | Rui Da Hung | CID001539 | TAIWAN, PROVINCE OF CHINA |
| Tin | Aurubis Berango | CID002774 | SPAIN |
| Tin | Luna Smelter, Ltd. | CID003387 | RWANDA |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | PHILIPPINES |
| Tin | Fenix Metals | CID000468 | POLAND |
| Tin | Minsur | CID001182 | PERU |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 | MALAYSIA |
| Tin | Dowa | CID000402 | JAPAN |
| Tin | Mitsubishi Materials Corporation | CID001191 | JAPAN |
| Tin | PT Timah Nusantara | CID001486 | INDONESIA |
| Tin | PT Babel Inti Perkasa | CID001402 | INDONESIA |
| Tin | PT Timah Tbk Kundur | CID001477 | INDONESIA |
| Tin | PT Timah Tbk Mentok | CID001482 | INDONESIA |
| Tin | PT Refined Bangka Tin | CID001460 | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | CID001468 | INDONESIA |
| Tin | PT Artha Cipta Langgeng | CID001399 | INDONESIA |
| | | | | | | | | | | |
| Tin | Woodcross Smelting Company Limited | CID004724 | UGANDA |
| Tin | PT Sukses Inti Makmur | CID002816 | INDONESIA |
| Tin | PT Bangka Prima Tin | CID002776 | INDONESIA |
| Tin | PT Bangka Serumpun | CID003205 | INDONESIA |
| Tin | PT Menara Cipta Mulia | CID002835 | INDONESIA |
| Tin | PT Tommy Utama | CID001493 | INDONESIA |
| Tin | PT Tinindo Inter Nusa | CID001490 | INDONESIA |
| Tin | PT Premium Tin Indonesia | CID000313 | INDONESIA |
| Tin | PT Aries Kencana Sejahtera | CID000309 | INDONESIA |
| Tin | CV Ayi Jaya | CID002570 | INDONESIA |
| Tin | PT Mitra Stania Prima | CID001453 | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 | INDONESIA |
| Tin | PT Cipta Persada Mulia | CID002696 | INDONESIA |
| Tin | CV Venus Inti Perkasa | CID002455 | INDONESIA |
| Tin | PT Bukit Timah | CID001428 | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | CID003381 | INDONESIA |
| Tin | PT Rajehan Ariq | CID002593 | INDONESIA |
| Tin | PT Prima Timah Utama | CID001458 | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | CID001463 | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | CID001421 | INDONESIA |
| Tin | PT Bangka Tin Industry | CID001419 | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | CID001406 | INDONESIA |
| Tin | China Tin Group Co., Ltd. | CID001070 | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | CHINA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | CHINA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | CHINA |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CID002180 | CHINA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 | CHINA |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 | CHINA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | CID002036 | BRAZIL |
| Tin | Mineracao Taboca S.A. | CID001173 | BRAZIL |
| Tin | Estanho de Rondonia S.A. | CID000448 | BRAZIL |
| Tin | Super Ligas | CID002756 | BRAZIL |
| Tin | Operaciones Metalurgicas S.A. | CID001337 | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | BRAZIL |
| Tin | Melt Metais e Ligas S.A. | CID002500 | BRAZIL |
| Tin | Resind Industria e Comercio Ltda. | CID002706 | BRAZIL |
| Tin | EM Vinto | CID000438 | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Aurubis Beerse | CID002773 | BELGIUM |
| | | | | | | | | | | |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | CID004403 | JAPAN |
| Tin | PT Mitra Sukses Globalindo | CID003449 | INDONESIA |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | CID003486 | BRAZIL |
| Tin | CRM Synergies | CID003524 | SPAIN |
| Tin | Mining Minerals Resources SARL | CID004065 | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | CID004754 | AUSTRALIA |
| Tin | PT Putera Sarana Shakti (PT PSS) | CID003868 | INDONESIA |
| Tin | DS Myanmar | CID003831 | MYANMAR |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CID003609 | CHINA |
| Tungsten | Lianyou Resources Co., Ltd. | CID004397 | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CID004430 | CHINA |
| Tungsten | Masan High-Tech Materials | CID002543 | VIET NAM |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | VIET NAM |
| Tungsten | Global Tungsten & Powders LLC | CID000568 | UNITED STATES OF AMERICA |
| Tungsten | Niagara Refining LLC | CID002589 | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Fallon | CID000966 | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | CID000105 | UNITED STATES OF AMERICA |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | PHILIPPINES |
| Tungsten | A.L.M.T. Corp. | CID000004 | JAPAN |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 | JAPAN |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | CID002542 | GERMANY |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 | GERMANY |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | CHINA |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CID003417 | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | CHINA |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CID002513 | CHINA |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | CHINA |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CID002641 | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | CHINA |
| | | | | | | | | | | |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | CHINA |
| Tungsten | Wolfram Bergbau und Hutten AG | CID002044 | AUSTRIA |
| Tungsten | Tungsten Vietnam Joint Stock Company | CID003993 | VIET NAM |
| Tungsten | Philippine Carreytech Metal Corp. | CID004438 | PHILIPPINES |
| Tungsten | Kenee Mining Corporation Vietnam | CID004619 | VIET NAM |
| Tungsten | Cronimet Brasil Ltda | CID003468 | BRAZIL |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation | CID004797 | PHILIPPINES |
SMELTERS NOT CURRENTLY CERTIFED CONFORMANT
This list contains smelters that are not certified conformant, reported by Zebra suppliers using 2024 RMI Conflict Minerals Reporting Template v6.4.
| | | | | | | | | | | |
| Metal | Smelter | RMI Smelter Id | Country |
| Gold | L'Orfebre S.A. | CID002762 | ANDORRA |
| Gold | ABC Refinery Pty Ltd. | CID002920 | AUSTRALIA |
| Gold | Industrial Refining Company | CID002587 | BELGIUM |
| Gold | Albino Mountinho Lda. | CID002760 | PORTUGAL |
| Gold | Marsam Metals | CID002606 | BRAZIL |
| Gold | Guangdong Jinding Gold Limited | CID002312 | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | CHINA |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | CHINA |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 | CHINA |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | CHINA |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 | CHINA |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 | CHINA |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | CHINA |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 | CHINA |
| Gold | Super Dragon Technology Co., Ltd. | CID001810 | TAIWAN, PROVINCE OF CHINA |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 | CHINA |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CID002750 | CHINA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 | CHINA |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 | CHINA |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | CHINA |
| Gold | Lingbao Gold Co., Ltd. | CID001056 | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | CHINA |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | CHINA |
| Gold | SAAMP | CID002761 | FRANCE |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 | GERMANY |
| Gold | Shirpur Gold Refinery Ltd. | CID002588 | INDIA |
| Gold | Gold Coast Refinery | CID003186 | GHANA |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | CID002852 | INDIA |
| Gold | JALAN & Company | CID002893 | INDIA |
| Gold | Sai Refinery | CID002853 | INDIA |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 | INDIA |
| Gold | Sovereign Metals | CID003383 | INDIA |
| Gold | 8853 S.p.A. | CID002763 | ITALY |
| Gold | Safimet S.p.A | CID002973 | ITALY |
| Gold | Kazakhmys Smelting LLC | CID000956 | KAZAKHSTAN |
| Gold | Samwon Metals Corp. | CID001562 | KOREA, REPUBLIC OF |
| | | | | | | | | | | |
| Gold | Samduck Precious Metals | CID001555 | KOREA, REPUBLIC OF |
| Gold | HwaSeong CJ CO., LTD. | CID000778 | KOREA, REPUBLIC OF |
| Gold | Torecom | CID001955 | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | CID001029 | KYRGYZSTAN |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 | LITHUANIA |
| Gold | Modeltech Sdn Bhd | CID002857 | MALAYSIA |
| Gold | Caridad | CID000180 | MEXICO |
| Gold | Morris and Watson | CID002282 | NEW ZEALAND |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | RUSSIAN FEDERATION |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | RUSSIAN FEDERATION |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | CID000929 | RUSSIAN FEDERATION |
| Gold | JSC Novosibirsk Refinery | CID000493 | RUSSIAN FEDERATION |
| Gold | Moscow Special Alloys Processing Plant | CID001204 | RUSSIAN FEDERATION |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 | RUSSIAN FEDERATION |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | RUSSIAN FEDERATION |
| Gold | AU Traders and Refiners | CID002850 | SOUTH AFRICA |
| Gold | L'azurde Company For Jewelry | CID001032 | SAUDI ARABIA |
| Gold | Sudan Gold Refinery | CID002567 | SUDAN |
| Gold | Cendres + Metaux S.A. | CID000189 | SWITZERLAND |
| Gold | Singway Technology Co., Ltd. | CID002516 | TAIWAN, PROVINCE OF CHINA |
| Gold | Umicore Precious Metals Thailand | CID002314 | THAILAND |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | TURKEY |
| Gold | African Gold Refinery | CID003185 | UGANDA |
| Gold | Kaloti Precious Metals | CID002563 | UNITED ARAB EMIRATES |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 | UNITED ARAB EMIRATES |
| Gold | Emirates Gold DMCC | CID002561 | UNITED ARAB EMIRATES |
| Gold | International Precious Metal Refiners | CID002562 | UNITED ARAB EMIRATES |
| Gold | Dijllah Gold Refinery FZC | CID003348 | UNITED ARAB EMIRATES |
| Gold | Fujairah Gold FZC | CID002584 | UNITED ARAB EMIRATES |
| Gold | NOBLE METAL SERVICES | CID003690 | UNITED STATES OF AMERICA |
| Gold | Pease & Curren | CID002872 | UNITED STATES OF AMERICA |
| Gold | QG Refining, LLC | CID003324 | UNITED STATES OF AMERICA |
| Gold | Sabin Metal Corp. | CID001546 | UNITED STATES OF AMERICA |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 | ZIMBABWE |
| Gold | Dongwu Gold Group | CID003663 | CHINA |
| | | | | | | | | | | |
| Gold | Augmont Enterprises Private Limited | CID003461 | INDIA |
| Gold | Kundan Care Products Ltd. | CID003463 | INDIA |
| Gold | Attero Recycling Pvt Ltd | CID004697 | INDIA |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | CID004435 | CHINA |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | CID003487 | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | CID003489 | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | CID003490 | INDIA |
| Gold | Alexy Metals | CID003500 | UNITED STATES OF AMERICA |
| Gold | MD Overseas | CID003548 | INDIA |
| Gold | Metallix Refining Inc. | CID003557 | UNITED STATES OF AMERICA |
| Gold | K.A. Rasmussen | CID003497 | NORWAY |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | CID003488 | INDIA |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 | RUSSIAN FEDERATION |
| Tantalum | 5D Production OU | CID003926 | ESTONIA |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | CID004692 | INDIA |
| Tin | PT Mitra Graha Raya | CID004685 | INDONESIA |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 | VIET NAM |
| Tin | VQB Mineral and Trading Group JSC | CID002015 | VIET NAM |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | VIET NAM |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | VIET NAM |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | VIET NAM |
| Tin | Novosibirsk Tin Combine | CID001305 | RUSSIAN FEDERATION |
| Tin | Pongpipat Company Limited | CID003208 | MYANMAR |
| Tin | Modeltech Sdn Bhd | CID002858 | MALAYSIA |
| Tin | PT Panca Mega Persada | CID001457 | INDONESIA |
| Tin | PT Tirus Putra Mandiri | CID002478 | INDONESIA |
| Tin | Precious Minerals and Smelting Limited | CID003409 | INDIA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | CHINA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 | CHINA |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | CHINA |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 | CHINA |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | CID003582 | BRAZIL |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | CID004796 | CHINA |
| Tungsten | LLC Vostok | CID003643 | RUSSIAN FEDERATION |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CID003662 | CHINA |
| Tungsten | Nam Viet Cromit Joint Stock Company | CID004034 | VIET NAM |
| Tungsten | MALAMET SMELTING SDN. BHD. | CID004056 | MALAYSIA |
| Tungsten | HANNAE FOR T Co., Ltd. | CID003978 | KOREA, REPUBLIC OF |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | CID003408 | RUSSIAN FEDERATION |
| | | | | | | | | | | |
| Tungsten | NPP Tyazhmetprom LLC | CID003416 | RUSSIAN FEDERATION |
| Tungsten | Hydrometallurg, JSC | CID002649 | RUSSIAN FEDERATION |
| Tungsten | Unecha Refractory metals plant | CID002724 | RUSSIAN FEDERATION |
| Tungsten | Moliren Ltd. | CID002845 | RUSSIAN FEDERATION |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | CID004060 | KOREA, REPUBLIC OF |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 | CHINA |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CID000769 | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | CHINA |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 | BRAZIL |
| Tungsten | ACL Metais Eireli | CID002833 | BRAZIL |
| Tungsten | OOO “Technolom” 1 | CID003614 | RUSSIAN FEDERATION |
| Tungsten | Artek LLC | CID003553 | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 2 | CID003612 | RUSSIAN FEDERATION |