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Exhibit 1.01

KEMET Corporation

CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2019
Report Date: May 22, 2020

INTRODUCTION
This Conflict Minerals Report for KEMET Corporation (“KEMET,” “we,” “us” or “our”) is presented to comply with Section 13(p) of the Securities Exchange Act of 1934, as amended, and Rule 13p-1 thereunder (the “Rule”) for the reporting period from January 1 to December 31, 2019.
For the reporting period from January 1 to December 31, 2019 (“Reporting Period”), KEMET conducted due diligence on the source and chain of custody of the cassiterite, columbite-tantalite, wolframite, and gold, including their derivatives, which are limited to tin, tantalum, and tungsten (“3TG”), that were necessary to the functionality or production of the products (“necessary conflict minerals”) that we manufactured or contracted to manufacture on or after January 1, 2019 to ascertain whether these conflict minerals originated in the Democratic Republic of Congo ("DRC") or an adjoining country as defined in the Rule (“Covered Countries”) and financed or benefited armed groups in any of these countries. It is noted that manufacturing products during a defined period of time may naturally include materials sourced prior to and during the Reporting Period. The reasonable country of origin inquiry and due diligence measures were applied to identified conflict mineral suppliers prior to and during the Reporting Period. Some conflict minerals utilized during the period were considered “outside the supply chain” under the Rule, meaning materials that were smelted (with respect to tin, tantalum, or tungsten) or fully refined (with respect to gold) prior to January 31, 2013, or materials that have not been smelted or fully refined but were located outside of the Covered Countries prior to January 31, 2013. As such, conflict minerals that were considered “outside the supply chain” are exempt from reporting under the Rule. However, for the purpose of this report, KEMET’s due diligence measures did not exclude these materials or suppliers.
DUE DILIGENCE MEASURES
Design of Our Due Diligence Measures
Our conflict minerals due diligence measures have been designed 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 (the “OECD Guidance”), as applicable for tin, tantalum, tungsten, and gold in all material respects. KEMET is both an “upstream” and “downstream” company. KEMET took an early leadership position in the industry in support of sourcing conflict-free material from the DRC and was instrumental in the development of the Kisengo Foundation. KEMET sustained these efforts in the Kisengo village in the Katanga province of the DRC by contributing to ongoing humanitarian projects. Periodically, KEMET deploys company representatives to monitor the progress of the program. We designed both our upstream and downstream due diligence measures to:
1.
Establish strong company management systems for conflict minerals supply chain due diligence and reporting compliance;
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, as required by the Rule.
Description of Due Diligence Performed as an Upstream Company
Based on the OECD Guidance, “upstream” refers to the mineral supply chain from the mine to the smelters/refiners. “Upstream companies” include miners (artisanal and small-scale or large-scale producers), local traders or exporters from the country of mineral origin, international concentrate traders, mineral re-processors and smelters/refiners. In addition, KEMET deployed representatives to the covered countries as part of our due diligence effort.
The source and chain of custody of tantalum materials were audited and validated in conformance with the Responsible Minerals Assurance Process (“RMAP”), formerly known as the Conflict-Free Smelter Program. Our compliance status as well as the audit protocols and procedures are publicly available on the Responsible Minerals Initiative (“RMI”) website. Information on such website or KEMET's website referenced herein does not constitute part of this Conflict Minerals Report.


1

Description of the Due Diligence Performed as a Downstream Company
Based on the OECD Guidance, “downstream” means the minerals supply chain from smelters/refiners to retailers. “Downstream companies” include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers (OEMs) and retailers. In the following chart, KEMET has described its due diligence activities that are in accordance with the five steps set forth in the OECD Guidance. These activities were performed during the Reporting Period.
Step 1: Establish strong company management systems.
A)    To clearly communicate to suppliers and the public, KEMET maintained a formal company policy to avoid the use of conflict minerals which may directly or indirectly finance or benefit armed groups in the DRC or an adjoining country (“Supply Chain Policy”). The Supply Chain Policy is publicly available on our website and is included in KEMET’s purchase order terms and conditions. The Supply Chain Policy was communicated to conflict minerals raw material suppliers during the Reporting Period and to new raw material suppliers during our supplier “on boarding” process. The Supply Chain Policy applies to any region determined by KEMET to be a conflict-affected and high risk area.
B)    To structure internal management and support supply chain due diligence, KEMET maintained in its internal Compliance Policy and Procedures, a conflict minerals document formally stating that KEMET’s Sustainability Council (“SC”) has oversight and ownership of the Supply Chain Policy. The SC membership consists of a cross section of senior management led by Senior Vice President - Quality, Global Supply Chain, Chief Compliance Officer, and Chief of Staff. The SC met quarterly to address current and future sustainability objectives and concerns. In addition, KEMET maintained a specific conflict minerals team (“Conflict Minerals Team”) that met periodically during the Reporting Period to address the implementation and progress of our due diligence efforts.
C)    To establish a system of controls and transparency over the conflict minerals supply chain as a downstream company, KEMET maintained in our internal quality and compliance procedures a requirement for suppliers to provide information on the smelters or refiners in their supply chain utilizing the RMI Conflict Minerals Reporting Template. Records of suppliers’ responses were recorded and maintained. The information was used by KEMET to determine material conflict-free status. The information was also used to provide our customers with conflict minerals smelter or refiner information.
D)    To strengthen engagement with its suppliers, KEMET performed smelter outreach and participated in supply chain seminars and conferences, as well as RMI conflict minerals discussion and working groups.
E)    KEMET had multiple communication channels available to serve as grievance mechanisms for early-warning risk awareness. Internally, KEMET provides a Whistleblower Hotline program to its personnel to anonymously report possible violations of KEMET’s Global Code of Conduct and other policies. The Whistleblower Hotline program was administered by a third-party firm which was not connected to KEMET. Externally, contact information for reporting possible violations was made available through KEMET’s public website (www.kemet.com). KEMET also actively participated in the following industry or multi-stakeholder group(s) which served as an early-warning risk-awareness system.
• Organisation for Economic Co-Operation and Development (OECD) - Participant
• RMI and RMI Grievance Mechanism - Member
• International Tin Research Institute Tin Supply Chain Initiative (iTSCi) - Member
• Tantalum-Niobium International Study Center (TIC) - Member
Step 2: Identify and assess risk in the supply chain.
A)    For the purpose of identifying risks, KEMET utilized the RMI Conflict Minerals Reporting Template (CMRT) to obtain smelter or refiner information from suppliers of raw materials which contained a conflict mineral.
B)    To assess risk, KEMET reviewed the supplier CMRT responses for completeness and for reasonableness [i.e., 1) a response does not contain contradictions or inconsistencies; and/or 2) the response is consistent with KEMET’s knowledge of the supplier]. KEMET followed up with suppliers who were unresponsive or required additional clarification.
Step 3: Design and implement a strategy to respond to identified risks.
A)    KEMET reported findings of supply chain risk to senior management through quarterly and monthly business review meetings.
B)    The risk management plan adopted by KEMET was in accordance with the Supply Chain Policy to discontinue doing business with any supplier found to be purchasing tungsten, tantalum, tin, or gold material which directly or indirectly finances or benefits armed groups in the DRC or an adjoining country. KEMET understood the global supply chain of conflict minerals is complex and disclosure of mineral sources is often considered confidential. When potential risks were discovered, KEMET communicated with the smelter or refiner to address the potential risks.
C)    To monitor and track performance of risk management efforts, KEMET relied on supplier survey updates and supplier RMI updates. The status was communicated internally to conflict minerals team members in periodic meetings.
D)    To undertake additional fact and risk assessments for risks requiring mitigation or after a change of circumstances, KEMET relied on the supplier approval status as governed by its compliance and quality procedures.



2

Step 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
KEMET relied on the RMAP independent third-party audits to supplement our internal due diligence of conflict minerals suppliers and monitored the progress of these audits to help determine the conflict-free status of our supply chain. As an RMI member, KEMET worked with other members to identify smelters in the supply chain and encouraged suppliers and customers to participate in the program. The data on which we relied for certain statements in this declaration was obtained through our membership in the RMI, using the Reasonable Country of Origin Inquiry report for member ID: “KMET.”
Step 5: Report on supply chain due diligence.
KEMET has publicly made available the Supply Chain Policy outlining its due diligence objectives. As required under Section 13(p) of the Securities and Exchange Act of 1934 and the Rule, and in consultation with internal and external counsel, KEMET has filed our Form SD - Special Disclosure Report, which includes this Conflict Minerals Report as Exhibit 1.01, with the Securities and Exchange Commission for the Reporting Period and made such disclosure available on its website at www.kemet.com.
DUE DILIGENCE DETERMINATION
Summary of Due Diligence Measures Performed
KEMET’s reasonable country of origin inquiry (“RCOI”) and due diligence employed a combination of measures to determine whether the necessary conflict minerals in KEMET’s products originated from the Covered Countries. Our due diligence measures included the following activities:
1.
KEMET surveyed all identified suppliers of raw materials which contained a conflict mineral to ascertain for each of the supplied conflict minerals (a) the smelter or refiner where it was processed and (b) its country of origin. The survey was conducted using the RMI Conflict Minerals Reporting Template. KEMET accepted supplier data up to March 31, 2020 for the Reporting Period.
2.
KEMET’s tantalum smelting and refining facilities were audited and validated as RMAP conformant. In addition, KEMET sourced its downstream externally supplied tantalum material only from RMAP conformant smelters.
3.
As a member company of the RMI, we leveraged the due diligence conducted by the RMAP of smelters and refiners. Developed by the RMI, the RMAP is a voluntary initiative in which an independent third party auditor audits smelter and refiner procurement and tolling activities and determines if the smelter or refiner demonstrated that all the minerals they processed originated from conflict-free sources.
Results of RCOI and Due Diligence Measures
KEMET is voluntarily providing disclosure as to the conflict-free status of its products in an effort to provide greater transparency over KEMET’s products.
DRC Conflict Free Products
We have designated our products as DRC Conflict Free if we were able to reasonably determine that they do not contain conflict minerals necessary to their functionality or production that directly or indirectly finance or benefit armed groups in a Covered Country, or that are obtained from recycled or scrap sources, all as further defined by applicable SEC rules. KEMET’s products manufactured in the Reporting Period were determined to be DRC Conflict Free if (a) all KEMET’s external third party suppliers who contributed necessary conflict minerals to those products provided a response to the supply chain survey confirming they had identified all of the smelters or refiners in their supply chain and (b) all of those smelters/refiners were either RMAP conformant or sourced outside the Covered Countries.
As a result of the RCOI and due diligence conducted as described above and in accordance with the Rule as originally promulgated, KEMET has determined the following product categories to be DRC Conflict Free for the Reporting Period.
•
Tantalum Capacitors
•
Tantalum Polymer Capacitors
•
Aluminum Polymer Capacitors
•
Ceramic Capacitors
•
Electrolytic Capacitors
•
Electric Double-Layered Capacitors
KEMET has insufficient information from suppliers or other sources regarding all smelters and refiners that processed the necessary conflict minerals to make a determination for the other product categories (“Other Product Categories”) set forth below and further identifies the known facilities used to process the necessary conflict minerals and country of origin in Table 1 hereunder. The country of origin information is based on the RMI Conformant Smelter Sourcing Information report dated March 31, 2020.
•
Electrical Filters
•
Electronic Control Boards
•
Film and Paper Capacitors
•
Magnetics
•
Sensors
•
Actuators

3


Note: In this Conflict Minerals Report, KEMET is utilizing comprehensive, top-level product categories for brevity. Certain specific products and/or product part numbers which are contained within the broad product categories listed above are DRC Conflict Free.
A total of 265 smelter and refiner facilities were identified by our suppliers. As of March 31, 2020:
•
258 were audited and found to be conformant to the RMAP
•
1 was actively participating in the RMAP
•
6 had temporarily or permanently ceased operations immediately prior to or during the Reporting Period

The charts below provide a summary of the RMAP status of the operational smelter and refiner facilities by conflict mineral:

conflictpicture.jpg















4

Table 1 below lists the known smelter and refiner facilities that processed the necessary conflict minerals in KEMET's products:
Table 1:
 
Mineral
Smelter or Refiner Facility Name
Location of Facility
Smelter ID
Other Product Categories
1
Gold
Advanced Chemical Company
United States of America
CID000015
√
2
Gold
Aida Chemical Industries Co., Ltd.
Japan
CID000019
√
3
Gold
Al Etihad Gold Refinery DMCC
United Arab Emirates
CID002560
√
4
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Germany
CID000035
√
5
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
CID000041
√
6
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Brazil
CID000058
√
7
Gold
Argor-Heraeus S.A.
Switzerland
CID000077
√
8
Gold
Asahi Pretec Corp.
Japan
CID000082
√
9
Gold
Asahi Refining Canada Ltd.
Canada
CID000924
√
10
Gold
Asahi Refining USA Inc.
United States of America
CID000920
√
11
Gold
Asaka Riken Co., Ltd.
Japan
CID000090
√
12
Gold
AU Traders and Refiners
South Africa
CID002850
√
13
Gold
Aurubis AG
Germany
CID000113
√
14
Gold
Bangalore Refinery
India
CID002863
√
15
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
CID000128
√
16
Gold
Boliden AB
Sweden
CID000157
√
17
Gold
C. Hafner GmbH + Co. KG
Germany
CID000176
√
18
Gold
Caridad
Mexico
CID000180
√
19
Gold
CCR Refinery - Glencore Canada Corporation
Canada
CID000185
√
20
Gold
Cendres + Metaux S.A.
Switzerland
CID000189
√
21
Gold
Chimet S.p.A.
Italy
CID000233
√
22
Gold
Chugai Mining
Japan
CID000264
√
23
Gold
Daejin Indus Co., Ltd.
Korea, Republic of
CID000328
√
24
Gold
DODUCO Contacts and Refining GmbH
Germany
CID000362
√
25
Gold
Dowa
Japan
CID000401
√
26
Gold
DS PRETECH Co., Ltd.
Korea, Republic of
CID003195
√
27
Gold
DSC (Do Sung Corporation)
Korea, Republic of
CID000359
√
28
Gold
Eco-System Recycling Co., Ltd.
Japan
CID000425
√
29
Gold
Emirates Gold DMCC
United Arab Emirates
CID002561
√
30
Gold
Geib Refining Corporation
United States of America
CID002459
√
31
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
China
CID002243
√
32
Gold
Guangdong Jinding Gold Limited
China
CID002312
√

5

33
Gold
HeeSung Metal Ltd.
Korea, Republic of
CID000689
√
34
Gold
Heimerle + Meule GmbH
Germany
CID000694
√
35
Gold
Heraeus Metals Hong Kong Ltd.
China
CID000707
√
36
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
CID000711
√
37
Gold
HwaSeong CJ CO., LTD.
Korea, Republic of
CID000778
√
38
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China
CID000801
√
39
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
CID000807
√
40
Gold
Istanbul Gold Refinery
Turkey
CID000814
√
41
Gold
Italpreziosi
Italy
CID002765
√
42
Gold
Japan Mint
Japan
CID000823
√
43
Gold
Jiangxi Copper Co., Ltd.
China
CID000855
√
44
Gold
JSC Uralelectromed
Russian Federation
CID000929
√
45
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
CID000937
√
46
Gold
Kazzinc
Kazakhstan
CID000957
√
47
Gold
Kennecott Utah Copper LLC
United States of America
CID000969
√
48
Gold
KGHM Polska Miedz Spolka Akcyjna
Poland
CID002511
√
49
Gold
Kojima Chemicals Co., Ltd.
Japan
CID000981
√
50
Gold
Korea Zinc Co., Ltd.
Korea, Republic of
CID002605
√
51
Gold
Kyrgyzaltyn JSC
Kyrgyzstan
CID001029
√
52
Gold
L'Orfebre S.A.
Andorra
CID002762
√
53
Gold
LS-NIKKO Copper Inc.
Korea, Republic of
CID001078
√
54
Gold
Marsam Metals
Brazil
CID002606
√
55
Gold
Materion
United States of America
CID001113
√
56
Gold
Matsuda Sangyo Co., Ltd.
Japan
CID001119
√
57
Gold
Metalor Technologies (Hong Kong) Ltd.
China
CID001149
√
58
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
CID001152
√
59
Gold
Metalor Technologies (Suzhou) Ltd.
China
CID001147
√
60
Gold
Metalor Technologies S.A.
Switzerland
CID001153
√
61
Gold
Metalor USA Refining Corporation
United States of America
CID001157
√
62
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Mexico
CID001161
√
63
Gold
Mitsubishi Materials Corporation
Japan
CID001188
√
64
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
CID001193
√
65
Gold
MMTC-PAMP India Pvt., Ltd.
India
CID002509
√
66
Gold
Moscow Special Alloys Processing Plant
Russian Federation
CID001204
√
67
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Turkey
CID001220
√

6

68
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
CID001236
√
69
Gold
NH Recytech Company
Korea, Republic of
CID003189
√
70
Gold
Nihon Material Co., Ltd.
Japan
CID001259
√
71
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Austria
CID002779
√
72
Gold
Ohura Precious Metal Industry Co., Ltd.
Japan
CID001325
√
73
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Russian Federation
CID001326
√
74
Gold
OJSC Novosibirsk Refinery
Russian Federation
CID000493
√
75
Gold
PAMP S.A.
Switzerland
CID001352
√
76
Gold
Pease & Curren
United States of America
CID002872
√
77
Gold
Planta Recuperadora de Metales SpA
Chile
CID002919
√
78
Gold
Prioksky Plant of Non-Ferrous Metals
Russian Federation
CID001386
√
79
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
CID001397
√
80
Gold
PX Precinox S.A.
Switzerland
CID001498
√
81
Gold
Rand Refinery (Pty) Ltd.
South Africa
CID001512
√
82
Gold
REMONDIS PMR B.V.
Netherlands
CID002582
√
83
Gold
Republic Metals Corporation*
United States of America
CID002510
√
84
Gold
Royal Canadian Mint
Canada
CID001534
√
85
Gold
SAAMP
France
CID002761
√
86
Gold
Safimet S.p.A
Italy
CID002973
√
87
Gold
Samduck Precious Metals
Korea, Republic of
CID001555
√
88
Gold
Samwon Metals Corp.
Korea, Republic of
CID001562
√
89
Gold
SAXONIA Edelmetalle GmbH
Germany
CID002777
√
90
Gold
SEMPSA Joyeria Plateria S.A.
Spain
CID001585
√
91
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China
CID001622
√
92
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
CID001736
√
93
Gold
Singway Technology Co., Ltd.
Taiwan, Province of China
CID002516
√
94
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Russian Federation
CID001756
√
95
Gold
Solar Applied Materials Technology Corp.
Taiwan, Province of China
CID001761
√
96
Gold
State Research Institute Center for Physical Sciences and Technology
Lithuania
CID003153
√
97
Gold
SungEel HiMetal Co., Ltd.
Korea, Republic of
CID002918
√
98
Gold
T.C.A S.p.A
Italy
CID002580
√
99
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
CID001875
√
100
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
China
CID001916
√
101
Gold
Tokuriki Honten Co., Ltd.
Japan
CID001938
√
102
Gold
Tongling Nonferrous Metals Group Co., Ltd.
China
CID001947
√

7

103
Gold
Torecom
Korea, Republic of
CID001955
√
104
Gold
Umicore Brasil Ltda.
Brazil
CID001977
√
105
Gold
Umicore Precious Metals Thailand
Thailand
CID002314
√
106
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
CID001980
√
107
Gold
United Precious Metal Refining, Inc.
United States of America
CID001993
√
108
Gold
Valcambi S.A.
Switzerland
CID002003
√
109
Gold
Western Australian Mint (T/a The Perth Mint)
Australia
CID002030
√
110
Gold
WIELAND Edelmetalle GmbH
Germany
CID002778
√
111
Gold
Yamakin Co., Ltd.
Japan
CID002100
√
112
Gold
Yokohama Metal Co., Ltd.
Japan
CID002129
√
113
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
CID002224
√
1
Tantalum
D Block Metals, LLC
United States of America
CID002504
 
2
Tantalum
Exotech Inc.
United States of America
CID000456
 
3
Tantalum
F&X Electro-Materials Ltd.
China
CID000460
 
4
Tantalum
FIR Metals & Resource Ltd.
China
CID002505
 
5
Tantalum
Global Advanced Metals Aizu
Japan
CID002558
 
6
Tantalum
Global Advanced Metals Boyertown
United States of America
CID002557
 
7
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
China
CID000291
 
8
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
China
CID000616
 
9
Tantalum
H.C. Starck Co., Ltd.
Thailand
CID002544
 
10
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
CID002547
 
11
Tantalum
H.C. Starck Inc.
United States of America
CID002548
 
12
Tantalum
H.C. Starck Ltd.
Japan
CID002549
 
13
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Germany
CID002550
 
14
Tantalum
H.C. Starck Tantalum and Niobium GmbH
Germany
CID002545
 
15
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
CID002492
 
16
Tantalum
Jiujiang Tanbre Co., Ltd.
China
CID000917
 
17
Tantalum
KEMET Blue Metals
Mexico
CID002539
 
18
Tantalum
KEMET Blue Powder
United States of America
CID002568
 
19
Tantalum
Metallurgical Products India Pvt., Ltd.
India
CID001163
 
20
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
CID001277
 
21
Tantalum
Power Resources Ltd.
Macedonia, The Former Yugoslav Republic of
CID002847
 
22
Tantalum
Telex Metals
United States of America
CID001891
 
23
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
CID001969
 
1
Tin
Alpha
United States of America
CID000292
√

8

2
Tin
An Vinh Joint Stock Mineral Processing Company
Viet Nam
CID002703
√
3
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China
CID000228
√
4
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
China
CID003190
√
5
Tin
China Tin Group Co., Ltd.
China
CID001070
√
6
Tin
CNMC (Guangxi) PGMA Co., Ltd.*
China
CID000278
√
7
Tin
CV Ayi Jaya
Indonesia
CID002570
√
8
Tin
CV Dua Sekawan
Indonesia
CID002592
√
9
Tin
CV Gita Pesona
Indonesia
CID000306
√
10
Tin
CV United Smelting
Indonesia
CID000315
√
11
Tin
CV Venus Inti Perkasa
Indonesia
CID002455
√
12
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
China
CID003356
√
13
Tin
Dowa
Japan
CID000402
√
14
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Viet Nam
CID002572
√
15
Tin
EM Vinto
Bolivia (Plurinational State of)
CID000438
√
16
Tin
Estanho de Rondonia S.A.
Brazil
CID000448
√
17
Tin
Fenix Metals
Poland
CID000468
√
18
Tin
Geiju Jinye Mineral Company*
China
CID002859
√
19
Tin
Gejiu Fengming Metallurgy Chemical Plant
China
CID002848
√
20
Tin
Gejiu Kai Meng Industry and Trade LLC
China
CID000942
√
21
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
CID000538
√
22
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
China
CID001908
√
23
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China
CID000555
√
24
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
China
CID003116
√
25
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
China
CID002849
√
26
Tin
HuiChang Hill Tin Industry Co., Ltd.
China
CID002844
√
27
Tin
Huichang Jinshunda Tin Co., Ltd.
China
CID000760
√
28
Tin
Jiangxi Ketai Advanced Material Co., Ltd.*
China
CID000244
√
29
Tin
Jiangxi New Nanshan Technology Ltd.
China
CID001231
√
30
Tin
Ma'anshan Weitai Tin Co., Ltd.
China
CID003379
√
31
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
CID002468
√
32
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
CID001105
√
33
Tin
Melt Metais e Ligas S.A.
Brazil
CID002500
√
34
Tin
Metallic Resources, Inc.
United States of America
CID001142
√
35
Tin
Metallo Belgium N.V.
Belgium
CID002773
√
36
Tin
Metallo Spain S.L.U.
Spain
CID002774
√

9

37
Tin
Mineracao Taboca S.A.
Brazil
CID001173
√
38
Tin
Minsur
Peru
CID001182
√
39
Tin
Mitsubishi Materials Corporation
Japan
CID001191
√
40
Tin
Modeltech Sdn Bhd
Malaysia
CID002858
√
41
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Viet Nam
CID002573
√
42
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
CID001314
√
43
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
CID002517
√
44
Tin
Operaciones Metalurgicas S.A.
Bolivia (Plurinational State of)
CID001337
√
45
Tin
Pongpipat Company Limited
Myanmar
CID003208
√
46
Tin
Precious Minerals and Smelting Limited1
India
CID003409
√
47
Tin
PT Aries Kencana Sejahtera
Indonesia
CID000309
√
48
Tin
PT Artha Cipta Langgeng
Indonesia
CID001399
√
49
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
CID002503
√
50
Tin
PT Babel Inti Perkasa
Indonesia
CID001402
√
51
Tin
PT Babel Surya Alam Lestari
Indonesia
CID001406
√
52
Tin
PT Bangka Prima Tin
Indonesia
CID002776
√
53
Tin
PT Bangka Serumpun
Indonesia
CID003205
√
54
Tin
PT Bangka Tin Industry
Indonesia
CID001419
√
55
Tin
PT Belitung Industri Sejahtera
Indonesia
CID001421
√
56
Tin
PT Bukit Timah
Indonesia
CID001428
√
57
Tin
PT DS Jaya Abadi
Indonesia
CID001434
√
58
Tin
PT Eunindo Usaha Mandiri*
Indonesia
CID001438
√
59
Tin
PT Inti Stania Prima
Indonesia
CID002530
√
60
Tin
PT Karimun Mining
Indonesia
CID001448
√
61
Tin
PT Kijang Jaya Mandiri
Indonesia
CID002829
√
62
Tin
PT Lautan Harmonis Sejahtera*
Indonesia
CID002870
√
63
Tin
PT Menara Cipta Mulia
Indonesia
CID002835
√
64
Tin
PT Mitra Stania Prima
Indonesia
CID001453
√
65
Tin
PT Panca Mega Persada
Indonesia
CID001457
√
66
Tin
PT Premium Tin Indonesia
Indonesia
CID000313
√
67
Tin
PT Prima Timah Utama
Indonesia
CID001458
√
68
Tin
PT Rajawali Rimba Perkasa
Indonesia
CID003381
√
69
Tin
PT Rajehan Ariq
Indonesia
CID002593
√
70
Tin
PT Refined Bangka Tin
Indonesia
CID001460
√
71
Tin
PT Sariwiguna Binasentosa
Indonesia
CID001463
√

10

72
Tin
PT Stanindo Inti Perkasa
Indonesia
CID001468
√
73
Tin
PT Sukses Inti Makmur
Indonesia
CID002816
√
74
Tin
PT Sumber Jaya Indah
Indonesia
CID001471
√
75
Tin
PT Timah Tbk Kundur
Indonesia
CID001477
√
76
Tin
PT Timah Tbk Mentok
Indonesia
CID001482
√
77
Tin
PT Tinindo Inter Nusa
Indonesia
CID001490
√
78
Tin
PT Tirus Putra Mandiri
Indonesia
CID002478
√
79
Tin
PT Tommy Utama
Indonesia
CID001493
√
80
Tin
Resind Industria e Comercio Ltda.
Brazil
CID002706
√
81
Tin
Rui Da Hung
Taiwan, Province of China
CID001539
√
82
Tin
Soft Metais Ltda.
Brazil
CID001758
√
83
Tin
Super Ligas
Brazil
CID002756
√
84
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
Viet Nam
CID002834
√
85
Tin
Thaisarco
Thailand
CID001898
√
86
Tin
Tin Technology & Refining
United States of America
CID003325
√
87
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Viet Nam
CID002574
√
88
Tin
White Solder Metalurgia e Mineracao Ltda.
Brazil
CID002036
√
89
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
CID002158
√
90
Tin
Yunnan Tin Company Limited
China
CID002180
√
91
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
China
CID003397
√
1
Tungsten
A.L.M.T. Corp.
Japan
CID000004
√
2
Tungsten
ACL Metais Eireli
Brazil
CID002833
√
3
Tungsten
Asia Tungsten Products Vietnam Ltd.
Viet Nam
CID002502
√
4
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
CID002513
√
5
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
CID000258
√
6
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
China
CID000499
√
7
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China
CID000875
√
8
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
China
CID002315
√
9
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
CID002494
√
10
Tungsten
Global Tungsten & Powders Corp.
United States of America
CID000568
√
11
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
CID000218
√
12
Tungsten
H.C. Starck Smelting GmbH & Co. KG
Germany
CID002542
√
13
Tungsten
H.C. Starck Tungsten GmbH
Germany
CID002541
√
14
Tungsten
Hunan Chenzhou Mining Co., Ltd.
China
CID000766
√
15
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
China
CID002579
√

11

16
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
CID000769
√
17
Tungsten
Hydrometallurg, JSC
Russian Federation
CID002649
√
18
Tungsten
Japan New Metals Co., Ltd.
Japan
CID000825
√
19
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China
CID002551
√
20
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
CID002321
√
21
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China
CID002318
√
22
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
CID002317
√
23
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
CID002316
√
24
Tungsten
Kennametal Fallon
United States of America
CID000966
√
25
Tungsten
Kennametal Huntsville
United States of America
CID000105
√
26
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China
CID002319
√
27
Tungsten
Masan Tungsten Chemical LLC (MTC)
Viet Nam
CID002543
√
28
Tungsten
Moliren Ltd.
Russian Federation
CID002845
√
29
Tungsten
Niagara Refining LLC
United States of America
CID002589
√
30
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Philippines
CID002827
√
31
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Viet Nam
CID001889
√
32
Tungsten
Unecha Refractory metals plant
Russian Federation
CID002724
√
33
Tungsten
Wolfram Bergbau und Hutten AG
Austria
CID002044
√
34
Tungsten
Woltech Korea Co., Ltd.
Korea, Republic of
CID002843
√
35
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
CID002320
√
36
Tungsten
Xiamen Tungsten Co., Ltd.
China
CID002082
√
37
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
China
CID002830
√
38
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
China
CID002095
√
Country of Origin May Include
Argentina, Benin, Angola, Armenia, Australia, Austria, Azerbaijan, Belarus, Belgium, Bolivia, Bolivia (Plurinational State of), Botswana, Brazil, Brunei, Bulgaria, Burkina Faso, Burundi, Cameroon, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Croatia, Cuba, Cyprus, Czech Republic, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Fiji, Finland, France, Gabon, Gambia, The, Georgia, Germany, Ghana, Greece, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Iran, Ireland, Israel, Italy, Ivory Coast, Japan, Jordan, Kazakhstan, Kazakhstan , Kenya, Korea, Republic of, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Liechtenstein, Lithuania, Luxembourg, Macau, Madagascar, Malaysia, Mali, Malta, Mauritania, Mauritius, Mexico, Monaco, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Caledonia, New Zealand, Nicaragua, Niger, Nigeria, Norway, Pakistan, Panama, Papua New Guinea, Paraguay, Peru, Philippines, Philippines, Poland, Portugal, Puerto Rico, Qatar, Romania, Russia, Russian Federation, Rwanda, San Marino, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Slovenia, Solomon Islands, Somaliland, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, United Kingdom, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Yemen, Zambia, Zimbabwe

1 For the Reporting Period, this smelter was actively participating in the RMAP.
* During the Reporting Period, these smelters and/or refiners were RMAP-conformant. However, immediately prior to or during the Reporting Period, these smelters and/or refiners were declared no longer operational.
 



12

Future Steps to Mitigate Risks
The due diligence steps previously described for both an upstream and downstream company will be used for future reporting periods to mitigate risk and improve our due diligence. KEMET will continue:
•
Engaging suppliers of 3TG to improve the content of their responses. This includes a conflict-minerals flow down clause as well as new supplier or new material conflict minerals provisions as part of our “on boarding process.”
•
Working through the RMI to accurately identify new or existing smelters and refiners and increase their participation in the RMAP.
•
Working with the OECD and relevant trade associations to define and improve best practices.
•
Sourcing our upstream materials from conflict-free validated mines which utilize traceability schemes to ensure complete chain of custody and maintain our RMAP.
•
Enhance our validation process to include review of additional risks related to applicable laws and regulations.
By conducting these supply chain exercises during each Reporting Period in accordance with our Supply Chain Policy, KEMET will continue our efforts to mitigate the risk that the necessary conflict minerals benefit armed groups and improve our due diligence.
INDEPENDENT PRIVATE SECTOR AUDIT
Our due diligence processes and certain descriptions in this Conflict Minerals Report were audited by Resource Consulting Services Limited ("RCS Global Ltd"), as our independent private sector auditor. The auditor’s report can be found as Appendix A to this Conflict Minerals Report.


13

Appendix A to Conflict Minerals Report of KEMET Corporation
REPORT OF INDEPENDENT PRIVATE SECTOR AUDITOR
[Letterhead of RCS Global Ltd]
INDEPENDENT PRIVATE SECTOR AUDIT REPORT
DODD FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT, SECTION 1502
KEMET CORPORATION
To Senior Vice President - Quality, Global Supply Chain, Chief Compliance Officer and Chief of Staff.
RCS Global Ltd (“RCS Global” or “RCS”) conducted an Independent Private Sector Audit (IPSA) of KEMET Corporation (“the Company”) Conflict Minerals Report for the reporting period of January 1 to December 31, 2019. We examined evidence relating to the audit objectives set forth in 17 CFR Part 249b.400, Section 1, Item 1.01, which state that the auditor is to express an opinion or conclusion as to:
1) Whether the design of the Company’s due diligence framework as set forth in Sections on Due Diligence Measures and Summary of Due Diligence Measures Performed of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, is in conformity, in all material respects, with the criteria set forth in 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 (“OECD Guidance”), and
2) Whether the Company’s description of the due diligence measures it performed, as set forth in the Sections on Due Diligence Measures and Summary of Due Diligence Measures Performed in the Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, is consistent with the due diligence process that the Company undertook.
Management is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. The opinion or conclusion in this audit report is in relation to the two audit objectives. These audit objectives are narrowly defined and do not include the auditor’s opinion on:
•
The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance.
•
The completeness of the Company’s description of the due diligence measures performed.
•
The suitability of the design or operating effectiveness of the Company’s due diligence process.
•
Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance.
•
The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof.
•
The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products.
Consequently, we do not express an opinion or conclusion on the matters listed above or any other matters included in any section of the Conflict Minerals Report other than the design of the Company’s due diligence framework and the Company’s description of the due diligence measures it performed as set forth in the Sections mentioned in the audit objectives.
We conducted this performance audit in accordance with generally accepted government auditing standards, in particular Chapters 1, 2, 3, 6 and 7 of the U.S. Government Accountability Office Generally Accepted Government Auditing Standards, Revision of December 2011. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.
For the first audit objective, we reviewed policies, processes and procedures describing the design of the due diligence framework and conducted interviews with the persons directly responsible for the conflict minerals program at the Company. For the second audit objective, we reviewed records supporting the implementation of due diligence measures as described in the Conflict Minerals Report. For the second audit objective, we adopted a sampling approach for the review of records, taking into account the type of mineral, the total population as well as type and level of risk associated with sourcing practices of supply chain actors.
We believe that the evidence obtained provides a reasonable basis for our findings based on our audit objectives.
Management was provided an opportunity to review and offer comments on a draft of this report and had no comments to the draft report.

14


In our opinion,
•
the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2019, as set forth in the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and
•
the Company’s description of the due diligence measures it performed as set forth in the Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, is consistent with the due diligence process that the Company undertook.
RCS Global Ltd.
London, 23 April 2020
 
By: /s/ JOSUE RUIZ 
MSc Josue Ruiz
Auditor

15