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.



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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















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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.
 



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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