Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

 

   √               Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014

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Introduction

This Specialized Disclosure Report on Form SD ("Form SD") of Intel Corporation ("Intel" or "we") for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to "conflict minerals" as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten.  The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (such minerals are referred to as "necessary conflict minerals"), excepting conflict minerals that, prior to January 31, 2013, were located "outside of the supply chain" (as defined in the Rule). For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo ("DRC") or an adjoining country, collectively defined as the "Covered Countries".  If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals contained in its products originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence as a method to conclude if the necessary conflict minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries.  Products which do not contain necessary conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered "DRC conflict free". We use the term "conflict free" in this Form SD in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries. Numerous terms in this Form SD are defined in the Rule and the reader is referred to that source and to SEC Release No. 34-67716 issued by the Securities and Exchange Commission on August 22, 2012 for such definitions.

 

Company Overview

 

We design and manufacture advanced integrated digital technology platforms. A platform consists of a microprocessor and chipset, and may be enhanced by additional hardware, software, and services. We sell these platforms primarily to original equipment manufacturers, original design manufacturers, and industrial and communications equipment manufacturers in the computing and communications industries. Our platforms are used to deliver a wide range of computing experiences in notebooks (including Ultrabook™ devices), 2 in 1 systems, desktops, servers, tablets, smartphones, and the Internet of Things (including wearables, transportation systems, and retail devices). We also develop and sell software and services primarily focused on security and technology integration.

 

Overview of Intel's Conflict Minerals Program

 

As a semiconductor manufacturer, we are knowledgeable of the design of our products including the materials needed to construct them.  We design the manufacturing processes to build those products and in some cases, design the detailed materials to manufacture those products. As a result, we know that many of our hardware products contain tantalum, tin, tungsten and/or gold that is necessary to the functionality or production of those products. Conflict minerals are obtained from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups in the Covered Countries. We believe that it is important for us and other companies to support responsible in-region mineral sourcing from the Covered Countries in order to not negatively affect the economies of such countries. Intel is a founding member of the Public Private Alliance for Responsible Minerals Trade (PPA). We participate in the "Solutions for Hope" project that provides suppliers with tantalum from conflict free sources in the DRC, and we are an associate member of the ITRI Tin Supply Chain Initiative (iTSCi) that establishes traceability in the upstream mineral chain in the DRC, Rwanda and Burundi.

We are an industry leader in the conflict minerals subject area, where we have worked extensively for over seven years to put in place processes and systems to develop conflict free supply chains for Intel and our industry. We recognize that broad collaborative efforts among governments, non-governmental organizations and industry are needed to solve this complex problem. Intel is a member of the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI)'s Conflict-Free Sourcing Initiative ("CFSI", unique member code INTC) and as such, are working with companies in the electronics and other industries that use necessary conflict minerals (e.g., jewelry, automotive, medical instrumentation, and others) to help create conflict free supply chains. In 2013 and 2014, we manufactured microprocessors that are DRC conflict free for tantalum, tin, tungsten and gold. In 2015, we are continuing our work to establish conflict free supply chains for these conflict minerals.

 

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Conflict Minerals Sourcing Policy

 

Intel's policy with respect to the sourcing of conflict minerals is as follows:

 

Conflict minerals originating from the DRC are sometimes mined and sold, "under the control of armed groups", to "finance conflict characterized by extreme levels of violence". Some of these minerals can make their way into the supply chains of the products used around the world, including those in the electronics industry. Intel's suppliers acquire and use conflict minerals from multiple sources worldwide. As part of Intel's commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, it is Intel's goal to use tantalum, tin, tungsten and gold in our products that do not directly or indirectly finance or benefit armed groups in the Covered Countries while continuing to support responsible mineral sourcing in the region.

 

We expect our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free.  We further expect our suppliers to comply with the EICC Code of Conduct and conduct their business in alignment with Intel's supply chain responsibility expectations.

 

In support of this policy, we will:

 

The full text of our Conflict Minerals Sourcing Policy is available at www.intel.com/conflictfree.  The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.

Supply Chain Description

 

Most of our hardware products, primarily microprocessors, chipsets and their packages, are manufactured in our own network of fabrication facilities ("fabs").  Although many of our hardware products contain conflict minerals, we do not purchase ore or unrefined conflict minerals from mines, and we are many steps removed in the supply chain from the mining of the conflict minerals. We purchase materials used in our products from a large network of suppliers; some of those materials contribute necessary conflict minerals to our products. The origin of conflict minerals cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners (sometimes referred to as "facilities") are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores.  We rely on our suppliers to assist with our reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the conflict minerals contained in the materials which they supply to us.  We are more knowledgeable about the source and chain of custody of the necessary conflict minerals contained in products we fully manufacture in our fabs as compared to products which we manufacture but also include ready-made component parts we purchase from third parties or products that are manufactured for us by other companies.

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SECTION 1 - CONFLICT MINERALS DISCLOSURE

 

Item 1.01                      Conflict Minerals Disclosure and Report

 

Conclusion Based on Reasonable Country of Origin Inquiry

 

Intel has concluded in good faith that during 2014,

 

 

Description of Reasonable Country of Origin Inquiry Efforts

 

For 2014, we conducted a supply chain survey with our suppliers to obtain country of origin information for the necessary conflict minerals in our products using the Conflict Minerals Reporting Template (CMRT). That supply chain survey requests our suppliers to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to Intel. We compared the smelters and refiners identified in the surveys against the lists of facilities which have received a conflict free designation by the CFSP or other independent third party audit program such as the London Bullion Market Association's Responsible Gold Programme and the Responsible Jewellery Council's Chain-of-Custody Certification program. If a smelter or refiner in our supply chain was not listed as having received a "conflict free" designation, we proactively attempted to contact such facility to request country of origin information for the conflict minerals that it processed.  We documented country of origin information for the smelters and refiners identified by the supply-chain survey as provided from multiple sources including the supply-chain survey, independent third party audit programs and directly from smelters and refiners that Intel contacted.

 

There is significant overlap between our RCOI efforts and our due diligence measures performed. Our due diligence measures performed are discussed further in the Conflict Minerals Report filed as Exhibit 1.01 hereto.

 

Below is a summary of the country of origin information collected as a result of our RCOI efforts.

 

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Conflict Minerals Disclosure

 

This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available at www.intc.com and www.intel.com/conflictfree as well as the SEC's EDGAR database at www.sec.gov.

 

 

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

 

 

 

 

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Intel, the Intel logo, and Ultrabook are trademarks of Intel Corporation in the U.S. and/or other countries.

 

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Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

 

 

 

 

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