UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
BLACKBERRY LIMITED
(Exact name of the registrant as specified in its charter)
| | | | | | | | | | | | | | |
| A6 | | 001-38232 | | 98-0164498 |
| (State or other jurisdiction of incorporation or organization) | | (Commission File Number) | | (IRS Employer Identification No.) |
| | | | |
2200 University Avenue East Waterloo, Ontario, Canada | | | | N2K 0A7 |
| (Address of principal executive offices) | | | | (Zip code) |
| | | | |
| Phil Kurtz | | | | (519) 888-7465 x12359 |
| (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:
_√__ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
Introduction
Transportation and Asset Tracking hardware products manufactured on behalf of BlackBerry Limited (“BlackBerry”) in 2023 contain Conflict Minerals that are necessary to their functionality or production. BlackBerry did not source these Conflict Minerals directly. These Conflict Minerals underwent various processing steps by multiple parties along the supply chain before being manufactured into electronic components and materials by sub-tier suppliers of BlackBerry, and subsequently assembled into BlackBerry products via an electronics manufacturing services provider.
BlackBerry continues to recognize its shared responsibility in relation to the responsible mining and sourcing of minerals in conflict-affected regions of the world, including the Democratic Republic of Congo and its neighboring countries. In early 2012, BlackBerry first adopted and published its Responsible Minerals Policy, consistent with its existing Supplier Code of Conduct and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The policy, available at: http://www.blackberry.com/responsiblemineralspolicy, establishes expectations within its supply chain that creates demand for responsibly sourced minerals used in BlackBerry's Transportation and Asset Tracking products.
Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Conflict Minerals Disclosure
BlackBerry has concluded in good faith that during the reporting period from January 1 to December 31, 2023,
i) it has contracted to manufacture products in which “Conflict Minerals” (as defined in Section 1, Item 1.01 (d)(3) of Form SD) are necessary to the functionality or production of such products (“Necessary Conflict Minerals”); and
ii) based on a “reasonable country of origin inquiry”:
a) a portion of its Necessary Conflict Minerals may have originated in the Democratic Republic of the Congo or an adjoining country (collectively referred to as the “Covered Countries”) and it has reason to believe that those Necessary Conflict Minerals are not from recycled or scrap sources; and
b) a portion of its Necessary Conflict Minerals has an unknown origin.
BlackBerry’s Reasonable Country of Origin Inquiry (RCOI) included a combination of measures to determine whether the Necessary Conflict Minerals in BlackBerry’s products originated from the Covered Countries. BlackBerry’s primary means of determining the country of origin of Necessary Conflict Minerals is based on information from the manufacturers of the components and materials used in BlackBerry hardware products. Considering its remote position in the supply chain relative to the processors of Conflict Minerals, BlackBerry relies on information provided by manufacturers to complete the RCOI and support subsequent due diligence.
The information obtained includes the identities of the processors of Conflict Minerals necessary to the functionality or production of the components and materials manufactured by the sub-tier suppliers. BlackBerry then compared the identified processors (smelters and refiners) to the Responsible Minerals Initiative’s (RMI’s) Conformant Smelter Sourcing Information report to determine if the processors are sourcing conflict minerals which originated in the Covered Countries. The RMI Conformant Smelter Sourcing Information report contains non-public information collected by the RMI, the London Bullion Market Association (LBMA), and the Responsible Jewelry Council (RJC) while conducting their Responsible Minerals Assurance Process audits of smelters and refiners. Although most country of origin information is provided by the RMI, LBMA and RJC in aggregate form, the RMI does identify specifically which processors source from the Covered Countries. As a member of the RMI, BlackBerry has access to this report.
Some suppliers have included country of origin information with their survey responses. Additional country of origin information was also made available to BlackBerry through smelters and refiners, and other third-party or public sources.
BlackBerry evaluated the country of origin data as provided by the different sources for consistency and plausibility, using available information including published mineral production references to inform our final RCOI results.
Subsequent to the above determination, BlackBerry has filed a Conflict Minerals Report as Exhibit 1.01 hereto, which is publicly available at https://www.blackberry.com/us/en/company/investors/corporate-governance-global.
The foregoing disclosure is qualified in its entirety by reference to the Conflict Minerals Report filed as Exhibit 1.01 hereto, which is incorporated by reference herein.
Section 2 – Exhibits
Item 2.01 Exhibits
* * * * *
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 duly authorized undersigned.
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BLACKBERRY LIMITED | | | |
| | | | |
| By: | /s/ Phil Kurtz | | Date: May 13, 2024 | |
| Name: | Phil Kurtz | | | |
| Title: | Chief Legal Officer and Corporate Secretary | | | |
* * * * *
BlackBerry Limited
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2023
INTRODUCTION
This Conflict Minerals Report for BlackBerry Limited (“BlackBerry”, “Company,” “we,” or “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, which implements Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, (the “Rule”) for the reporting period from January 1 to December 31, 2023.
The Rule imposes certain reporting obligations on U.S Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain tantalum, tin, tungsten, or gold (defined by Item 1.01(d)(3) of Form SD as “Conflict Minerals”), that are necessary to the functionality or production of those products. If the SEC registrant has reason to believe that any of those Conflict Minerals may have originated in the Democratic Republic of the Congo or an adjoining country (“Covered Countries”), or is unable to determine the country of origin of those Conflict Minerals, the SEC registrant is required to submit a Conflict Minerals Report to the SEC that includes a description of the measures it took to exercise due diligence on the Conflict Minerals’ source and chain of custody.
Transportation and Asset Tracking hardware products manufactured on behalf of BlackBerry in 2023 contain Conflict Minerals including tantalum, tin, tungsten, and gold that are necessary to their functionality or production (“Necessary Conflict Minerals”). BlackBerry did not source these Conflict Minerals directly. These Conflict Minerals were typically commingled with minerals of varied provenance and then processed using chemical and/or thermal methods into purified metals and compounds. They are then either further processed and/or subsequently manufactured into components and materials by sub-tier suppliers of BlackBerry, and finally assembled into end products via an electronics manufacturing services provider.
For the reporting period from January 1 to December 31, 2023, BlackBerry conducted a Reasonable Country of Origin Inquiry (“RCOI”). A description of BlackBerry’s RCOI is included in Form SD. The results of our RCOI were as follows:
a) a portion of our Necessary Conflict Minerals may have originated in a Covered Country and we have reason to believe that those Necessary Conflict Minerals are not from recycle or scrap sources; and
b) a portion of our Necessary Conflict Minerals has an unknown origin.
The statements below are based on the due diligence activities performed to date and in good faith by BlackBerry and are based on the information available through March 31, 2024. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to: incomplete supplier, smelter, or refiner data; errors or omissions by suppliers, smelters or refiners; evolving definition and confirmation of smelters and refiners by the Responsible Minerals Initiative (the “RMI”); incomplete or inaccurate information from industry or other third-party sources; or aggregated data which is not wholly attributable to the parts, suppliers, smelters or refiners existing in BlackBerry’s supply chain.
DUE DILIGENCE MEASURES
We conducted due diligence on the source and chain of custody of the Necessary Conflict Minerals contained in products that we contracted to manufacture as described above to ascertain whether these minerals originated in a Covered Country and directly or indirectly financed or benefited non-state armed groups in any of these countries.
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Design of Our Due Diligence Measures With consideration of our scale and position in the supply chain, we have designed our Conflict Minerals due diligence measures to conform with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016) (the “OECD Guidance”), as applicable for tantalum, tin, tungsten and gold and for downstream companies (as the term is defined in the OECD Guidance), in all relevant material respects: 1.establish strong company management systems for Conflict Minerals supply chain due diligence; 2.identify and assess Conflict Minerals risks in our supply chain; 3.design and implement strategies to respond to Conflict Minerals risks identified; 4.contribute to independent third-party audits of the due diligence practices of Conflict Minerals smelters and refiners by participating in industry organizations; and 5.report on our Conflict Minerals supply chain due diligence activities. |
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Due Diligence Measures Performed BlackBerry’s due diligence measures during, and in support of, the reporting year included the following activities:
Step 1: Establish strong company management systems for Conflict Minerals supply chain due diligence 1)Implemented our Responsible Minerals Policy by conducting due diligence on the source of Conflict Minerals contained in BlackBerry’s Transportation and Asset Tracking hardware products; 2)Maintained internal resources to advance BlackBerry’s Conflict Minerals Program and implement our Responsible Minerals Policy; 3)Maintained BlackBerry EthicsLink as a grievance mechanism support tool for use by employees and third parties as a confidential means of reporting violations of our policies and monitored the Responsible Minerals Initiative (the “RMI”) Grievance Report and discussions for any applicable issues; and 4)Maintained records associated with the implementation of BlackBerry’s due diligence process in accordance with specified requirements (minimum 5-year retention).
Step 2: Identify and assess risk in the supply chain 5)Identified relevant sub-tier suppliers with the potential for providing materials, components, subassemblies, or finished goods containing at least one of the Necessary Conflict Minerals; 6)Obtained information from relevant sub-tier suppliers through the RMI Conflict Minerals Reporting Template (“CMRT”), version 6.31 or later. This approach allows us to identify sourcing and Conflict Minerals due diligence information pertaining to BlackBerry’s supply chain, including the identification of smelters and refiners in the supply chains of BlackBerry’s sub-tier suppliers; 7)Reviewed CMRT submissions for completeness and data credibility against BlackBerry criteria and third-party data sources; and 8)Used information: as submitted by suppliers in the CMRT; as provided by the RMI as a benefit of our membership; and as collected from other third-party sources to conduct an RCOI as described in BlackBerry’s Form SD report.
Step 3: Design and implement a strategy to respond to identified risks 9)Provided due diligence guidance and communicated issues requiring corrective action based on assessments in Step 2 to relevant sub-tier suppliers. |
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Step 4: Carry out independent third-party audit of due diligence practices 10)Relied upon the due diligence conducted on smelters and refiners by the RMI’s Responsible Minerals Assurance Process (the “RMAP”). The RMAP relies on independent private sector auditors to audit the source, including mines of origin and chain of custody of the Conflict Minerals used by smelters and refiners that agree to participate in the RMAP. The smelters and refiners found to be RMAP conformant are those which the independent auditor has verified the responsible sourcing of minerals in conformance with RMAP requirements; and 11)Maintained an active membership in the RMI. Step 5: Report on supply chain due diligence
12)As required under Section 13(p) of the Securities and Exchange Act of 1934, BlackBerry has filed a Form SD which includes this Conflict Minerals Report and made such information available on our website, demonstrating our progress in implementing our Responsible Minerals Policy. |
Independent Private Sector Audit
This Conflict Minerals Report has not been subject to an independent private sector audit (“IPSA”). Per guidance issued by the SEC on April 29, 2014 and the related order subsequently issued on May 2, 2014, only issuers who describe their products as “DRC conflict free” are subject to an IPSA.
DUE DILIGENCE DETERMINATION
On the basis of the due diligence measures detailed above, which are on the source and chain of custody of the Conflict Minerals in BlackBerry’s products, BlackBerry describes the following products as “DRC Conflict Undeterminable” *:
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| Product Category |
| BlackBerry’s Transportation and Asset Tracking hardware products |
*DRC conflict undeterminable products are those for which we were unable to determine that such products do not directly or indirectly finance or benefit armed groups in Covered Countries.
Facilities Processing Conflict Minerals
As described in Form SD, BlackBerry compiled the list of facilities processing Conflict Minerals (smelters and refiners) by surveying the manufacturers of the components and materials used in BlackBerry products. The survey responses were either specific to the components used in BlackBerry products or represented a broader segment of the manufacturer’s portfolio. The latter could result in the over-reporting of smelters and refiners (i.e., the inclusion of smelters and refiners who supply conflict minerals to the manufacturer for use in components and materials not actually used in BlackBerry products).
A summary of the status of the smelters and refiners which have been reported by these manufacturers, is provided in Table 1. The smelters and refiners are listed in Table 2. Facilities reported by manufacturers who do not meet the RMI’s definition of a “refiner” or “smelter” are not included in these tables.
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| Table 1: Status Summary of Facilities Processing Conflict Minerals |
| Conflict Mineral | Total | Conflict-Free Status** |
| DRC Conflict-Free | Unknown |
| Gold | 90 | 88 (98%) | 2 (2%) |
| Tantalum | 32 | 32 (100%) | 0 (0%) |
| Tin | 65 | 65 (100%) | 0 (0%) |
| Tungsten | 31 | 31 (100%) | 0 (0%) |
| All | 218 | 216 (99%) | 2 (1%) |
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| Table 2: List of Facilities Processing Conflict Minerals |
| Conflict Mineral | Name of Smelter or Refiner Processing Conflict Mineral | Location of Smelter or Refiner | Conflict-Free Status** |
| Gold | Abington Reldan Metals, LLC | United States of America | DRC Conflict-Free |
| Gold | Advanced Chemical Company | United States of America | Unknown |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | Unknown |
| Gold | Agosi A.G. | Germany | DRC Conflict-Free |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | DRC Conflict-Free |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | DRC Conflict-Free |
| Gold | Argor-Heraeus S.A. | Switzerland | DRC Conflict-Free |
| Gold | Asahi Pretec Corp. | Japan | DRC Conflict-Free |
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| Gold | Asahi Refining Canada Ltd. | Canada | DRC Conflict-Free |
| Gold | Asahi Refining USA Inc. | United States of America | DRC Conflict-Free |
| Gold | Asaka Riken Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Aurubis AG | Germany | DRC Conflict-Free |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | DRC Conflict-Free |
| Gold | Boliden AB | Sweden | DRC Conflict-Free |
| Gold | C. Hafner GmbH + Co. KG | Germany | DRC Conflict-Free |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | DRC Conflict-Free |
| Gold | Chimet S.p.A. | Italy | DRC Conflict-Free |
| Gold | Chugai Mining | Japan | DRC Conflict-Free |
| Gold | Dowa | Japan | DRC Conflict-Free |
| Gold | DSC (Do Sung Corporation) | South Korea | DRC Conflict-Free |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | DRC Conflict-Free |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | DRC Conflict-Free |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | DRC Conflict-Free |
| Gold | Gold by Gold Columbia | Columbia | DRC Conflict-Free |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | DRC Conflict-Free |
| Gold | Heimerle + Meule GmbH | Germany | DRC Conflict-Free |
| Gold | Heraeus Germany GmbH Co. KG | Germany | DRC Conflict-Free |
| Gold | Heraeus Metals Hong Kong Ltd. | China | DRC Conflict-Free |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | DRC Conflict-Free |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Istanbul Gold Refinery | Turkey | DRC Conflict-Free |
| Gold | Italpreziosi | Italy | DRC Conflict-Free |
| Gold | Japan Mint | Japan | DRC Conflict-Free |
| Gold | Jiangxi Copper Co., Ltd. | China | DRC Conflict-Free |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | DRC Conflict-Free |
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| Gold | Kazzinc | Kazakhstan | DRC Conflict-Free |
| Gold | Kennecott Utah Copper LLC | United States of America | DRC Conflict-Free |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | DRC Conflict-Free |
| Gold | Kojima Chemicals Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Korea Zinc Co., Ltd. | Korea (Republic Of) | DRC Conflict-Free |
| Gold | L'Orfebre S.A. | Andorra | DRC Conflict-Free |
| Gold | LS MnM Inc. | Korea (Republic Of) | DRC Conflict-Free |
| Gold | LT Metal Ltd. | Korea (Republic Of) | DRC Conflict-Free |
| Gold | Materion | United States of America | DRC Conflict-Free |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | DRC Conflict-Free |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | DRC Conflict-Free |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | DRC Conflict-Free |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | DRC Conflict-Free |
| Gold | Metalor Technologies S.A. | Switzerland | DRC Conflict-Free |
| Gold | Metalor USA Refining Corporation | United States of America | DRC Conflict-Free |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | DRC Conflict-Free |
| Gold | Mitsubishi Materials Corporation | Japan | DRC Conflict-Free |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | MKS PAMP SA | Switzerland | DRC Conflict-Free |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | DRC Conflict-Free |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | DRC Conflict-Free |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | DRC Conflict-Free |
| Gold | NH Recytech Company | Korea (Republic Of) | DRC Conflict-Free |
| Gold | Nihon Material Co., Ltd. | Japan | DRC Conflict-Free |
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| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | DRC Conflict-Free |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Planta Recuperadora de Metales SpA | Chile | DRC Conflict-Free |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | DRC Conflict-Free |
| Gold | PX Precinox S.A. | Switzerland | DRC Conflict-Free |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | DRC Conflict-Free |
| Gold | REMONDIS PMR B.V. | Netherlands | DRC Conflict-Free |
| Gold | Royal Canadian Mint | Canada | DRC Conflict-Free |
| Gold | SAFINA A.S. | Czechia | DRC Conflict-Free |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | DRC Conflict-Free |
| Gold | Shandong Gold Smelting Co., Ltd. | China | DRC Conflict-Free |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | DRC Conflict-Free |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | DRC Conflict-Free |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | DRC Conflict-Free |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | SungEel HiMetal Co., Ltd. | Korea (Republic Of) | DRC Conflict-Free |
| Gold | T.C.A S.p.A | Italy | DRC Conflict-Free |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | DRC Conflict-Free |
| Gold | Tokuriki Honten Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan | DRC Conflict-Free |
| Gold | Torecom | Korea (Republic Of) | DRC Conflict-Free |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | DRC Conflict-Free |
| Gold | United Precious Metal Refining, Inc. | United States of America | DRC Conflict-Free |
| Gold | Valcambi S.A. | Switzerland | DRC Conflict-Free |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | DRC Conflict-Free |
| | | | | | | | | | | |
| Gold | WIELAND Edelmetalle GmbH | Germany | DRC Conflict-Free |
| Gold | Yamakin Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Yokohama Metal Co., Ltd. | Japan | DRC Conflict-Free |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | DRC Conflict-Free |
| Tantalum | AMG Brasil | Brazil | DRC Conflict-Free |
| Tantalum | D Block Metals, LLC | United States of America | DRC Conflict-Free |
| Tantalum | F&X Electro-Materials Ltd. | China | DRC Conflict-Free |
| Tantalum | FIR Metals & Resource Ltd. | China | DRC Conflict-Free |
| Tantalum | Global Advanced Metals Aizu | Japan | DRC Conflict-Free |
| Tantalum | Global Advanced Metals Boyertown | United States of America | DRC Conflict-Free |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | Jiangxi Tuohong New Raw Material | China | DRC Conflict-Free |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | KEMET de Mexico | Mexico | DRC Conflict-Free |
| Tantalum | Materion Newton Inc. | United States of America | DRC Conflict-Free |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | DRC Conflict-Free |
| Tantalum | Mineracao Taboca S.A. | Brazil | DRC Conflict-Free |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | DRC Conflict-Free |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | NPM Silmet AS | Estonia | DRC Conflict-Free |
| Tantalum | QuantumClean | United States of America | DRC Conflict-Free |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | DRC Conflict-Free |
| | | | | | | | | | | |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | Taki Chemical Co., Ltd. | Japan | DRC Conflict-Free |
| Tantalum | TANIOBIS Co., Ltd. | Thailand | DRC Conflict-Free |
| Tantalum | TANIOBIS GmbH | Germany | DRC Conflict-Free |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan | DRC Conflict-Free |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany | DRC Conflict-Free |
| Tantalum | Telex Metals | United States of America | DRC Conflict-Free |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | DRC Conflict-Free |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China | DRC Conflict-Free |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | DRC Conflict-Free |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | DRC Conflict-Free |
| Tin | Alpha | United States of America | DRC Conflict-Free |
| Tin | Aurubis Beerse | Belgium | DRC Conflict-Free |
| Tin | Aurubis Berango | Spain | DRC Conflict-Free |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | DRC Conflict-Free |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | DRC Conflict-Free |
| Tin | China Tin Group Co., Ltd. | China | DRC Conflict-Free |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | DRC Conflict-Free |
| Tin | CRM Synergies | Spain | DRC Conflict-Free |
| Tin | CV Ayi Jaya | Indonesia | DRC Conflict-Free |
| Tin | CV Venus Inti Perkasa | Indonesia | DRC Conflict-Free |
| Tin | Dowa | Japan | DRC Conflict-Free |
| Tin | DS Myanmar | Myanmar | DRC Conflict-Free |
| Tin | EM Vinto | Bolivia | DRC Conflict-Free |
| Tin | Estanho de Rondonia S.A. | Brazil | DRC Conflict-Free |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | DRC Conflict-Free |
| | | | | | | | | | | |
| Tin | Fenix Metals | Poland | DRC Conflict-Free |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | DRC Conflict-Free |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | DRC Conflict-Free |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | DRC Conflict-Free |
| Tin | Jiangxi New Nanshan Technology Ltd. | China | DRC Conflict-Free |
| Tin | Luna Smelter, Ltd. | Rwanda | DRC Conflict-Free |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | DRC Conflict-Free |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | DRC Conflict-Free |
| Tin | Metallic Resources, Inc. | United States of America | DRC Conflict-Free |
| Tin | Mineracao Taboca S.A. | Brazil | DRC Conflict-Free |
| Tin | Minsur | Peru | DRC Conflict-Free |
| Tin | Mitsubishi Materials Corporation | Japan | DRC Conflict-Free |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | DRC Conflict-Free |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | DRC Conflict-Free |
| Tin | Operaciones Metalurgical S.A. | Bolivia | DRC Conflict-Free |
| Tin | PT Aries Kencana Sejahtera | Indonesia | DRC Conflict-Free |
| Tin | PT Artha Cipta Langgeng | Indonesia | DRC Conflict-Free |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | DRC Conflict-Free |
| Tin | PT Babel Inti Perkasa | Indonesia | DRC Conflict-Free |
| Tin | PT Babel Surya Alam Lestari | Indonesia | DRC Conflict-Free |
| Tin | PT Bangka Prima Tin | Indonesia | DRC Conflict-Free |
| Tin | PT Bangka Serumpun | Indonesia | DRC Conflict-Free |
| Tin | PT Bukit Timah | Indonesia | DRC Conflict-Free |
| Tin | PT Cipta Persada Mulia | Indonesia | DRC Conflict-Free |
| Tin | PT Menara Cipta Mulia | Indonesia | DRC Conflict-Free |
| Tin | PT Mitra Stania Prima | Indonesia | DRC Conflict-Free |
| Tin | PT Mitra Sukses Globalindo | Indonesia | DRC Conflict-Free |
| Tin | PT Premium Tin Indonesia | Indonesia | DRC Conflict-Free |
| Tin | PT Prima Timah Utama | Indonesia | DRC Conflict-Free |
| | | | | | | | | | | |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia | DRC Conflict-Free |
| Tin | PT Rajawali Rimba Perkasa | Indonesia | DRC Conflict-Free |
| Tin | PT Rajehan Ariq | Indonesia | DRC Conflict-Free |
| Tin | PT Refined Bangka Tin | Indonesia | DRC Conflict-Free |
| Tin | PT Sariwiguna Binasentosa | Indonesia | DRC Conflict-Free |
| Tin | PT Stanindo Inti Perkasa | Indonesia | DRC Conflict-Free |
| Tin | PT Sukses Inti Makmur | Indonesia | DRC Conflict-Free |
| Tin | PT Timah Tbk Kundur | Indonesia | DRC Conflict-Free |
| Tin | PT Timah Tbk Mentok | Indonesia | DRC Conflict-Free |
| Tin | PT Timah Nusantara | Indonesia | DRC Conflict-Free |
| Tin | PT Tinindo Inter Nusa | Indonesia | DRC Conflict-Free |
| Tin | PT Tommy Utama | Indonesia | DRC Conflict-Free |
| Tin | Resind Industria e Comercio Ltda. | Brazil | DRC Conflict-Free |
| Tin | Rui Da Hung | Taiwan, Province Of China | DRC Conflict-Free |
| Tin | Super Ligas | Brazil | DRC Conflict-Free |
| Tin | Thaisarco | Thailand | DRC Conflict-Free |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | DRC Conflict-Free |
| Tin | Tin Technology & Refining | United States of America | DRC Conflict-Free |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | DRC Conflict-Free |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | DRC Conflict-Free |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | A.L.M.T. Corp. | Japan | DRC Conflict-Free |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam | DRC Conflict-Free |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Cronimet Brasil Ltda | Brazil | DRC Conflict-Free |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | DRC Conflict-Free |
| | | | | | | | | | | |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Global Tungsten & Powders LLC | United States of America | DRC Conflict-Free |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | DRC Conflict-Free |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | DRC Conflict-Free |
| Tungsten | Japan New Metals Co., Ltd. | Japan | DRC Conflict-Free |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Kennametal Fallon | United States of America | DRC Conflict-Free |
| Tungsten | Kennametal Huntsville | United States of America | DRC Conflict-Free |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province of China | DRC Conflict-Free |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Masan High-Tech Materials | Vietnam | DRC Conflict-Free |
| Tungsten | Niagara Refining LLC | United States of America | DRC Conflict-Free |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | DRC Conflict-Free |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany | DRC Conflict-Free |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | DRC Conflict-Free |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | DRC Conflict-Free |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | DRC Conflict-Free |
**Based on RMI’s Responsible Minerals Assurance Process (the “RMAP”) results through March 31, 2024. Facilities which are reported to be conformant to the RMAP or equivalent program are reasonably assumed to be “DRC Conflict-Free.” “DRC Conflict-Free” does not include facilities designated by the RMI as “Active” or any other status. In this report, one of the smelters and refiners reported by suppliers was designated as “Active” by the RMI and one was designated as “Non Conformant” by the RMI through March 31, 2024 for failing to undergo routine or follow-up audits within the required timeframe. Based on available evidence, none of these smelters source raw materials from the covered countries and could reasonably be assumed to be “DRC Conflict-Free”, however, lacking conclusive information such as RMAP audit completion, they have been labeled as “Unknown” in this report.
Countries of Origin of Conflict Minerals
By conducting a Reasonable Country of Origin Inquiry as described in Form SD, BlackBerry established a list of countries, provided in Table 3, from which the facilities listed in Table 2 may be sourcing Conflict Minerals. BlackBerry has no specific knowledge linking the Conflict Minerals originating in any specific country to the metals present in any of its Transportation and Asset Tracking hardware products. To protect the confidentiality of minerals sourcing by smelters and refiners, the Responsible Minerals Initiative (RMI), London Bullion Market Association (LBMA), and Responsible Jewelry Council (RJC) in almost all respects have aggregated country of origin data. Being the primary source of the information in this table, the provision of data in this manner by the RMI, LBMA, and RJC results in considerable uncertainty when correlating specific countries to specific smelters and refiners, and subsequently BlackBerry products.
| | | | | | | | | | | | | | |
| Table 3: Countries of Origin |
| Country | Gold | Tantalum | Tin | Tungsten |
| Argentina | X | | | |
| Australia | X | X | X | X |
| Austria | | | | X |
| Azerbaijan | X | | | |
| Benin | X | | | |
| Bolivia | X | | X | X |
| Botswana | X | | | |
| Brazil | X | X | X | X |
| Burkina Faso | X | | | |
| Burundi*** | | X | X | X |
| Cambodia | X | | | |
| Canada | X | | | |
| Chile | X | | | |
| China | X | X | X | X |
| Colombia | X | | | |
| Côte D'Ivoire | X | | | |
| Democratic Republic of Congo*** | X | X | X | X |
| Dominican Republic | X | | | |
| | | | | | | | | | | | | | |
| Ecuador | X | | | |
| Egypt | X | | | |
| Ethiopia | | X | | |
| Fiji | X | | | |
| Finland | X | | | |
| France | | X | | |
| French Guiana | X | | | |
| Georgia | X | | | |
| Ghana | X | | | |
| Guatemala | X | | | |
| Guinea | X | | | |
| Guyana | X | | | |
| Honduras | X | | | |
| Hong Kong | X | | | |
| Indonesia | X | | X | |
| Japan | X | | | |
| Kazakhstan | X | | | X |
| Kenya | X | | | |
| Korea, Republic of | X | | | |
| Kyrgyzstan | X | | | |
| Laos | X | | X | |
| Liberia | X | | | |
| Madagascar | | X | | |
| Malaysia | | | X | X |
| Mali | X | | | |
| | | | | | | | | | | | | | |
| Mauritania | X | | | |
| Mexico | X | | | X |
| Mongolia | X | | X | X |
| Morocco | X | | | |
| Mozambique | X | X | | |
| Myanmar | | | X | X |
| Namibia | X | | | |
| New Zealand | X | | | |
| Nicaragua | X | | | |
| Niger | X | | | |
| Nigeria | | X | X | X |
| Oman | X | | | |
| Panama | X | | | |
| Papua New Guinea | X | | | |
| Peru | X | | X | |
| Philippines | X | | | |
| Portugal | | | | X |
| Russian Federation | X | | X | X |
| Rwanda*** | | X | X | X |
| Saudi Arabia | X | | | |
| Senegal | X | | | |
| Serbia | X | | | |
| Sierra Leone | | X | | |
| South Africa | X | | | |
| Spain | X | X | X | X |
| | | | | | | | | | | | | | |
| Sudan | X | | | |
| Suriname | X | | | |
| Sweden | X | | | |
| Tanzania*** | X | | X | X |
| Thailand | X | | X | X |
| Turkey | X | | | |
| Uganda*** | | | | X |
| United Kingdom | | | X | X |
| United States of America | X | | | X |
| Uzbekistan | X | | | |
| Vietnam | | | X | X |
| Zambia*** | X | | | |
| Zimbabwe | X | | | |
*** “Covered Countries” which include the Democratic Republic of Congo and its adjoining countries.
Efforts to Determine the Conflict Minerals’ Mine or Location of Origin
BlackBerry’s efforts to determine the conflict minerals’ mine or location of origin included two approaches: (i) use of the CMRT as a method to query and transmit sourcing information along the supply chain; and (ii) reliance on, and support for, the RMAP as an independent third party audit solution through which mineral sources are identified and independently evaluated.
The CMRT helps a company to identify the smelters and refiners within its supply chain and their sources of minerals. The use of the CMRT by industry participants is dependent upon each tier in the supply chain collecting information from its direct suppliers and passing it on to customers. The amount of detail and quality of data being collected by this process is improving; however, considering the number of tiers within BlackBerry’s supply chain, we expect that several reporting cycles will be needed to refine data collection.
The source of minerals is valuable intellectual property for most smelters, and the OECD Guidance acknowledges that reporting of information may be limited by concerns of business confidentiality. An independent third-party audit solution such as the RMAP can offer an efficient means to address these confidentiality concerns and to help promote the reliability of information collected. BlackBerry has
therefore incorporated reliance on the RMAP as a key element of its due diligence process. Through the course of the RMAP smelter assessment process, independent auditors review information on the mines of origin for the smelters and refiners. To be conformant with the RMAP, smelters and refiners must have disclosed the identities of their mines or locations of origin to the auditors, and the auditors must have independently validated that sufficient evidence exists to support the sourcing claims and that those sources are DRC conflict-free.
BlackBerry is a member of the RMI and continues to support the implementation and expansion of the RMAP.
Steps to Improve Due Diligence
BlackBerry is committed to being a socially and environmentally responsible corporation, within our own activities and through those in our supply chain. Despite our small scale and remote position in the supply chain, we expect to continue to engage with relevant manufacturers and the broader industry to improve our due diligence on the source and chain of custody of the Necessary Conflict Minerals.
We intend to continue impressing upon the manufacturers our expectation that they apply the OECD Guidance in good faith. We also expect to continue to focus our efforts working with industry peers through the RMI to improve the systems of transparency and control and leverage those systems within our own supply chain.
Although circumstances may change necessitating an adjustment of plans, specific steps we are contemplating to further improve our reasonable due diligence in 2024 include:
1)Providing guidance for relevant manufacturers on Conflict Mineral reporting and the OECD Guidance;
2)Enhancing our messaging regarding the use of RMAP, or equivalent, validated smelters and refiners;
3)Evaluating the due diligence best practices of companies for possible implementation at BlackBerry;
4)Using the updated CMRT and latest smelter lists for collecting due diligence information from relevant manufacturers;
5)Continuing our participation in the RMI;
6)Reviewing our Responsible Minerals Policy for opportunities to expand our expectations for responsible minerals sourcing both within and beyond conflict-affected areas and revising as appropriate;
7)Monitoring for the development of new or changing legislation; and
8)Encouraging the responsible sourcing of minerals from the Democratic Republic of Congo and adjoining countries.
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