UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Calix, Inc.
(Exact name of registrant as specified in its charter)
| | | | | | | | |
| | |
| Delaware | 001-34674 | 68-0438710 |
(State or other jurisdiction
of incorporation) | (Commission
File No.) | (I.R.S. Employer
Identification No.) |
2777 Orchard Parkway, San Jose, California 95134
(Address of Principal Executive Offices) (Zip Code)
Doug McNitt,
EVP, General Counsel
(408) 514-3000
(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 to which this form is being filed and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Calix, Inc.’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and is publicly available at https://investor-relations.calix.com under Governance – Governance Documents.
Item 1.02 Exhibit
As required by Item 1.01 of this Form SD, a Conflict Minerals Report has been filed as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this Form SD:
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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| Date: May 31, 2024 | | | | | | CALIX, INC. |
| | | | |
| | | | | | By: | | /s/ Doug McNitt |
| | | | | | | | Doug McNitt |
| | | | | | | | EVP, General Counsel |
Exhibit 1.01
Conflict Minerals Report
Calix, Inc.
For the Year Ended December 31, 2023
This Conflict Minerals Report (“CMR”) is provided to comply with Rule 13p-1 of the Securities Exchange Act of 1934, as amended, for Calix, Inc. (“Calix”) for the calendar year ended December 31, 2023. Rule 13p-1, as implemented by the Securities and Exchange Commission (“SEC”), imposes reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Act”). Rule 13p-1 applies to SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products, other than conflict minerals sourced solely from recycled or scrap sources. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten and gold, referred to as 3TG.
If a registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together with the DRC, the “Covered Countries”), or a registrant is unable to determine the country of origin of those conflict minerals, then the Act requires that the registrant exercise due diligence on the source and chain of custody of those conflict minerals.
Overview
Calix is a leading global provider of cloud and software platforms, systems and services that focus on the access network, the portion of the network that governs available bandwidth and determines the range and quality of services that can be offered to subscribers. Calix’s cloud and software platforms enable communication service providers to provide a wide range of revenue-generating services, from basic voice and data to advanced broadband services, over legacy and next-generation access networks. Calix primarily relies upon third-party manufacturing partners to manufacture its products, including the purchase of components or materials that may contain smelted or refined minerals and the purchase raw ore or minerals. As a result of this third-party manufacturing model, Calix is several levels removed from the purchase of raw ore and minerals, and the mining of conflict minerals. These purchases occur much further upstream in Calix’s supply chain.
For purposes of Rule 13p-1, Calix engaged a third-party vendor to assist with survey efforts and outreach with our third-party manufacturing partners. This process included researching whether suppliers upstream in Calix’s supply chain utilized conflict minerals in the manufacture of products for Calix, and, if so, the origin of those conflict minerals. Because Calix relies upon third-party manufacturing partners, consisting of contract manufacturers and original design manufacturers, to source for and produce its products, in most cases, Calix has no visibility into the upstream suppliers and does not control the supplier sourcing decisions. In selecting manufacturing partners, Calix requires partners to regularly engage with and assess their supplier base to evaluate the components and materials used to produce Calix products.
Based on information obtained during this survey process for our manufacturing partners in 2023, Calix identified that some components and materials that are included in Calix products contain conflict minerals.
Reasonable Country of Origin Inquiry
In order to perform a reasonable country of origin inquiry (“RCOI”), Calix and its third party vendor, worked directly with suppliers and third-party manufacturers to conduct surveys of their direct supplier base to determine whether the conflict minerals contained in components of Calix products originated from the Covered Countries. This survey was conducted using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”), and included inquiries related to the facilities used to process conflict minerals, a supplier’s commitment and processes to support conflict free sourcing and the smelters and refiners used.
For 2023, surveys were distributed to approximately 189 suppliers with a reported response rate of 97%. To support improved response rate and quality of the CMRT process, personnel that have oversight responsibilities for conflict minerals within our manufacturing partner organizations review the CMRT responses and engage with our manufacturing partners to conduct follow-up inquiries for CMRT completeness and accuracy.
Based on the RCOI described above, we have reason to believe that some of the components used in the manufacture of our products in 2023 contained conflict minerals that originated from the Covered Countries and were not sourced solely from recycled or scrap sources.
Supply Chain Due Diligence and Assessment
Based on the RCOI, and as required by Rule 13p-1, we undertook due diligence on our supply chain to ascertain whether the conflict minerals in Calix products directly or indirectly financed or benefited arms groups in the Covered Countries.
Based on our RCOI for 2023, there were approximately 507 smelters and refiners that were identified by suppliers as a source of conflict minerals, of which 178 were known to be sourcing conflict minerals originating from the Covered Countries and 3 were sourcing from an unknown country of origin. In accordance with the Organization for Economic Co-operation and Development Due Diligence Guidelines for Responsible Supply Chains of Minerals from High-Risk Areas and related supplements, Calix conducted further due diligence on its supply chain to assess the source and chain of custody of the conflict minerals, including taking the following actions:
•Collection of conflict minerals information from the supply chain utilizing the CMRT
•Reviews of supplier, smelter and refinery information in CMRT responses for plausibility, consistency and completeness
•Follow-up efforts with suppliers for information about identified smelters and refiners
•Engagement with suppliers for further conflict minerals reporting upstream through the supply chain
•Review whether identified smelters and refiners, including those identified as a source of conflict minerals originating from the Covered Countries, are listed as participating in the Responsible Minerals Assurance Process (“RMAP”) operated by the RMI or otherwise verified as conflict free by industry recognized programs
•Conduct supplier outreach as recommended and in support of RMI initiatives, particularly for non-responding suppliers
Based on the due diligence conducted, we determined that 178 of the smelters and refiners identified to supply conflict minerals originating in the Covered Countries are included on the RMI list of conformant, active and eligible smelters and refiners. Based on the information provided by our suppliers as of May 30, 2024, we believe that the facilities that may have been used to process the 3TG minerals in our products include the smelters and refiners listed in Appendix I to this CMR. Note that this list is likely to be both incomplete and over-inclusive of facilities in our supply chain. We are dependent on direct suppliers to identify the smelters and refiners in our supply chain. Although we request suppliers to provide information specific to the parts, components and products provided to us, most responses submitted are at a company-level, and not specific to our supply chain. In addition, many suppliers are disclosing that they have not yet completed their own due diligence and are unable to disclose a complete list of smelters and refiners. Pursuant to Rule 13p-1, this CMR is not subject to an independent private sector audit.
Ongoing Risk Management
We intend to continue our work with our manufacturing partners and suppliers to improve response rates to our conflict minerals surveys, including through direct and indirect outreach efforts, and to improve awareness upstream in the supply chain. We also expect to further refine conflict minerals assessments and inquiries as part of our supplier and manufacturer partner evaluation processes. This CMR is also available on Calix’s Investor Relations website at: https://investor-relations.calix.com under Governance – Governance Documents.
Forward-Looking Statements
Statements made in this report that are not statements of historical fact are forward-looking statements. Forward-looking statements are subject to the “safe harbor” provisions of the Private Securities Litigation Reform Act of 1995. Forward-looking statements are based on our current expectations and assumptions about our business and operations and are subject to risks and uncertainties that could cause actual results to differ materially from expectations. These risks and uncertainties include the effect of changes in laws and regulations, economic, market and business conditions, the performance and operations of third-party partners and suppliers, availability of critical components and materials, and other risks as described in our Form 10-K and our quarterly reports on Form 10-Q, each as filed with the SEC. Forward-looking statements speak only as of the date the statements are made and are based on information available to us at the time those statements are made and/or management’s good faith belief as of that time with respect to future events. We assume no obligation to update forward-looking statements to reflect actual performance or results, changes in assumptions or changes in other factors affecting forward-looking information, except to the extent required by applicable securities laws.
Appendix I
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| Smelter ID | Smelter Name | Metal | Smelter Country |
| CID000019 | Aida Chemical Industries Co., Ltd. | Gold | JAPAN |
| CID000035 | Agosi AG | Gold | GERMANY |
| CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | Gold | UZBEKISTAN |
| CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | Gold | BRAZIL |
| CID000077 | Argor-Heraeus S.A. | Gold | SWITZERLAND |
| CID000082 | Asahi Pretec Corp. | Gold | JAPAN |
| CID000090 | Asaka Riken Co., Ltd. | Gold | JAPAN |
| CID000113 | Aurubis AG | Gold | GERMANY |
| CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Gold | PHILIPPINES |
| CID000157 | Boliden Ronnskar | Gold | SWEDEN |
| CID000176 | C. Hafner GmbH + Co. KG | Gold | GERMANY |
| CID000185 | CCR Refinery - Glencore Canada Corporation | Gold | CANADA |
| CID000197 | Yunnan Copper Industry Co., Ltd. | Gold | CHINA |
| CID000233 | Chimet S.p.A. | Gold | ITALY |
| CID000264 | Chugai Mining | Gold | JAPAN |
| CID000359 | DSC (Do Sung Corporation) | Gold | KOREA, REPUBLIC OF |
| CID000401 | Dowa | Gold | JAPAN |
| CID000425 | Eco-System Recycling Co., Ltd. East Plant | Gold | JAPAN |
| CID000689 | LT Metal Ltd. | Gold | KOREA, REPUBLIC OF |
| CID000694 | Heimerle + Meule GmbH | Gold | GERMANY |
| CID000707 | Heraeus Metals Hong Kong Ltd. | Gold | CHINA |
| CID000711 | Heraeus Germany GmbH Co. KG | Gold | GERMANY |
| CID000773 | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | Gold | CHINA |
| CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | Gold | CHINA |
| CID000814 | Istanbul Gold Refinery | Gold | TURKEY |
| CID000823 | Japan Mint | Gold | JAPAN |
| CID000855 | Jiangxi Copper Co., Ltd. | Gold | CHINA |
| CID000920 | Asahi Refining USA Inc. | Gold | UNITED STATES OF AMERICA |
| CID000924 | Asahi Refining Canada Ltd. | Gold | CANADA |
| CID000937 | JX Nippon Mining & Metals Co., Ltd. | Gold | JAPAN |
| CID000957 | Kazzinc | Gold | KAZAKHSTAN |
| CID000969 | Kennecott Utah Copper LLC | Gold | UNITED STATES OF AMERICA |
| CID000981 | Kojima Chemicals Co., Ltd. | Gold | JAPAN |
| CID001149 | Metalor Technologies (Hong Kong) Ltd. | Gold | CHINA |
| CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | Gold | SINGAPORE |
| CID001153 | Metalor Technologies S.A. | Gold | SWITZERLAND |
| CID001157 | Metalor USA Refining Corporation | Gold | UNITED STATES OF AMERICA |
| CID001188 | Mitsubishi Materials Corporation | Gold | JAPAN |
| | | | | | | | | | | |
| Smelter ID | Smelter Name | Metal | Smelter Country |
| CID001259 | Nihon Material Co., Ltd. | Gold | JAPAN |
| CID001326 | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Gold | RUSSIAN FEDERATION |
| CID001352 | MKS PAMP SA | Gold | SWITZERLAND |
| CID001386 | Prioksky Plant of Non-Ferrous Metals | Gold | RUSSIAN FEDERATION |
| CID001512 | Rand Refinery (Pty) Ltd. | Gold | SOUTH AFRICA |
| CID001555 | Samduck Precious Metals | Gold | KOREA, REPUBLIC OF |
| CID001916 | Shandong Gold Smelting Co., Ltd. | Gold | CHINA |
| CID001955 | Torecom | Gold | KOREA, REPUBLIC OF |
| CID001993 | United Precious Metal Refining, Inc. | Gold | UNITED STATES OF AMERICA |
| CID002003 | Valcambi S.A. | Gold | SWITZERLAND |
| CID002129 | Yokohama Metal Co., Ltd. | Gold | JAPAN |
| CID002509 | MMTC-PAMP India Pvt., Ltd. | Gold | INDIA |
| CID002511 | KGHM Polska Miedz Spolka Akcyjna | Gold | POLAND |
| CID002515 | Fidelity Printers and Refiners Ltd. | Gold | ZIMBABWE |
| CID002560 | Al Etihad Gold Refinery DMCC | Gold | UNITED ARAB EMIRATES |
| CID002561 | Emirates Gold DMCC | Gold | UNITED ARAB EMIRATES |
| CID002567 | Sudan Gold Refinery | Gold | SUDAN |
| CID002605 | Korea Zinc Co., Ltd. | Gold | KOREA, REPUBLIC OF |
| CID002762 | L'Orfebre S.A. | Gold | ANDORRA |
| CID002765 | Italpreziosi | Gold | ITALY |
| CID002778 | WIELAND Edelmetalle GmbH | Gold | GERMANY |
| CID002850 | AU Traders and Refiners | Gold | SOUTH AFRICA |
| CID002919 | Planta Recuperadora de Metales SpA | Gold | CHILE |
| CID002973 | Safimet S.p.A | Gold | ITALY |
| CID003153 | State Research Institute Center for Physical Sciences and Technology | Gold | LITHUANIA |
| CID003185 | African Gold Refinery* | Gold | UGANDA |
| CID003189 | NH Recytech Company | Gold | KOREA, REPUBLIC OF |
| CID003324 | QG Refining, LLC | Gold | UNITED STATES OF AMERICA |
| CID003383 | Sovereign Metals | Gold | INDIA |
| CID003497 | K.A. Rasmussen | Gold | NORWAY |
| CID003641 | Gold by Gold Colombia | Gold | COLOMBIA |
| CID000211 | Changsha South Tantalum Niobium Co., Ltd. | Tantalum | CHINA |
| CID000456 | Exotech Inc. | Tantalum | UNITED STATES OF AMERICA |
| CID000460 | F&X Electro-Materials Ltd. | Tantalum | CHINA |
| CID000616 | XIMEI RESOURCES (GUANGDONG) LIMITED | Tantalum | CHINA |
| CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Tantalum | CHINA |
| CID000917 | Jiujiang Tanbre Co., Ltd. | Tantalum | CHINA |
| CID001076 | AMG Brasil | Tantalum | BRAZIL |
| CID001163 | Metallurgical Products India Pvt., Ltd. | Tantalum | INDIA |
| CID001175 | Mineracao Taboca S.A. | Tantalum | BRAZIL |
| CID001192 | Mitsui Mining and Smelting Co., Ltd. | Tantalum | JAPAN |
| CID001200 | NPM Silmet AS | Tantalum | ESTONIA |
| | | | | | | | | | | |
| Smelter ID | Smelter Name | Metal | Smelter Country |
| CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | Tantalum | CHINA |
| CID001508 | QuantumClean | Tantalum | UNITED STATES OF AMERICA |
| CID001522 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | Tantalum | CHINA |
| CID001769 | Solikamsk Magnesium Works OAO | Tantalum | RUSSIAN FEDERATION |
| CID001869 | Taki Chemical Co., Ltd. | Tantalum | JAPAN |
| CID001891 | Telex Metals | Tantalum | UNITED STATES OF AMERICA |
| CID001969 | Ulba Metallurgical Plant JSC | Tantalum | KAZAKHSTAN |
| CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | Tantalum | CHINA |
| CID002504 | D Block Metals, LLC | Tantalum | UNITED STATES OF AMERICA |
| CID002505 | FIR Metals & Resource Ltd. | Tantalum | CHINA |
| CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Tantalum | CHINA |
| CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | Tantalum | CHINA |
| CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Tantalum | CHINA |
| CID002539 | KEMET de Mexico | Tantalum | MEXICO |
| CID002544 | TANIOBIS Co., Ltd. | Tantalum | THAILAND |
| CID002545 | TANIOBIS GmbH | Tantalum | GERMANY |
| CID002548 | Materion Newton Inc. | Tantalum | UNITED STATES OF AMERICA |
| CID002549 | TANIOBIS Japan Co., Ltd. | Tantalum | JAPAN |
| CID002550 | TANIOBIS Smelting GmbH & Co. KG | Tantalum | GERMANY |
| CID002557 | Global Advanced Metals Boyertown | Tantalum | UNITED STATES OF AMERICA |
| CID002558 | Global Advanced Metals Aizu | Tantalum | JAPAN |
| CID002707 | Resind Industria e Comercio Ltda. | Tantalum | BRAZIL |
| CID002842 | Jiangxi Tuohong New Raw Material | Tantalum | CHINA |
| CID004054 | PowerX Ltd. | Tantalum | RWANDA |
| CID000228 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | Tin | CHINA |
| CID000292 | Alpha | Tin | UNITED STATES OF AMERICA |
| CID000402 | Dowa | Tin | JAPAN |
| CID000438 | EM Vinto | Tin | N.A.BOLIVIA (Plurinational STATE OF) |
| CID000448 | Estanho de Rondonia S.A. | Tin | BRAZIL |
| CID000468 | Fenix Metals | Tin | POLAND |
| CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | Tin | CHINA |
| CID000555 | Gejiu Zili Mining And Metallurgy Co., Ltd. | Tin | CHINA |
| CID001070 | China Tin Group Co., Ltd. | Tin | CHINA |
| CID001105 | Malaysia Smelting Corporation (MSC) | Tin | MALAYSIA |
| CID001142 | Metallic Resources, Inc. | Tin | UNITED STATES OF AMERICA |
| CID001173 | Mineracao Taboca S.A. | Tin | BRAZIL |
| CID001182 | Minsur | Tin | PERU |
| CID001191 | Mitsubishi Materials Corporation | Tin | JAPAN |
| CID001231 | Jiangxi New Nanshan Technology Ltd. | Tin | CHINA |
| CID001337 | Operaciones Metalurgicas S.A. | Tin | N.A.BOLIVIA (Plurinational STATE OF) |
| | | | | | | | | | | |
| Smelter ID | Smelter Name | Metal | Smelter Country |
| CID001453 | PT Mitra Stania Prima | Tin | INDONESIA |
| CID001460 | PT Refined Bangka Tin | Tin | INDONESIA |
| CID001477 | PT Timah Tbk Kundur | Tin | INDONESIA |
| CID001482 | PT Timah Tbk Mentok | Tin | INDONESIA |
| CID001486 | PT Timah Nusantara | Tin | INDONESIA |
| CID001490 | PT Tinindo Inter Nusa | Tin | INDONESIA |
| CID001539 | Rui Da Hung | Tin | TAIWAN, PROVINCE OF CHINA |
| CID001758 | Soft Metais Ltda. | Tin | BRAZIL |
| CID001898 | Thaisarco | Tin | THAILAND |
| CID002015 | VQB Mineral and Trading Group JSC | Tin | VIET NAM |
| CID002036 | White Solder Metalurgia e Mineracao Ltda. | Tin | BRAZIL |
| CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | Tin | CHINA |
| CID002180 | Tin Smelting Branch of Yunnan Tin Co., Ltd. | Tin | CHINA |
| CID002468 | Magnu's Minerais Metais e Ligas Ltda. | Tin | BRAZIL |
| CID002517 | O.M. Manufacturing Philippines, Inc. | Tin | PHILIPPINES |
| CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Tin | VIET NAM |
| CID002706 | Resind Industria e Comercio Ltda. | Tin | BRAZIL |
| CID002756 | Super Ligas | Tin | BRAZIL |
| CID002773 | Aurubis Beerse | Tin | BELGIUM |
| CID002774 | Aurubis Berango | Tin | SPAIN |
| CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | Tin | CHINA |
| CID003190 | Chifeng Dajingzi Tin Industry Co., Ltd. | Tin | CHINA |
| CID003325 | Tin Technology & Refining | Tin | UNITED STATES OF AMERICA |
| CID003387 | Luna Smelter, Ltd. | Tin | RWANDA |
| CID003449 | PT Mitra Sukses Globalindo | Tin | INDONESIA |
| CID003582 | Fabrica Auricchio Industria e Comercio Ltda. | Tin | BRAZIL |
| CID003831 | DS Myanmar | Tin | MYANMAR |
| CID003868 | PT Putera Sarana Shakti (PT PSS) | Tin | INDONESIA |
| CID004065 | Mining Minerals Resources SARL | Tin | CONGO, DEMOCRATIC REPUBLIC OF THE |
| CID000004 | A.L.M.T. Corp. | Tungsten | JAPAN |
| CID000105 | Kennametal Huntsville | Tungsten | UNITED STATES OF AMERICA |
| CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | Tungsten | CHINA |
| CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | Tungsten | CHINA |
| CID000568 | Global Tungsten & Powders LLC | Tungsten | UNITED STATES OF AMERICA |
| CID000766 | Hunan Chenzhou Mining Co., Ltd. | Tungsten | CHINA |
| CID000825 | Japan New Metals Co., Ltd. | Tungsten | JAPAN |
| CID000966 | Kennametal Fallon | Tungsten | UNITED STATES OF AMERICA |
| CID002044 | Wolfram Bergbau und Hutten AG | Tungsten | AUSTRIA |
| CID002082 | Xiamen Tungsten Co., Ltd. | Tungsten | CHINA |
| CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Tungsten | CHINA |
| CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | Tungsten | CHINA |
| | | | | | | | | | | |
| Smelter ID | Smelter Name | Metal | Smelter Country |
| CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Tungsten | CHINA |
| CID002318 | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Tungsten | CHINA |
| CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | Tungsten | CHINA |
| CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | Tungsten | CHINA |
| CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | Tungsten | CHINA |
| CID002502 | Asia Tungsten Products Vietnam Ltd. | Tungsten | VIET NAM |
| CID002513 | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | Tungsten | CHINA |
| CID002541 | H.C. Starck Tungsten GmbH | Tungsten | GERMANY |
| CID002542 | TANIOBIS Smelting GmbH & Co. KG | Tungsten | GERMANY |
| CID002543 | Masan High-Tech Materials | Tungsten | VIET NAM |
| CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Tungsten | CHINA |
| CID002589 | Niagara Refining LLC | Tungsten | UNITED STATES OF AMERICA |
| CID002641 | China Molybdenum Tungsten Co., Ltd. | Tungsten | CHINA |
| CID002645 | Ganzhou Haichuang Tungsten Co., Ltd. | Tungsten | CHINA |
| CID002649 | Hydrometallurg, JSC | Tungsten | RUSSIAN FEDERATION |
| CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Tungsten | BRAZIL |
| CID003468 | Cronimet Brasil Ltda | Tungsten | BRAZIL |
* Certain surveyed suppliers reported potential sourcing of 3TG in 2023 from CID003185 - African Gold Refinery (“AGR”). To our knowledge, AGR is a gold smelter in a Covered Country and is not currently listed as a conformant or active facility by the RMI. Furthermore, on March 17, 2022, the United States Department of Treasury’s Office of Foreign Assets Control designated AGR as a Specially Designated National. Calix has not identified any direct transactions or contractual relationships with AGR, and to date has not received confirmation from any of our suppliers that they utilized 3TG sourced from AGR in any of Calix’s products in 2023. Calix continues to work with our suppliers to ensure improved transparency and accountability in our supply chain.
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