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Anthesis LLC Confidential WD PEC Supplier Webinar March 2015 26 March 2015

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Page 1: WD PEC Supplier Webinar - WordPress.com...WD PEC Supplier Webinar March 2015 26 March 2015 Agenda •Introduction from Western Digital •WD Requirements •Highlights of new PEC process

Anthesis LLC Confidential

WD PEC Supplier WebinarMarch 2015

26 March 2015

Page 2: WD PEC Supplier Webinar - WordPress.com...WD PEC Supplier Webinar March 2015 26 March 2015 Agenda •Introduction from Western Digital •WD Requirements •Highlights of new PEC process

Agenda• Introduction from Western Digital

• WD Requirements

• Highlights of new PEC process

• WDCDC training

• Help desk support

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3

Role of the 3rd party PEC Service Provider:

Communication to Suppliers

Collect all Declaration of Conformity forms, FMD declarations and

3rd party lab reports directly from each supplier

Supplier on-boarding and continuous training via webinar

Prompt support to all suppliers on submission of all required data

and compliance

Provide up to date training on new WD PEC requirements and/or

any new industry updates

Provide regular data to WD on all related metrics with regards to

collection, review and closure of data for each part, by program

basis so we can drive the cycle time required to completely close a

program’s compliance within 30 calendar days (initial goal)

Provide Customer specific report to WD on demand within 2

calendar days

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4

Expected benefits for both WD & Supplier:

Communication to Suppliers

Significantly better and real time support by industry experts

Faster data collection, review and upload to an efficient database,

managed by expert professionals

Automated validation of cumulative declared ppm vs legislation or

WD spec (whichever is tighter), hence improved data accuracy and

compliance -> Reduced risk of non-compliance for both supplier

and WD, with use of significantly improved PEC application

software

Reduced time-to-market for WD products (enable faster ramp to

volume for new programs)

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5

WD Contacts (Asia Materials and SQE)

Communication to Suppliers

CK Goh, Asia Materials Mechanical Director (HDD)

[email protected]

PY Chan, Asia Materials Electrical Senior Manager (HDD)

[email protected]

Sharuddin Razie, Asia Materials Director (Branded Products)

[email protected]

Peter Ng, Asia SQE Director (HDD & Branded Products)

[email protected]

Sasipen Siriwat, Staff Engineer – Asia Prod. Env. Compliance

[email protected]

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Summary of WD’s PEC Requirements

WD PEC Requirements

• The supplier’s parts must meet all the requirements of WD ENVIRONMENTAL SPECIFICATION FOR MATERIALS, COMPONENTS AND PRODUCTS 2096-001669 latest rev

• The supplier must provide data to demonstrate compliance‒ Full Material Disclosure using WDCDC (IPC 1752A compliant)

‒ RoHS and Halogen lab reports on all homogeneous materials –renewed annually

‒ XRF lab reports where any RoHS or halogen controlled substance exceeds 80% of limit – quarterly

‒ Phthalate lab report or guarantee letter – one time

• The supplier must report to WD any material changes that might impact the compliance of their parts

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Summary of WD’s PEC Requirements – Key ChangesKey changes between 2096-001669 rev AM (October 2014) and rev AN (February 2015):

1. Table 2 added to include 161 SVHC Candidate List substances

Note: WD limit is < 1000 ppm (Component Level)

2. Updated Table 1 Substances Prohibited by Government Regulations including Threshold Limits

3. Anthesis added as 3rd party Service Provider with edited WD PEC process flow diagram

4. References to WD Declaration of Conformity form 2093-701020-001 deleted, reference to new WDCDC form added, referenced to Material Safety Data Sheet (MSDS) and IPC 1752 class 5 deleted

5. Required file formats updated to include file naming convention for WDCDC forms

6. New Definitions: Critical Minerals, Nanoparticles, Non-Ferrous Metals

7. Revised classes of materials and substances that must be managed and declared indicated in which table each product (HDD or BP) is required to comply

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New Definitions

• Critical Minerals – A mineral can be regarded as critical only if it performs an essential function for which few or no satisfactory substitutes exist and the supply of which has a high probability of becoming restricted, leading to physical unavailability or excessive costs for the applicable minerals and materials in key applications

The European Commission has identified 14 mineral raw materials, which have high supply risks due to potential shortages resulting from constrained production in the face of high rates of the growth in demand.

(Antimony, Beryllium, Cobalt, Fluorspar, Gallium, Germanium, Graphite, Indium, Magnesium, Niobium, PGMs (Platinum Group Metals), Rare earths, Tantalum, Tungsten)

• Nanoparticles: A natural, incidental or manufactured material that contains particles in an unbound state or as an aggregate or as an agglomerate and where, for 50% or more of the particles in the number size distribution, one or more external dimensions is in the range 1nm-100nm

• Non-Ferrous Metals: Any metal, including alloys, that does not contain iron in appreciable amounts.

Examples of the more commonly used non ferrous metals include

copper, nickel, aluminum, titanium, tungsten steel and brass.

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List of Change Item 6 Materials and Substances ClassificationRevised classes of materials and substances that must be managed and declared

• 6.1 Substances Prohibited by Governmental Laws and Regulations(Table 1) => HDD & BP required to comply on this item

• 6.2 Substances Restricted by REACH Substances of High Concern(SVHC)(Table 2) => HDD & BP required to comply on this item

• 6.3 Substances Prohibited/Restricted by WD specification(Table 3) => Only HDD required to comply on this item

• 6.4 Substances Restricted by Halogen Free/Low Halogen Specification (Table 4) => HDD & BP that WD part numbers with designations XXXX-77XXXX & XXXX-80XXXX, XXXX-20XXXX required to comply on this item

• 6.5 Substances Restricted by Packaging Specification (Table 5) => Only HDD required to comply on this item

• 6.6 Reportable Substances (Table 6) => HDD required to comply on this item

• 6.7 Conflict and Critical Minerals (Table 7) => HDD & BP required to comply on this item

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Section 7.2 Table 1 Substances Prohibited By Governmental Laws & Regulations

Substance CAS Threshold Limit (ppm in Homogenous material)

Regulation

BNST: Benzenamine, N-phenyl-, Reaction Products with Styrene and

2,4,4-Trimethylpentene68921-45-9 Prohibited

Canada Prohibition of Certain Toxic Substances Regulations, 2012 (SOR/2012-285)

Di-μ-oxo-di-n-butylstanniohydroxyborane (DBB)

[also known as dibutyltin hydrogen borate],)

75113-37-0 1000 in preparations ANNEX XVII of REACH Regulation (EC) No 1907/2006

Dimethylfumarate (DMF) 624-49-70.1 in product

Prohibited in desiccantsANNEX XVII of REACH Regulation (EC) No 1907/2006

Diphenylether, octabromoderivative, C12H2Br8O

32536-52-0 1000ANNEX XVII of REACH Regulation (EC) No 1907/2006

Hexachloroethane67-72-1 Prohibited in Non-ferrous

metalsANNEX XVII of REACH Regulation (EC) No 1907/2006

Pentachlorophenol 87-86-51000 ANNEX XVII of REACH Regulation (EC) No

1907/2006

Trichlorobenzene 120-82-1 1000ANNEX XVII of REACH Regulation (EC) No

1907/2006

Monomethyl —

tetrachlorodiphenyl methane,

Trade name: Ugilec 141

76253-60-6 ProhibitedANNEX XVII of REACH Regulation (EC) No

1907/2006

Monomethyl-dichloro-diphenyl

methane, Trade name: Ugilec

121; Ugilec 21

EC#400-

140-6Prohibited

ANNEX XVII of REACH Regulation (EC) No

1907/2006

Monomethyl-dibromo-diphenyl

methane

bromobenzylbromotoluene,

mixture of isomers; Trade

name: DBBT

99688-47-8 ProhibitedANNEX XVII of REACH Regulation (EC) No

1907/2006

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Substance CASThreshold Limit (ppm in homogeneous material)

Brominated Flame Retardants, BFRs32534-81-940088-47-9

1000 on products casing;not to be used in adhesive

Cd in Plating 7440-43-9 50

Hexavalent Chromium and its Compounds in metals, metal plating, or conversion coatings, paints, inks and plastics

7440-47-3Non Detectable and not intentionally

added

Lead in plastics, rubber, coatings,paint, inks, dyes and pigments

7439-92-1 100

Nickel/Nickel Compounds1000 - Metallic nickel or nickel alloy

exempted in allapplications

Perflourooctane sulfonate (PFOS)1763-23-1

Prohibited from use in manufacturing processes in preparations exceeding 50ppm (Exemption- Photoresists or

antireflective coatings for photolithography purposes)

ND -Photoresists or anti-reflective coatings

for photolithography processes, photographic coatings applied to films,

papers or printing plates.

Section 7.4 Table 3 Substances Prohibited/Restricted by WD

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New WD PEC Process

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Highlights of the New PEC Process

Key changes from current PEC process:

1. All FMD data and certain lab data will be submitted by suppliers using the Western Digital Compliance Data Collection (WDCDC) IPC 1752A compliant form

2. The use of the existing 2093-701020-001 WD Supplier Declaration of Conformity for HDD will be discontinued

3. Data collection will be via email workflow, not upload to the ECT database as in the past

4. The Anthesis Compliance Suite (ACS) software will be used to automate the data collection and validation process

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Highlights of the New PEC Process

1. WD will identify parts and suppliers needing data – new HDD programs, new parts, ECOs*

2. Data requests are sent to the supplier by email from [email protected]• The data request email has attached a form, WDCDC, for suppliers to provide

full material disclosure (FMD) data

• The data request email lists other reports the supplier is required to submit

3. Supplier inputs FMD data and required information into the WDCDC form. Version IPC 1752-2 files can be uploaded into WDCDC

4. Supplier responds by email to [email protected] and provides compliance data – WDCDC file, RoHS and halogen lab reports, phthalate report, and XRF report if required

• Note that some suppliers may need to submit FMD data using the new WDCDC form even if you have submitted the same data to WD in the past

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Highlights of the New PEC Process

5. The Anthesis Compliance Suite (ACS) software opens supplier’s email and reads compliance data files, and checks for completeness and compliance with WD’s ENVIRONMENTAL SPECIFICATION FOR MATERIALS, COMPONENTS AND PRODUCTS 2096-001669

6. Anthesis performs manual checks, and accepts or rejects the data• Rejected submissions are returned to the supplier with a

request for changes needed.

• Accepted submissions are loaded into the ACS data base

• WD accesses dashboards and data reports in the ACS application

• Anthesis uses the data to prepare standardized and custom reports for WD customers

7. Anthesis provides help desk support for suppliers to answer any questions and to help with compliance data submittals

• Note: If supplier’s file sizes are too large for a supplier’s email systems, contact Anthesis for instructions on how to provide those large files.

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WDCDC Training

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WDCDC Form User Instructions

From the dropdown provided, choose ‘Accepted’ upon your acceptance of the Legal declaration described.

- All Mandatory fields are noted with an asterisk (*). When a mandatory field isleft blank, an error prompt will be seen by the user.

- Use dropdowns when available. Use cut and paste special functions only whenpossible.

- Supported versions of Microsoft Excel: 2007 SP and above

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WDCDC Form User Instructions

Answer all Supplier Information fields. For the Company Unique ID, please indicated your Company DUNS ID. If you do not

have a DUNS number, you may obtain or update your DUNS number at the following site: http://www.dnb.com/get-a-duns-number.html. There is no charge for requesting and obtaining a DUNS number.

All Requester Information will be pre-populated and provided in the form

Business Information Tab

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WDCDC Form User Instructions

WD suppliers can declare a single part or multiple parts that belong to one

product family in one declaration form.

Single part declaration

Multiple Parts declaration

Parts must be the same weight and composition

and utilize the same exemptions

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If a certain homogeneous material is associated in a sub product, choose the sub product in the dropdown.

WDCDC Form User Instructions

Select the Material Group of the Homogeneous Material from the dropdown provided.

Input the total mass/weight of the Homogeneous Material. This should be numeric in value and should match the Unit of measure selected. Use the dropdowns to select the UoM. Use only one UoM for the whole declaration.

Input the homogeneous materials associated to each product.

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WDCDC Form User Instructions

Select the Homogeneous Material that a specific substance should be mapped with from the dropdown. These has been concatenated based on the information provided from the previous tabs.

Choose the Level of declaration of the homogeneous material from the dropdown.

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WDCDC Form User Instructions

• Substance Name: Input the Substance Name. A complete Chemical Substance

Name is required to be inputted. This is a mandatory field. An error will be

prompted when no data is inputted.

• CAS Numbers must be provided unless unavailable for the substance which is

being declared.

• Mass: Indicate the mass of the substance if you have chosen Mass in the

Setting Tab. If not, this cell will be disabled. The form will require the

concentration of the substance.

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WDCDC Form User Instructions

• UoM: Indicate the Unit of measure used in the substance declaration from the dropdown

provided.

• Concentration: This is an editable field where the concentration of a regulated substance category

in % of homogeneous material mass must be entered if Concentration has been selected in the

Settings Tab.

• Select the applicable EU RoHS exemption in the dropdown if the part exceeds the regulated

values. The exemption description will be automatically pre-populated once the exemption has

been chosen in the dropdown.

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The indicated data from RoHS and halogen lab reports for the Product must be entered

in this tab. Note: All concentrations must be entered as ppm (mg/kg). The actual lab

reports must also be submitted but you must fill in the lab report data in this Lab Data.

Note that Lab Report File Name must conform to file naming conventions in WD

Environmental Specification 2096-001669 (also shown in subsequent slide).

WDCDC Form User Instructions

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This tab summarizes all the information inputted by the user. It indicates if the required information

has been satisfied by showing green “Completed” notification and indicated the missing information

by showing the red “Required” notification on the required fields. A link is provided so that the user

can return to the specific tab or cell where a required information is missing or incorrect in value.

Once all the required fields has been satisfied and completed, the form is ready for submission to

WD.

WDCDC Form User Instructions

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Option to import IPC 1752-2 to WDCDC

Select the format of the file you are trying to import, i.e. IPC 1752-2

Click on the Import button and load the IPC 1752-2 XML file and the data will be loaded into the WDCDC. You may also use this function if you would like to edit previous XML with similar format. After uploading the XML you may have to make some edits to the information in WDCDC, to conform with all of the WD requirements.

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WD File Naming ConventionsSupplier must follow the file naming conventions specified in WD Environmental Specification 2096-001669 rev AN:

• WDCDC: Supplier name_WDCDC_WD part number (Supplier part number)(Day_Month_Year)

Example: ACME_WDCDC_1234567(ACME123)(23_02_2015)

Laboratory Reports:• RoHS report : Supplier Name_RS_Sub Component Name_Material

Name&Type_Mfg Name (Day_Month_Year)

Example: ACME_RS_Capacitor_leadframe_Fabricators Inc (23_02_2015)

• HF report : Supplier Name_HF_Sub Component Name_MaterialName&Type_Mfg Name (Day_Month_Year)

Example: ACME_HF_Capacitor_leadframe_Fabricators Inc (23_02_2015)

• Phthalates report : Supplier Name_Phthalates_Sub Component Name_MaterialName&Type_Mfg Name (Day_Month_Year)

Example: ACME_Phthalates_Capacitor_leadframe_Fabricators Inc (23_02_2015)

• RoHS & HF report : Supplier Name_RS_HF_Sub Component Name_MaterialName&Type_Mfg Name (Day_Month_Year)

Example: ACME_RS_HF_Capacitor_leadframe_Fabricators Inc (23_02_2015)

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Key Anthesis Contacts

John Hennessey

PEC Project ManagerEmail: [email protected]

Doug Lockwood

PEC Program ManagerEmail: [email protected]

Irene Oliquino

WD PEC Project LeadEmail: [email protected]

Sharleen Rivera

Manager, Manila Support TeamEmail: [email protected]

Supplier Help Desk and Training PEC Program Management

The help desk is available to help you with any questions on compliance data submittals and WD PEC requirements

+632-667-3016+639176822398

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Back up

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30

FAQ (Frequently Asked Questions)Communication to Suppliers

WD CONFIDENTIAL

What is PEC?

PEC = Product Environmental Compliance; all suppliers to WD must comply with the EU RoHS,

Reach, Halogen free, etc. Besides the legislative requirements, WD has also included customers

requirements that are more stringent than what’s required by law

Why should supplier pay USD1k per year to Anthesis, as suggested by WD?

WD proposed “Joint accountability model” as both supplier and WD are jointly responsible to

comply with WD PEC spec (to WD’s customers and those bounded by law)

WD is primary party that is fully responsible for the fees charged by Anthesis to collect, validate

and assure compliance for all WD’s suppliers/parts. Even after the supplier fee offset, WD still

owns more than half the total costs incurred. Cost to each supplier is a very small fraction of

WD’s costs. WD appreciates the co-operation and joint accountability spirit from all our valued

suppliers

If we have several divisions under the same group of company, do we need to

provide > 1 PEC contact? How will supplier be charged?

Supplier may opt to provide more than 1 PEC contact (please specify what parts are covered by

each contact)

Supplier only need to pay USD1k for all your company’s (under same Group of companies) parts

shipped to WD, even if they come under HDD and Branded Products BU

Is this a common industry practice?

Yes, several 3rd party service provider have managed this model successfully

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31

FAQ (Frequently Asked Questions)Communication to Suppliers

WD CONFIDENTIAL

What are the benefits to suppliers?

Access to industry experts whose core business is to assure compliance

Unlimited training, webinars, technical support by phone, email, etc

Improved confidence to comply fully with WD PEC requirements

Regular updates/training on new industry and/or WD PEC requirements

What are the benefits to WD?

Significantly increased automation to validate 100% of all our suppliers/parts

comply with WD PEC spec, reducing our risks of non compliance (we are

limited with only few full time staff on PEC, using manual processes)

What are the new role of WD PEC engrs?

WD PEC will need to trigger Anthesis on NPL BOM and AVL for them to start

the data collection, review and approval with all suppliers

Randomly audit Anthesis completeness and quality of work (initial stage)

Conduct on site audit at suppliers for higher risk suppliers

Focus on suppliers/parts that are of higher risk of non-compliance, based on

data validated by Anthesis

Focus on WD customers’ audit and request for PEC data

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FAQ (Frequently Asked Questions)

Communication to Suppliers

WD CONFIDENTIAL

How does this affect suppliers communication to WD SQE?

Not affected, this 3rd party service provider appointment is to cover PEC only. There is

another module on Conflict Minerals that Anthesis will help collect data for WD Materials

team

WD SQE will continue to be suppliers’ direct contact for WD Quality and Technical

information

What NDA are in place between WD and Anthesis?

Mutual NDA signed between WD and Anthesis dated 17 Oct 2013

Do we need to sign 3 way NDA among WD, Anthesis and Supplier?

Not required per WD legal counsel and Anthesis (from their experience with Clients on

similar service provided)

WD already has NDA with Suppliers and has appointed Anthesis as its agent for the sole

purpose of collecting this data on WD’s behalf

What is Duns# ?

the D-U-N-S number is supplied by Dun & Bradstreet http://www.dnb.com/get-a-duns-

number.html. We often use this number to uniquely identify a supplier. Most of them would

have this number. Although optional, it can prove very useful in weeding out duplicate

supplier and contact records (this apply to off-the-shelf parts; not for custom/ASIC parts)

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®

WD Acceptable Test Methods- All Materials

Removed Pretreatment Method & Revised Minimum Detection Limit

Cadmium (Cd) and Its Compounds

Reference to methods in IEC 62321:2008

Analysis Method: AA, ICP/AES, ICP/OES or

ICP/MS

Detection Limit must be declared in the

report at the minimum 50% < than threshold

limit.

Mercury (Hg) and its Compounds

Reference to methods in IEC 62321:2008

Analysis Method: AA, ICP/AES, ICP/OES, ICP/MS

or Mercury Analyzer

Detection Limit must be declared in the report at

the minimum 50% < than threshold limit.

Hexavalent Chromium (Cr (VI)) and Its

Compounds

Reference to methods in IEC 62321:2008

Polymers and Non-Metal homogeneous

materials:

Analysis Method: UV-VIS Spectrometry

Metal homogeneous materials:

Analysis Method: UV-VIS Spectrometry

Detection Limit must be declared in the

report at the minimum 50% < than threshold

limit.

Polybrominated biphenyls (PBB) polybrominated

diphenylethers (PBB/PBDE), and

Hexabromocyclododecane (HBCDD)

Reference to methods in IEC 62321:2008

Analysis Method: GC/MS

Detection Limit must be declared in the report at

the minimum 50% < than threshold limit.

Testing not required for metals

NOTE- For Hexabromocyclododecane (HBCDD)

ONLY, “Total Halogen” test can be used to

demonstrate compliance with WD approval.

Page 33

WD Confidential

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®

WD Acceptable Test Methods- All Materials

Lead (Pb) and Its Compounds

Reference to methods in 62321:2008

Analysis Method: AA, ICP/AES, ICP/OES

or ICP/MS

Detection Limit must be declared in the

report at the minimum 50% < than

threshold limit.

Phthalates (DEHP, BBP, DBP, DINP, DNOP, DIDP)

Reference to methods in EN14372 Analysis

Analysis Method: GC/MS

Detection Limit must be declared in the report at

the minimum 50% < than threshold limit.

Testing not required for metals

Total Halogen

EN 14582 Method B

Testing not required for metallic materials

(testing is required for all non-metals,

including glass, ceramic and silicon)

Applicable to WD part numbers with designations

XXXX-77XXXX and/or those with “HF” in the part

description. Total Halogen must be tested for

using the method listed.

Page 34

WD Confidential

Summary: Supplier need to ensure the material must be sent to testing by accredited

laboratory (ISO17025) & used Pretreatment method follow WD Acceptable test

method and minimum detection limit of 3rd laboratory must be equal or less than

minimum detection limit specified above

Removed Pretreatment Method & Revised Minimum Detection Limit

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®

WD Supply chain Conflict Minerals Training Material

Maneerat S.EICC / CSR

Nov 2014

WD CONFIDENTIAL

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®

Overview of Conflict Minerals : Exploitation and trade of conflict minerals

originating in the Democratic Republic of the

Congo (DRC) is helping to finance conflict

characterized by extreme levels of violence in

the eastern DRC. This conflict has claimed

more than 5.4 million lives since it began in

the late 1990’s.

“DRC conflict-free” cover Democratic Republic of the Congo

(DRC)

Central Africa Republic

The Republic of the Congo

Tanzania

Burundi

Rwanda

Uganda

The Republic of South

Sudan

Zambia

Angola

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WD Conflict Minerals

The Conflict Minerals Rule was adopted by the Securities and Exchange

Commission (SEC) in August 2012. It was mandated by Section 1502 of the

Dodd-Frank Act.

WD required to conduct due diligence/ SEC report to determine whether the

conflict minerals in its products originated in the DRC or one of the nine

adjoining countries “DRC conflict minerals” or not.

WD actions :

WD Corporate declares the Conflict Minerals / Metals statement in the

website http://www.wdc.com/en/company/globalcitizenship/supplychainmgmt.aspx

Establish CFM requirement in to WD spec. 2096-001669 rev. AM.

WD expects suppliers to adhere to the following:

To source materials responsibly and not fund armed groups that are

committing human rights abuses in the DRC.

To comply with the Conflict Minerals rule adopted by the SEC.

To provide the necessary declarations on a product level before or by

the deadline requested.

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WD’S Conflict Minerals Next Steps :

Please ensure that 3TG contained in materials that supply to WD was processed by

smelters validated by the Conflict Free Smelter Program.

Not use the conflict minerals originated from the Democratic Republic of the Congo

(DRC) and its adjoining countries.

Make the same requirements to their upstream suppliers, and push the down-

stream supplier identified by CFS and get certification;

By the end of 2014 that produce tantalum for use in materials supplied to WD

must be included on the Conflict Free Smelter Program List.

By the end of 2016, any facilities in your supply chain that produce tin,

tungsten, or gold for use in supplied to WD must be included on the Conflict

Free Smelter Program List.

Require supplier to resubmit with new revision of CMRT 3.02 ( CFSP released on

12th Nov 2014)

Supplier shall address and provide necessary validation for the item

identified “Red flag” procedure 80-020768-000 by WD.

Supplier shall declare 100% of their smelters in supply chain cover only WD

“Product level”.

Supplier shall declare country of origin of mine (Col. N of Smelter Tab).

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WD ConfidentialWD Confidential

WD Conflict Mineral contact person:

WD Ethics Hotline has now been updated to reflect conflict minerals.

http://www.wdc.com/en/company/governance/EthicsHotline.aspx

Key contacts – Procurement department is responsible to ensure the new

supplier sign the declare the conflict minerals / metals (EICCGeSI Due

Diligence) before the supplier qualification activity starts.

Piriya Wijackanaphan [email protected]

Pricha Leelanukrom [email protected]

Maneerat Singkham [email protected]

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Store In the Data storage

Supplier Working on the report template

Conflict Minerals Team

Validate the report

Request sent to

Suppliers

Request Doc

- EICC

conflict

minerals the

last revision

of due

diligence

reporting

tool (

CMRT) refer

from http://www.conf

lictfreesmelter.

org/activesmelt

erList.htm by

yearly basis

Suppliers are

require to

- Understand to

conflict mineral

information from

their lower tier

level supplier

- Determine

whether their

products

component

contain 3TG

- Determine the

smelter or mine

origin

Suppliers are require

to Completed CMRT

report then sent to WD

Suppliers are require

to Completed Survey

Report then sent to

WD if smelters are not

in active list refer CFSI

(http://www.conflictfreesmelt

er.org/activesmelterList.htm)

All

completed

CMRT

report will

be stored in

WD data

base for 5

Years

WD’S Conflict Minerals Due Diligence : Overall process flow

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EICC conflict mineral due diligence reporting tool ( CMRT)

Pls. complete CMRT Form by refer the last template with link

http://www.conflictfreesourcing.org/conflict-minerals-reporting-template/

Pls. refer training file “ How o complete CMRT Form” by link :

http://www.conflictfreesourcing.org/resources-and-training/training/

Save your Template as “Company Name-Date” using the date format of

YYYY-MM-DD (e.g., Supplier XXX_ November 29, 2012).

Please send your completed Template to [email protected]

We will review your template and get back to you with questions. If you

have smelters that are not in the Standard Smelter Names Worksheet, we

will want to learn more about them, so you can expect more questions.

If you have any questions about the Template or Conflict Minerals, please

contact us at [email protected]. We will be happy to try to

answer any questions. If we don’t know the answer, we can probably find

someone who does.

WD Confidential

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8. Conflict MineralPage 42

8.5 Materials Declaration must declare percentage of Conflict and Critical Minerals is

present at a homogeneous level.

8.5.1 TABLE 7 Conflict and Critical Minerals Table

WD Confidential

Critical Minerals

Antimony Beryllium Cobalt

Fluorspar Gallium Germanium

Graphite Indium - RL 7.6 Magnesium

Niobium Tantalum Tungsten

PGMs (Platinum Group Metals): Platinum, Palladium, Indium, Rhodium, Ruthenium, Osmium

Rare Earths: Yttrium, Scandium, and the so-called lanthanides (Lanthanum,

Cerium, Praseodymium, Neodymium, Promethium, Samarium, Europium,

Gadolinium, Terbium, Dysprosium, Holmium, Erbium, Thulium, Ytterbium and

Lutetium

Conflict Mineral:

Tin Tungsten Tantalum Gold

Summary: Both HDD & BP supplier required to declare ppm of Conflict & Critical

Mineral if component contained any substances in homogenous material