Valley View Road
Eden Prairie, MN 55344-3617
Conflict Minerals Report
for the year ended December 31, 2019
We are filing this Conflict Minerals Report for
the year ended December 31, 2019 pursuant to Rule
13p-1 under the Securities Exchange Act (17
Our policy is that we will not knowingly purchase
raw material items that contain Conflict Minerals that directly or
indirectly finance or benefit armed groups in the Democratic Republic of the Congo
(DRC) or the following adjoining countries: the Republic of the Congo,
the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania,
Conflict Minerals are defined in Section
1502(e)(4) of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection
Act, and are currently identified as columbite-tantalite (coltan), cassiterite,
gold, wolframite, or their derivatives, which are limited to tantalum, tin, and
tungsten. We consider gold, tantalum, tin, and tungsten necessary to the functionality
or production of certain of our products.
We are working with our suppliers to ensure our
suppliers are aware of our policy and have urged our suppliers to support this
policy. Our policy is to take continuous practical action to seek to ensure that
materials from the conflict region do not enter our supply chain or products by
obtaining certification of origin for materials covered by this policy.
Due Diligence Performed
We have performed a Reasonable Country of Origin
Inquiry (RCOI). The inquiry was designed to determine whether our
Conflict Minerals either did not originate in the DRC or an adjoining country
or came from recycled or scrap sources. We apply reasonable skepticism and judgment
in assessing statements from suppliers and look for discrepancies such as omissions
of Conflict Minerals and locations of the supplier.
We have taken a number of steps to exercise due
diligence on the source and chain of custody of Conflict Minerals. Our due diligence
is designed to be consistent with the Electronic Industry Citizenship Coalition
and the Global e-Sustainability Initiative (EICC-GeSI) approach. These
||We adopted a Conflict Minerals Policy / Position governing the
supply chain of Conflict Minerals.
||Based on our RCOI, we have notified relevant suppliers to ensure
they are aware of our Conflict Minerals Policy and have urged our suppliers to
support this policy.
||Our policy is available to our customers and suppliers from our
Website, has been provided to appropriate NVE employees, and sent to customers
and suppliers on request.
||We designated an employee responsible for
Conflict Minerals Policy compliance with the authority to conduct due diligence as necessary.
||We have performed due diligence on the source and chain of custody
of the Conflict Minerals that are included in our products and for which, based
on our RCOI, we have reason to believe may have originated in the DRC or an adjoining
country and may not have come from recycled or scrap sources.
||We have an established process to obtain information from our
suppliers concerning the origins of the metals used in the manufacture of our
||We require suppliers of items that may contain Conflict Minerals
to complete a EICC-GeSI Conflict Minerals reporting template.
||All of our suppliers of items containing Conflict Minerals have
provided some or all of EICC-GeSI Conflict Minerals reports, DRC conflict-free
designations from a recognized industry group, independent audits of a processing
facilitys supply chain, or other certifications or audits.
We identified the following products we manufactured or
contract to manufacture that may contain necessary Conflict Minerals during the
reporting period: sensors, couplers, peripheral integrated circuits, evaluation
kits, printed circuit boards, and evaluation boards.
Due Diligence Results
All of our suppliers have provided the reports we
require of them, however not all of our suppliers have complete information from
their suppliers. Therefore, despite the due diligence described above, we have
not yet been able to determine all of the facilities used to process the necessary
Conflict Minerals in our products or the countries of origin of all of the necessary
Conflict Minerals in our products. Based on our RCOI and due diligence, however,
we believe the great majority of the Conflict Minerals in our products either
(i) did not originate in the DRC or an adjoining country, (ii) came
from recycled or scrap sources, or (iii) came from smelters or refiners determined
to be compliant with the EICC-GeSI Conflict-Free Smelter Program assessment protocols.
Based on our RCOI and due diligence:
||We believe that all of our raw material metals did not originate
in the DRC or an adjoining country or came from recycled or scrap sources.
||We believe all Conflict Minerals used by our packaging vendors
to manufacture our sensors, couplers, and peripheral integrated circuit products
did not originate in the DRC or an adjoining country or came from recycled or
||We believe all materials used by printed circuit board manufacturers
and the components on those printed circuit boards did not originate in the DRC
or an adjoining country or came from recycled or scrap sources.
||Some of our suppliers of foundry wafers used in some
products, and some suppliers of certain components used in our evaluation boards,
have reported Conflict Minerals originating in the DRC or an adjoining country,
although the majority of those were from smelters or refiners determined to be
compliant with the EICC-GeSI Conflict-Free Smelter Program assessment protocols.
However, there are a small number of Conflict Mineral sources for which our suppliers
have not provided definitive documentation of origin, representing an extremely
small amount of material. The suppliers of those items have indicated they will
continue their due diligence to definitively determine all of the facilities used
to process Conflict Minerals. We are also seeking alternate suppliers for such
foundry wafers and components.
Future Due Diligence
We plan to continue to take practical action to
seek to ensure that materials from the conflict region do not enter our supply
chain or products.
Some of the statements made in this report constitute
forward-looking statements within the meaning of the Private Securities Litigation
Reform Act of 1995. These statements are subject to the safe harbor provisions
of the reform act. Forward-looking statements may be identified by the use of
the terminology such as may, will, expect, anticipate, intend, believe, estimate,
should, or continue, or the negatives of these terms or other variations on these
words or comparable terminology. Statements that relate to future plans or events
are forward-looking statements that are subject to certain risks and uncertainties
including, among others, the risk factors listed from time to time in our filings
with the SEC, including our Annual Report on Form
10-K for the fiscal year ended March 31, 2020 and other reports filed
with the SEC.