Cree, Inc.
CREE INC (Form: SD, Received: 05/30/2017 13:55:08)



UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

CREE, INC.
(Exact name of registrant as specified in its charter)


North Carolina
0-21154
56-1572719
(State or other jurisdiction of
incorporation)
(Commission File
Number)
(I.R.S. Employer
Identification Number)

4600 Silicon Drive
 
Durham, North Carolina
27703
(Address of principal executive offices)
(Zip Code)


Michael E. McDevitt (919) 407-5300
(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:

[ ü ]    Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.






Section 1 – Conflict Minerals Disclosure

Item 1.01
Conflict Minerals Disclosure and Report

In accordance with Rule 13p-1 under the Securities and Exchange Act of 1934, as amended, Cree, Inc. (“Cree”) hereby files this Form SD and the associated Conflict Minerals Report with the SEC. The Conflict Minerals Report includes a description of Cree’s due diligence program, the efforts Cree undertook in making its determinations with respect to products manufactured by it in 2016, and the results of such efforts.

Conflict Minerals Disclosure

A copy of Cree’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD and is publicly available at http://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals. No contents from Cree’s website are incorporated into this Form SD by this reference.

Item 1.02
Exhibit

The Conflict Minerals Report required by Item 1.01 of Form SD is filed as Exhibit 1.01 to this Form SD.

Section 2 – Exhibits

Item 2.01
Exhibits

Exhibit 1.01
 
Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016.






SIGNATURE

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.


 
CREE, INC.
 
 
 
 
 
 
 
 
 
By:
 
/s/ Michael E. McDevitt
 
 
 
Michael E. McDevitt
 
 
 
Executive Vice President and Chief Financial Officer


Date: May 30, 2017




Exhibit 1.01 to Form SD

Conflict Minerals Report

CREE_LOGOA04.JPG

CREE, INC.
For The Year Ended December 31, 2016
This Conflict Minerals Report (CMR) of Cree, Inc. (Cree, the Company, we, us, or our) for the year ended December 31, 2016 is filed to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule) promulgated by the Securities and Exchange Commission (the SEC) pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act). This CMR has been prepared on behalf of Cree management.

This CMR contains forward-looking statements regarding our business and conflict minerals efforts, including steps we intend to take to mitigate the risk that conflict minerals in our products benefit certain armed groups. Words such as “expects,” “intends,” “believes,” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this CMR. Additionally, statements concerning future matters that are not historical are forward-looking statements. Forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Risks, uncertainties, assumptions, and other factors that could cause or contribute to such differences in results and outcomes include, among other things, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our conflict minerals program and our ability to identify and mitigate related risks in our supply chain. We undertake no obligation to review or update any forward-looking statements to reflect events or circumstances occurring after filing this CMR with the SEC.

Cree has performed due diligence measures as required by the Rule with the goal of determining the chain of custody and country of origin information for the necessary conflict minerals, 1 also referred to as 3TGs, used in our products manufactured in 2016. In particular, we sought to determine whether any of the necessary conflict minerals in our product supply chains may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country, also referred to as the Covered Countries, and whether any conflict minerals originating in the Covered Countries directly or indirectly financed or benefited armed groups in the Covered Countries. As used herein, the term “manufactured” includes products manufactured or contracted to be manufactured by Cree.
_______________
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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 Democratic Republic of the Congo or an adjoining country.




Because not all suppliers have provided smelter and refiner data and the data provided by some of our suppliers is incomplete, Cree is unable at this time to determine the exact origin of the conflict minerals in all of the assemblies, components, and minerals supplied to us. Therefore, we cannot exclude the possibility that some conflict minerals used in our products manufactured in 2016 may have originated in the Covered Countries, come from sources other than recycled or scrap sources, or come from sources that directly or indirectly financed or benefited armed groups in the Covered Countries. We have obtained no information, however, to indicate that any conflict minerals used in our products manufactured in 2016 originated in the Covered Countries and directly or indirectly financed or benefited armed groups in the Covered Countries.

Pursuant to the Rule, Cree is submitting this CMR as an Exhibit to its Form SD.

Company and Product Overview
Cree is a leading innovator of lighting-class light emitting diode (LED) products, lighting products, and semiconductor products for power and radio-frequency (RF) applications. Our products are targeted for applications such as indoor and outdoor lighting, video displays, transportation, electronic signs and signals, power supplies, solar inverters, and wireless systems.

We develop and manufacture semiconductor materials and devices primarily based on silicon carbide (SiC), gallium nitride (GaN), and related compounds. Our LED products consist of LED components, LED chips, and SiC materials. Our lighting products primarily consist of LED lighting systems, lamps and bulbs. We design, manufacture and sell lighting systems, lamps, and bulbs for indoor and outdoor applications, with our primary focus on LED lighting systems for the commercial and industrial markets. In addition, we develop, manufacture and sell power products made from SiC and RF devices made from GaN.

The majority of our products are manufactured at our production facilities located in North Carolina, Wisconsin, and China. We also use contract manufacturers for certain aspects of product fabrication, assembly, and packaging.

Our SiC materials, in the form of substrates and boules, do not contain any 3TGs, and thus no further due diligence is required with respect to those products. All other Cree products have the potential to include one or more of the conflict minerals. Table 1 below outlines Cree’s products and provides typical conflict mineral content along with the percent of revenue per business unit.


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Table 1
Cree Business Unit
Percent of Cree Revenue*
Products
Percentage of Products that contain Conflict Minerals?
Typical Conflict Mineral Content by Weight Percentage
Au
Sn
W
Ta
LED Lighting Products
51%
LED Lamps and Bulbs
100%
0.1 - 1%
0.1 - 1%
< 0.1%
< 0.1%
LED Lighting
100%
0.05 - 1%
0.1 - 1%
< 0.1%
< 0.05%
Accessories
50-75%
< 0.1%
0 - 1%
< 0.05%
< 0.1%
LED Products
35%
LED Chips
100%
0.5 - 3%
0.2 - 10%
0 - 0.6%
0%
LED Components
100%
0.1 - 0.3%
0 - 0.3%
0 - 0.1%
0 - 0.1%
Modules + Drivers
100%
0.1 - 0.3%
0.1 - 0.5%
0 - 0.01%
0 - 0.1%
Accessories
30-50%
< 0.1%
< 0.5%
0%
0%
Wolfspeed Products
14%
Materials
0%
N/A
N/A
N/A
N/A
RF Die
100%
0.5 - 35%
0.2 - 10%
0 - 0.6%
0%
Power Diodes
100%
< 0.05%
< 0.05%
< 0.1%
0%
RF Transistor Packages
100%
0.01 - 0.1%
< 0.01%
0 - 85%
< 0.05%
*Note: Based on reported revenue for six months ended December 25, 2016.

Conflict Minerals Policy

Cree has adopted a Conflict Minerals Policy under which it expects its suppliers to develop internal conflict mineral policies, due diligence frameworks, and management systems that meet the minimum requirements of the guidelines developed by the Organisation for Economic Co-operation and Development (OECD). Our suppliers’ conflict minerals policies must be designed to identify and eliminate from use in products sold to Cree any conflict minerals which are known to come from sources funding armed groups in the DRC region. Cree requires its direct suppliers to source conflict minerals from smelters and refiners whose due diligence practices have been validated by an independent third party audit program such as the Conflict-Free Sourcing Initiative (CFSI) or its equivalent. Cree fully expects our suppliers to cooperate with us and to provide information to support these efforts, even if the supplier is not directly subject to the Act. Suppliers that do not reasonably comply with Cree’s Conflict Mineral Policy will be reviewed by Cree’s supply chain management to assess whether Cree will conduct business with those suppliers in the future.

To view Cree’s complete Conflict Minerals Policy, visit our webpage located at: http://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals. With this reference we are incorporating into this Conflict Minerals Report only our Conflicts Minerals Policy and not the entire contents of our webpage.

Description of Our RCOI Process
Cree’s scoping process included creating a master supplier list of potential in-scope suppliers for 2016 by filtering our supplier database to remove suppliers known to be outside of the scope of the reasonable country of origin inquiry (RCOI), such as service providers, equipment vendors, and

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indirect material suppliers. The objective of filtering was to identify only suppliers that provided to Cree items potentially containing 3TGs that were incorporated into final products in the calendar year 2016.

Once filtered, the master list was provided to Cree’s third-party conflict mineral compliance service provider (the CSP) to conduct a survey using the Conflict Minerals Reporting Template (CMRT). The CMRT was developed by the CFSI; an initiative sponsored by the Electronic Industry Citizenship Coalition, or the EICC, and the Global e-Sustainability Initiative, or the GeSI, and requires suppliers to identify the smelters and refiners that process the necessary conflict minerals contained in the items supplied and the country of origin thereof. During the supplier survey process, suppliers were contacted and responses were tracked using the CSP’s interactive cloud- based platform. This platform allows suppliers to upload completed survey forms directly to the system for review and management.

The CSP launched Cree’s 2016 campaign by providing information about itself and training materials to educate the suppliers believed to be in-scope on 3TGs and the CSP’s reporting system. The full campaign involved multiple communications by the CSP and/or Cree to each supplier, including automated emails, personalized emails, and in some instances phone calls. All significant communications were monitored and tracked in the CSP’s platform for transparency and future reporting.

Based on supplier feedback, the CSP and Cree determined which surveyed suppliers were also outside the scope of the RCOI. These suppliers were marked out-of-scope on the master list. In all other cases, the CSP and Cree reviewed the information provided by each supplier to determine the quality and nature of the response and to determine whether further action was needed to meet Cree’s expectations at this point in the process.

Although 98% of Cree’s in-scope suppliers responded to the RCOI, up from 93% in 2015, some of those suppliers have not yet provided complete smelter or refiner data after several requests by Cree and the CSP. For the suppliers that responded and provided smelter or refiner data, the CSP reviewed all supplier responses that claimed in the declaration section of the CMRT to have known DRC sourced material. The CSP compared the smelting and refining facilities identified in each of these surveys to the list of facilities that have received a “conflict-free” designation from the Conflict-Free Smelter (CFS) program, another resource developed by the CFSI, to determine whether each facility has been certified “conflict-free.”

Because there is considerable overlap between our RCOI and due diligence processes, the determinations we were able to make based on our survey efforts are discussed in more detail in the section below entitled “Due Diligence Results.”

Design of Our Due Diligence Process

Cree’s due diligence measures have been designed to conform in all material respects with the 5-step framework in The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, and the related Supplements for gold and for tin, tantalum and tungsten (collectively, the OECD Guidance) as it relates to our position in the

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conflict minerals supply chain. A summary of the correlation between our due diligence measures and the 5-step framework set forth in the OECD Guidance is described below.

Step 1: Establish strong company management systems

Cree has established a strong management system to address our compliance with the Rule. Our management system is sponsored by the Company’s Chief Financial Officer with support from a team of internal subject matter experts from relevant functions such as Compliance, Engineering, Procurement, Legal, and Internal Audit. The team of subject matter experts is responsible for implementing Cree’s conflict minerals compliance strategy and reports to the CFO, who serves as the conflict minerals program manager. The program manager informs senior management about the results of our due diligence efforts on a regular basis and briefs the Company’s Audit Committee at least quarterly.

As described above, Cree has adopted a Conflict Minerals Policy that includes our commitment and requirement for responsible sourcing of Conflict Minerals. Cree has developed a due diligence strategy to implement our policy that includes using a CSP to educate Cree’s suppliers on the requirements of the Rule annually, or more frequently when deemed necessary, survey our suppliers using the CMRT, review and analyze results, and maintain records for transparency, reporting, and accountability purposes. Consistent with the OECD Guidelines, documentation relevant to Cree’s compliance with the Rule will be retained for a minimum period of five years after the date the related CMR is submitted to the SEC.

We have strengthened engagement with our suppliers by providing education, through the CSP and CFSI resources, on the Rule as well as by communicating, through our Conflict Minerals Policy and contractual provisions, our expectations for suppliers desiring to continue to do business with Cree. Specifically, this includes adding to our standard contracts language that obligates suppliers to exercise due diligence to comply with our Conflict Minerals Policy, which includes a requirement that the supplier must source conflict minerals from smelters and refiners whose due diligence practices have been validated by an independent third party audit program, such as the CFSI or a mutually agreed equivalent. As existing contracts are renewed with suppliers, the new conflict mineral language is being incorporated as well. We have also leveraged the existing communications between Cree’s procurement team and our suppliers to encourage the suppliers to interact with the CSP.

Cree’s Supplier Code of Conduct requires among other things that each Cree in-scope supplier eliminate from use in its products sold to Cree any Conflict Minerals which are known to come from sources funding armed groups in the DRC region. To assist in determining in-scope suppliers and to provide an opportunity for earlier interaction, our new supplier setup procedures include a section asking the new supplier to indicate if any product(s) sold to Cree may contain 3TG material. Lastly, we have a Cree conflict minerals on-line platform that provides employees, suppliers, and other stakeholders a place to report any grievances or concerns with our conflict minerals program (http://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals/conflict-minerals-form).


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Step 2: Identify and assess risk in the supply chain

Because of our size, the complexity of our products, our position in the supply chain, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify sources of conflict minerals upstream from our direct suppliers. Further, we typically do not have direct relationships with 3TG smelters or refiners. Accordingly, we must rely on our direct suppliers to provide information on the origin of the 3TGs contained in assemblies, components, and materials supplied to us - including sources of 3TGs that are supplied to them from upstream sources.

The RCOI activities described above are an integral part of Cree’s efforts to identify and assess the risks in our supply chain. As further described below regarding our due diligence process, our CSP’s system is designed to automatically identify and flag missing information and inconsistencies in supplier CMRTs. Flagged suppliers are contacted to gather pertinent data and perform an assessment of the supplier's commitment to the due diligence process. A revised CMRT is requested and stored in the CSP’s database along with all of the information and findings from this process. During the RCOI process, known DRC sources are identified, and the smelter or refiner (SOR) status is validated against the current CFSI status. If further investigation of a SOR is deemed necessary, we gather additional information through other independent third party audit programs such as TI-CMC, the Responsible Jewellery Council’s Chain-of-Custody Certification Program, and the London Bullion Market Association’s Responsible Gold Programme.

Step 3: Design and implement a strategy to respond to identified risks

While many risks exist in the search for the origin of the conflict minerals used in assemblies, components, and materials supplied to Cree, we believe that one of the greatest risks to Cree is the inability to obtain complete and accurate information to make determinations about our own products. Without this information, we in turn become an obstacle to our customers making determinations about their products.

While there are numerous initiatives working to improve transparency and accountability at the smelter and refiner levels of the supply chain, we can only benefit from the information being developed by these initiatives if our suppliers are able to trace back the conflict minerals in their products to a specific smelter or refiner.
 
This objective is reflected in our Conflict Minerals Policy, which indicates that we expect all of our suppliers to develop their own conflict mineral policies, due diligence frameworks, and management systems, and to provide us all information reasonably needed for us to comply with the Rule. We have included similar obligations in our contractual agreements with our direct suppliers. Our primary focus has shifted from ascertaining whether our immediate suppliers have undertaken efforts to build their own due diligence capabilities meeting the expectations set forth in our Conflicts Minerals Policy to collecting and validating smelter information in completed CMRTs. Our due diligence framework also includes a corrective action management plan designed to move our suppliers toward compliance with our Conflict Minerals Policy. This includes a requirement that any suppliers identified as utilizing a smelter that is known to process Conflict Minerals from sources funding armed groups in the DRC region be placed in escalation mode for further review by our supply chain management and interaction with the supplier in accordance with our Conflict Minerals

6


Policy. For 2016, all known DRC sources identified in our supply chain were either CFSI “compliant” or “active”.

Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices
We typically do not have direct relationships with any 3TG smelter or refiner, so it is impracticable, if not impossible, for us to perform or direct audits of these entities within our supply chain. Rather, we have relied on audits conducted under the CFS program operated by the CFSI and other reputable auditors. The CFSI publishes a list of smelters, by conflict mineral, found to be compliant with the CFS protocol. Pursuant to the CFS program, a smelter voluntarily submits to an independent third party evaluation of its procurement activities and an assessment as to whether the materials processed by the smelter originated from conflict-free sources. If the smelter is able to demonstrate that the materials it processes are conflict-free, based on the sourcing location requirements of the CFS program, the smelter will be considered CFS-compliant.

The CFSI also makes available to its members information on the countries of origin of the conflict minerals processed by each CFS-compliant smelter. We are an active member of the CFSI in order to support their efforts and to have broader access to the country of origin information as well as other valuable tools and resources provided to its members.

Cree management has determined that it is reasonable and appropriate to rely on the results of the CFS program audits and other comparable audits. Given our position in the supply chain, however, our due diligence measures can provide only reasonable assurances, not guarantees, regarding the chain of custody and country of origin of the necessary conflict minerals in our products.

Step 5: Report on supply chain due diligence

The measures we took in 2016 to exercise due diligence on the source and chain of custody of our conflict minerals were as follows:

communicated our Conflict Minerals Policy to our suppliers and posted a copy on our webpage at http://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals;
directed our in-scope suppliers to provide information concerning SORs in their supply chains by completing and sending to us the Conflict Minerals Reporting Template (CMRT) that provides a common means for suppliers to provide customers with information on the source of conflict minerals;
analyzed suppliers’ CMRT responses for completeness and accuracy and pursued further information from the supplier when warranted;
sent outreach letters to SORs to influence and leverage their participation to becoming CFS-compliant;
sent outreach letters to our in-scope suppliers to influence and leverage, or ultimately remove SORs who are not CFS-compliant; and
communicated our Supplier Code of Conduct defining our expectations of our in-scope suppliers to develop internal Conflict Minerals policies, due diligence frameworks, and management systems that are designed to identify and eliminate from use in products sold to

7


Cree any conflict minerals that are known to come from sources funding armed groups in the DRC region. Our Supplier Code of Conduct is located at http://www.cree.com/about/suppliers-contractors/cree-supplier-resources.

No other contents from our website are intended to be incorporated into the Conflict Minerals Report by these website references.

Description of Our Due Diligence Process

Cree’s due diligence process reflects our strategy for identifying, assessing, and responding to the risk that conflict minerals known to have directly or indirectly financed or benefited armed groups in the Covered Countries may be included in our product supply chains. This description is of our process only and is not intended to imply that we have fully implemented this process for all of our suppliers in calendar year 2016.

Our due diligence process includes data evaluation in three phases, all of which are designed to move supplier responses toward compliance with our Conflict Minerals Policy:

Phase 1 - Did the supplier pass our minimum criteria for its CMRT, as assessed by our CSP?
Phase 2 - Did the supplier provide information in its 2016 CMRT survey response which passed Cree’s data validation criteria, as assessed by our CSP?
Phase 3 - Were the CSP’s conclusions reasonable, as assessed by Cree’s subject matter experts on the products supplied to us, and can the smelter information be validated by Cree?

In designing our due diligence process for calendar year 2016, we first reviewed prior year minimum criteria for evaluation during Phase 1 and reaffirmed the applicability for 2016. In evaluating a supplier’s CMRT, we primarily look for three things: effective date-is the information in the report current; completeness-are all of the questions reasonably answered; and consistency-are the supplier’s responses internally consistent.

Suppliers that do not meet these three requirements are contacted with the objective of helping them to understand the requirements for submitting a valid and complete CMRT. Phase 1 is essentially Cree’s corrective action management stage. By implementing supplier corrective action measures, Cree is helping to ensure its suppliers put policies and procedures in place that will produce the necessary data in an accurate and reliable manner.

During Phase 2, the CSP reviews the supplier’s information in its 2016 survey response to validate smelter and refiner information. Smelter and refiner information is reviewed and corrected, and duplicate information is removed whenever possible. All of this data and correspondence is stored in the CSP’s platform. Verified smelter and refiner information is used to obtain reliable information from CFSI and other reputable auditors on the country of origin of the conflict minerals processed by the known smelters or refiners in Cree’s supply chains.
 
If there are no obvious inaccuracies in the supplier’s CMRT responses, the supplier’s CMRT is deemed reliable by the CSP. If the supplier’s CMRT response is inadequate, the supplier’s survey

8


response will be placed in escalation mode and corrective action measures will be applied.

After the CSP completes its analysis under the first two phases, Cree commences its own evaluation in Phase 3. During this evaluation, Cree’s subject matter experts review the information provided by each supplier and the conclusions reached by the CSP from that supplier’s survey data to determine whether those conclusions were reasonable based on information the experts have about the assemblies, components, or materials supplied to Cree. By bringing our specialized knowledge of the industry and Cree’s products into the analysis, Cree is able to identify inaccuracies and inconsistencies in the survey data that may not be obvious to the CSP. If Cree finds inaccuracies and inconsistencies in the survey data, the supplier’s survey response will be placed in escalation mode and corrective action measures will be applied.

Additionally, during Phase 3 Cree validates supplier provided smelter information against the most current known CFSI aliases, smelter status, and mine sourcing. This step allows Cree to determine the certification status of the smelters, as provided in Table 3 below.

There were many challenges in 2016 similar to the previous year’s RCOI, and it is clear that many suppliers do not fully understand the scope of the requirements of the Rule, and that many privately held companies put little or no effort into screening their SOR lists. This, coupled with SOR and recycler dynamics, such as acquisitions, mergers, relocation, or simply going out of business, resulted in uncertainty with respect to SOR accuracy at any given moment in time. We continue to be reminded that it is impractical to expect all supply chain participants to have completed their due diligence procedures or even to be at the same stage of completion. Accordingly, our goal at this point, as reflected in our multi-phase due diligence efforts, is to get all suppliers to demonstrate that they are on the right path to obtain and provide to Cree complete and accurate SOR data. We believe that this will enable us in future years to better determine the facilities used to process the necessary conflict minerals used in the assemblies, components, and materials supplied to us, the country of origin of the necessary conflict minerals in those items, and the mine or location of origin with the greatest possible specificity.

Due Diligence Results
We received responses from the majority of our suppliers known to be in scope. We reviewed the responses against the minimum criteria we developed to determine which ones required further assistance to progress through Phase 3. The CSP and Cree worked directly with the suppliers that required further assistance to obtain revised responses or a commitment to meet the minimum criteria within a reasonable period of time.

Of the responses received, most of our suppliers met our minimum criteria for Phase 1. Of the suppliers contacted for additional information and clarification, a significant percentage provided sufficient information in Phase 2 to validate the accuracy of the survey responses. Further, during our evaluation in Phase 3, Cree determined that the conclusions reached by the CSP in Phase 2 were correct in almost all cases and that most of the smelters could be validated and accurately classified.

Despite our efforts, our due diligence measures can provide only reasonable, not absolute, assurances regarding the source and chain of custody of the necessary conflict minerals because we

9


are relying on source information provided by our suppliers, many of whom in turn obtained the information from their suppliers. We also are relying on information obtained and disseminated by independent third party audit programs, and such sources of information may provide inaccurate or incomplete information.

Additionally, a majority of the responses that included SOR data provided data at a company level as opposed to a product level. We were therefore unable to determine with certainty that the 3TGs reported by these suppliers were contained in assemblies, components, or materials actually supplied to us in 2016. None of the respondents, however, provided information that the necessary conflict minerals used in the assemblies, components, and materials they supplied to Cree were known to have directly or indirectly financed or benefited armed groups in the Covered Countries.

Table 2 lists the number of known and verified SORs identified by our suppliers as potentially having processed the necessary conflict minerals in each of Cree’s specific business units.


Table 2
Cree Business Unit
Number of SORs*
LED Lighting Products
305
LED Products
303
Power & RF Products
305
* It should be noted that the number of SORs in each Cree business unit is inflated from the actual number that would have provided necessary conflict minerals to Cree because most suppliers are reporting at a company level instead of a product level.

Table 3 below lists the SORs identified by our suppliers as potentially having processed the necessary conflict minerals in Cree’s products that are known and verified by the CFSI.


Table 3
#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
1
Gold
Abington Reldan Metals, LLC
United States Of America
2
Gold
Advanced Chemical Company*
United States Of America
3
Gold
Aida Chemical Industries Co., Ltd.*
Japan
4
Gold
Al Etihad Gold LLC*
United Arab Emirates
5
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
Germany
6
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
7
Gold
AngloGold Ashanti Corrego do Sitio Mineracao*
Brazil
8
Gold
Argor-Heraeus S.A.*
Switzerland
9
Gold
Asahi Pretec Corp.*
Japan
10
Gold
Asahi Refining Canada Ltd.*
Canada
11
Gold
Asahi Refining USA Inc.*
United States Of America
12
Gold
Asaka Riken Co., Ltd.*
Japan

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#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
13
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Turkey
14
Gold
AU Traders and Refiners*
South Africa
15
Gold
Aurubis AG*
Germany
16
Gold
Bangalore Refinery^
India
17
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
Philippines
18
Gold
Boliden AB*
Sweden
19
Gold
C. Hafner GmbH + Co. KG*
Germany
20
Gold
Caridad
Mexico
21
Gold
CCR Refinery - Glencore Canada Corporation*
Canada
22
Gold
Cendres + Metaux S.A.
Switzerland
23
Gold
Chimet S.p.A.*
Italy
24
Gold
Chugai Mining
Japan
25
Gold
Daejin Indus Co., Ltd.*
Korea, Republic Of
26
Gold
Daye Non-Ferrous Metals Mining Ltd.
China
27
Gold
DODUCO GmbH*
Germany
28
Gold
Dowa*
Japan
29
Gold
DSC (Do Sung Corporation)*
Korea, Republic Of
30
Gold
Eco-System Recycling Co., Ltd.*
Japan
31
Gold
Elemetal Refining, LLC
United States Of America
32
Gold
Emirates Gold DMCC*
United Arab Emirates
33
Gold
Fidelity Printers and Refiners Ltd.
Zimbabwe
34
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
China
35
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
India
36
Gold
Geib Refining Corporation*
United States Of America
37
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.*
China
38
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
China
39
Gold
Guangdong Jinding Gold Limited
China
40
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
China
41
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
China
42
Gold
Heimerle + Meule GmbH*
Germany
43
Gold
Heraeus Metals Hong Kong Ltd.*
China
44
Gold
Heraeus Precious Metals GmbH & Co. KG*
Germany
45
Gold
Hunan Chenzhou Mining Co., Ltd.
China
46
Gold
HwaSeong CJ CO., LTD.
Korea, Republic Of
47
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.*
China
48
Gold
Ishifuku Metal Industry Co., Ltd.*
Japan
49
Gold
Istanbul Gold Refinery*
Turkey
50
Gold
Japan Mint*
Japan
51
Gold
Jiangxi Copper Co., Ltd.*
China
52
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Russian Federation
53
Gold
JSC Uralelectromed*
Russian Federation
54
Gold
JX Nippon Mining & Metals Co., Ltd.*
Japan

11


#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
55
Gold
Kaloti Precious Metals
United Arab Emirates
56
Gold
Kazakhmys Smelting LLC
Kazakhstan
57
Gold
Kazzinc*
Kazakhstan
58
Gold
Kennecott Utah Copper LLC*
United States Of America
59
Gold
KGHM Polska Miedz Spolka Akcyjna^
Poland
60
Gold
Kojima Chemicals Co., Ltd.*
Japan
61
Gold
Korea Zinc Co., Ltd.*
Korea, Republic Of
62
Gold
Kyrgyzaltyn JSC*
Kyrgyzstan
63
Gold
L'azurde Company For Jewelry
Saudi Arabia
64
Gold
Lingbao Gold Co., Ltd.
China
65
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
China
66
Gold
LS-NIKKO Copper Inc.*
Korea, Republic Of
67
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
China
68
Gold
Materion*
United States Of America
69
Gold
Matsuda Sangyo Co., Ltd.*
Japan
70
Gold
Metalor Technologies (Hong Kong) Ltd.*
China
71
Gold
Metalor Technologies (Singapore) Pte., Ltd.*
Singapore
72
Gold
Metalor Technologies (Suzhou) Ltd.*
China
73
Gold
Metalor Technologies S.A.*
Switzerland
74
Gold
Metalor USA Refining Corporation*
United States Of America
75
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.*
Mexico
76
Gold
Mitsubishi Materials Corporation*
Japan
77
Gold
Mitsui Mining and Smelting Co., Ltd.*
Japan
78
Gold
MMTC-PAMP India Pvt., Ltd.*
India
79
Gold
Modeltech Sdn Bhd^
Malaysia
80
Gold
Morris and Watson
New Zealand
81
Gold
Moscow Special Alloys Processing Plant*
Russian Federation
82
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.*
Turkey
83
Gold
Navoi Mining and Metallurgical Combinat^
Uzbekistan
84
Gold
Nihon Material Co., Ltd.*
Japan
85
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH*
Austria
86
Gold
Ohura Precious Metal Industry Co., Ltd.*
Japan
87
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)*
Russian Federation
88
Gold
OJSC Novosibirsk Refinery*
Russian Federation
89
Gold
PAMP S.A.*
Switzerland
90
Gold
Penglai Penggang Gold Industry Co., Ltd.
China
91
Gold
Prioksky Plant of Non-Ferrous Metals*
Russian Federation
92
Gold
PT Aneka Tambang (Persero) Tbk*
Indonesia
93
Gold
PX Precinox S.A.*
Switzerland
94
Gold
Rand Refinery (Pty) Ltd.*
South Africa
95
Gold
Remondis Argentia B.V.
Netherlands

12


#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
96
Gold
Republic Metals Corporation*
United States Of America
97
Gold
Royal Canadian Mint*
Canada
98
Gold
SAAMP
France
99
Gold
Sabin Metal Corp.
United States Of America
100
Gold
SAFINA A.S.^
Czech Republic
101
Gold
Sai Refinery
India
102
Gold
Samduck Precious Metals*
Korea, Republic Of
103
Gold
Samwon Metals Corp.
Korea, Republic Of
104
Gold
SAXONIA Edelmetalle GmbH*
Germany
105
Gold
Schone Edelmetaal B.V.*
Netherlands
106
Gold
SEMPSA Joyeria Plateria S.A.*
Spain
107
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
China
108
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
China
109
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
China
110
Gold
Singway Technology Co., Ltd.*
Taiwan, Province Of China
111
Gold
So Accurate Group, Inc.
United States Of America
112
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals*
Russian Federation
113
Gold
Solar Applied Materials Technology Corp.*
Taiwan, Province Of China
114
Gold
Sudan Gold Refinery
Sudan
115
Gold
Sumitomo Metal Mining Co., Ltd.*
Japan
116
Gold
T.C.A S.p.A*
Italy
117
Gold
Tanaka Kikinzoku Kogyo K.K.*
Japan
118
Gold
The Refinery of Shandong Gold Mining Co., Ltd.*
China
119
Gold
Tokuriki Honten Co., Ltd.*
Japan
120
Gold
Tongling Nonferrous Metals Group Co., Ltd.
China
121
Gold
Tony Goetz NV^
Belgium
122
Gold
TOO Tau-Ken-Altyn
Kazakhstan
123
Gold
Torecom*
Korea, Republic Of
124
Gold
Umicore Brasil Ltda.*
Brazil
125
Gold
Umicore Precious Metals Thailand*
Thailand
126
Gold
Umicore S.A. Business Unit Precious Metals Refining*
Belgium
127
Gold
United Precious Metal Refining, Inc.*
United States Of America
128
Gold
Universal Precious Metals Refining Zambia
Zambia
129
Gold
Valcambi S.A.*
Switzerland
130
Gold
Western Australian Mint (T/a The Perth Mint)*
Australia
131
Gold
WIELAND Edelmetalle GmbH*
Germany
132
Gold
Yamamoto Precious Metal Co., Ltd.*
Japan
133
Gold
Yokohama Metal Co., Ltd.*
Japan
134
Gold
Yunnan Copper Industry Co., Ltd.
China
135
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
China
136
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
China
137
Tantalum
Conghua Tantalum and Niobium Smeltry*
China

13


#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
138
Tantalum
D Block Metals, LLC*
United States Of America
139
Tantalum
Duoluoshan*
China
140
Tantalum
Exotech Inc.*
United States Of America
141
Tantalum
F&X Electro-Materials Ltd.*
China
142
Tantalum
FIR Metals & Resource Ltd.*
China
143
Tantalum
Global Advanced Metals Aizu*
Japan
144
Tantalum
Global Advanced Metals Boyertown*
United States Of America
145
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
China
146
Tantalum
H.C. Starck Co., Ltd.*
Thailand
147
Tantalum
H.C. Starck Hermsdorf GmbH*
Germany
148
Tantalum
H.C. Starck Inc.*
United States Of America
149
Tantalum
H.C. Starck Ltd.*
Japan
150
Tantalum
H.C. Starck Smelting GmbH & Co. KG*
Germany
151
Tantalum
H.C. Starck Tantalum and Niobium GmbH*
Germany
152
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
China
153
Tantalum
Hi-Temp Specialty Metals, Inc.*
United States Of America
154
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
China
155
Tantalum
Jiangxi Tuohong New Raw Material*
China
156
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
China
157
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited*
China
158
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
China
159
Tantalum
KEMET Blue Metals*
Mexico
160
Tantalum
KEMET Blue Powder*
United States Of America
161
Tantalum
King-Tan Tantalum Industry Ltd.*
China
162
Tantalum
LSM Brasil S.A.*
Brazil
163
Tantalum
Metallurgical Products India Pvt., Ltd.*
India
164
Tantalum
Mineracao Taboca S.A.*
Brazil
165
Tantalum
Mitsui Mining and Smelting Co., Ltd.*
Japan
166
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
China
167
Tantalum
NPM Silmet AS*
Estonia
168
Tantalum
Power Resources Ltd.*
Macedonia, The Former Yugoslav Republic Of
169
Tantalum
QuantumClean*
United States Of America
170
Tantalum
Resind Industria e Comercio Ltda.*
Brazil
171
Tantalum
RFH Tantalum Smeltry Co., Ltd.*
China
172
Tantalum
Solikamsk Magnesium Works OAO*
Russian Federation
173
Tantalum
Taki Chemical Co., Ltd.*
Japan
174
Tantalum
Telex Metals*
United States Of America
175
Tantalum
Tranzact, Inc.*
United States Of America
176
Tantalum
Ulba Metallurgical Plant JSC*
Kazakhstan
177
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.*
China
178
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.*
China

14


#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
179
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.*
China
180
Tin
Alpha*
United States Of America
181
Tin
An Thai Minerals Co., Ltd.
Viet Nam
182
Tin
An Vinh Joint Stock Mineral Processing Company
Viet Nam
183
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*
China
184
Tin
China Tin Group Co., Ltd.*
China
185
Tin
CNMC (Guangxi) PGMA Co., Ltd.
China
186
Tin
Cooperativa Metalurgica de Rondonia Ltda.*
Brazil
187
Tin
CV Ayi Jaya*
Indonesia
188
Tin
CV Dua Sekawan*
Indonesia
189
Tin
CV Gita Pesona*
Indonesia
190
Tin
CV Serumpun Sebalai*
Indonesia
191
Tin
CV Tiga Sekawan*
Indonesia
192
Tin
CV United Smelting*
Indonesia
193
Tin
CV Venus Inti Perkasa*
Indonesia
194
Tin
Dowa*
Japan
195
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company^
Viet Nam
196
Tin
Elmet S.L.U.*
Spain
197
Tin
EM Vinto*
Bolivia (Plurinational State Of)
198
Tin
Estanho de Rondonia S.A.
Brazil
199
Tin
Fenix Metals*
Poland
200
Tin
Gejiu Fengming Metallurgy Chemical Plant*
China
201
Tin
Gejiu Jinye Mineral Company*
China
202
Tin
Gejiu Kai Meng Industry and Trade LLC^
China
203
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
China
204
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.^
China
205
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China
206
Tin
Guanyang Guida Nonferrous Metal Smelting Plant*
China
207
Tin
HuiChang Hill Tin Industry Co., Ltd.*
China
208
Tin
Huichang Jinshunda Tin Co., Ltd.^
China
209
Tin
Jiangxi Ketai Advanced Material Co., Ltd.*
China
210
Tin
Magnu's Minerais Metais e Ligas Ltda.*
Brazil
211
Tin
Malaysia Smelting Corporation (MSC)*
Malaysia
212
Tin
Melt Metais e Ligas S.A.*
Brazil
213
Tin
Metallic Resources, Inc.*
United States Of America
214
Tin
Metallo-Chimique N.V.*
Belgium
215
Tin
Mineracao Taboca S.A.*
Brazil
216
Tin
Minsur*
Peru
217
Tin
Mitsubishi Materials Corporation*
Japan
218
Tin
Modeltech Sdn Bhd^
Malaysia
219
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.^
China

15


#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
220
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Viet Nam
221
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
Thailand
222
Tin
O.M. Manufacturing Philippines, Inc.*
Philippines
223
Tin
Operaciones Metalurgical S.A.*
Bolivia (Plurinational State Of)
224
Tin
PT Aries Kencana Sejahtera*
Indonesia
225
Tin
PT Artha Cipta Langgeng*
Indonesia
226
Tin
PT ATD Makmur Mandiri Jaya*
Indonesia
227
Tin
PT Babel Inti Perkasa*
Indonesia
228
Tin
PT Bangka Prima Tin*
Indonesia
229
Tin
PT Bangka Tin Industry*
Indonesia
230
Tin
PT Belitung Industri Sejahtera*
Indonesia
231
Tin
PT Bukit Timah*
Indonesia
232
Tin
PT DS Jaya Abadi*
Indonesia
233
Tin
PT Eunindo Usaha Mandiri*
Indonesia
234
Tin
PT Inti Stania Prima*
Indonesia
235
Tin
PT Karimun Mining*
Indonesia
236
Tin
PT Kijang Jaya Mandiri*
Indonesia
237
Tin
PT Lautan Harmonis Sejahtera*
Indonesia
238
Tin
PT Menara Cipta Mulia*
Indonesia
239
Tin
PT Mitra Stania Prima*
Indonesia
240
Tin
PT O.M. Indonesia*
Indonesia
241
Tin
PT Panca Mega Persada*
Indonesia
242
Tin
PT Prima Timah Utama*
Indonesia
243
Tin
PT Refined Bangka Tin*
Indonesia
244
Tin
PT Sariwiguna Binasentosa*
Indonesia
245
Tin
PT Stanindo Inti Perkasa*
Indonesia
246
Tin
PT Sukses Inti Makmur*
Indonesia
247
Tin
PT Sumber Jaya Indah*
Indonesia
248
Tin
PT Timah (Persero) Tbk Kundur*
Indonesia
249
Tin
PT Timah (Persero) Tbk Mentok*
Indonesia
250
Tin
PT Tinindo Inter Nusa*
Indonesia
251
Tin
PT Tommy Utama*
Indonesia
252
Tin
Resind Industria e Comercio Ltda.*
Brazil
253
Tin
Rui Da Hung*
Taiwan, Province Of China
254
Tin
Soft Metais Ltda.*
Brazil
255
Tin
Thaisarco*
Thailand
256
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Viet Nam
257
Tin
VQB Mineral and Trading Group JSC*
Viet Nam
258
Tin
White Solder Metalurgia e Mineracao Ltda.*
Brazil
259
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
China
260
Tin
Yunnan Tin Company Limited*
China
261
Tungsten
A.L.M.T. TUNGSTEN Corp.*
Japan

16


#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
262
Tungsten
ACL Metais Eireli^
Brazil
263
Tungsten
Asia Tungsten Products Vietnam Ltd.*
Viet Nam
264
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
China
265
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.*
China
266
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
China
267
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
China
268
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
China
269
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
China
270
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
China
271
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
China
272
Tungsten
Global Tungsten & Powders Corp.*
United States Of America
273
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
China
274
Tungsten
H.C. Starck Smelting GmbH & Co. KG*
Germany
275
Tungsten
H.C. Starck Tungsten GmbH*
Germany
276
Tungsten
Hunan Chenzhou Mining Co., Ltd.*
China
277
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
China
278
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.*
China
279
Tungsten
Hydrometallurg, JSC*
Russian Federation
280
Tungsten
Japan New Metals Co., Ltd.*
Japan
281
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.*
China
282
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
China
283
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
China
284
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
China
285
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*
China
286
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.*
China
287
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.*
China
288
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.*
China
289
Tungsten
Kennametal Fallon*
United States Of America
290
Tungsten
Kennametal Huntsville*
United States Of America
291
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*
China
292
Tungsten
Moliren Ltd.*
Russian Federation
293
Tungsten
Niagara Refining LLC*
United States Of America
294
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC*
Viet Nam
295
Tungsten
Philippine Chuangxin Industrial Co., Inc.*
Philippines
296
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City*
China
297
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
Viet Nam
298
Tungsten
Unecha Refractory metals plant*
Russian Federation
299
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.*
Viet Nam
300
Tungsten
Wolfram Bergbau und Hutten AG*
Austria
301
Tungsten
Woltech Korea Co., Ltd.*
Korea, Republic Of
302
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
China
303
Tungsten
Xiamen Tungsten Co., Ltd.*
China

17


#
Mineral
Smelter or Refiner Facility Name
Country Location of Smelter
304
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*
China
305
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
China

* CFSI Compliant Smelters/refiners as of May 18, 2017
^ CFSI Active Smelters/refiners as of May 18, 2017

Based upon the RCOI data made available from the CFSI, the countries of origin of the conflict minerals sourced and processed by the CFS-compliant smelters and refiners identified as potentially being in Cree’s product supply chains may include, but are not necessarily limited to, the following:
Australia, Austria, Belgium, Bolivia (Plurinational State Of), Brazil, Canada, China, Czech Republic, Estonia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Republic Of, Kyrgyzstan, Macedonia, The Former Yugoslav Republic Of [Macedonia], Malaysia, Mexico, Netherlands, New Zealand, Peru, Philippines, Poland, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Province Of China, Thailand, Turkey, United Arab Emirates, United States Of America, Uzbekistan, Viet Nam, Zambia and Zimbabwe.

We are not including any country of origin information relating to other smelters and refiners identified as potentially being in Cree’s product supply chains because we do not have reliable third party audit results, and we have not completed our due diligence process with respect to, these facilities.

This CMR describes Cree’s efforts to determine the SOR and the country of origin of the necessary conflict minerals in our products manufactured in 2016 with the greatest possible specificity. In response to our RCOI inquiry, our suppliers identified a total of 305 known and verified SORs that may have processed the necessary conflict minerals contained in the materials provided to Cree.

Based on the information obtained in our due diligence process, we have no reason to believe that any of these 305 SORs directly or indirectly finance or benefit armed groups in the Covered Countries. Since this does not reflect all of the SORs in our product supply chains, however, we are not in a position to conclude that all of the necessary conflict minerals in our products were obtained from conflict-free sources.

While we have not yet succeeded in obtaining a complete and accurate list of SORs for all of our products that include necessary conflict minerals, we believe that we have made good progress given the current state of the data available to us and the relative lack of sophistication of certain portions of our supply chain with respect to the requirements of the Rule.

Steps to Mitigate Risk
The previous parts of this CMR detail the steps taken in 2016 to mitigate risk. In the future, we plan to take or continue taking the following actions to improve the due diligence conducted on our supply chain to further mitigate any risk that the necessary 3TGs in our products could finance or

18


benefit armed groups in the Covered Countries:

a. Leverage our direct suppliers that can most effectively and most directly mitigate the identified risks;
b. Continue to be an active CFSI member and, as a member, support SOR and recycler outreach programs by sending letters and/or emails to them explaining the importance of audit certification;
c. Work with upstream distributors in our supply chain and develop best practices to improve the quality and reporting of RCOI data;
d. Continue to strengthen engagement with relevant suppliers and to provide training, as appropriate, to help them understand and comply with Cree requirements related to 3TG minerals under the Rule;
e. Continue to seek qualitative improvements in supplier and smelter due diligence of conflict minerals;
f. Continue to seek qualitative improvements in supplier and smelter due diligence of conflict minerals; and
g. Monitor to determine if any additional changes in our procurement process are needed to improve visibility to necessary 3TGs in the assemblies, components, and materials purchased.
During the fifth year of Cree’s conflict minerals program, the Company will continue its focus on obtaining complete and reliable SOR and country of origin data by requiring suppliers to provide in a timely manner accurate smelter identification numbers and supplemental information that will allow Cree to determine the correlation between the identified SORs, countries of origin, and the assemblies, components, and materials supplied to Cree.



The Cree logo is a trademark of Cree, Inc.


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