Section 1 Conflict Minerals Disclosure
Item 1.01
Conflict Minerals Disclosure and Report
Square, Inc. (the Company or Square) is filing this Form SD pursuant to Rule
13p-1
promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2018 to December 31, 2018.
The
Companys primary hardware products include its magstripe reader, contactless and chip reader, chip card reader, Square Stand, Square Register, and Square Terminal, which are all manufactured by third parties (the Covered Products).
A more complete description of the Companys products is included in its Annual Report on Form
10-K
for the year ended December 31, 2018 filed with the Securities and Exchange Commission.
Reasonable Country of Origin Inquiry (RCOI)
Following
our initial determination that certain of our hardware products contain components that contain metallic forms of tin, tungsten, tantalum and/or gold (3TG) minerals (derived from columbite-tantalite (coltan), cassiterite, gold, or
wolframite, Conflict Minerals), we conducted an RCOI to determine whether such 3TG minerals may have originated in the Democratic Republic of Congo and/or adjoining countries (the Covered Countries). Direct suppliers were
asked to provide answers to the RMI-GeSI Conflict Minerals Reporting Template (CMRT) reflecting Squares position on the supply chain. The CMRT is regarded as the most common reporting tool for Conflict Minerals content and sourcing
information worldwide, developed by several of the worlds leading consumer electronics companies.
Responses were reviewed for completeness and
consistency, and we routinely followed up with our suppliers for corrections and clarifications as needed. We submitted this questionnaire to three suppliers. We received responses to the questionnaire from each of these suppliers. The
suppliers CMRTs identified lists of smelters or refiners, which may supply 3TG minerals utilized in our manufactured products. The information obtained indicated that there was reason to believe that a portion of the 3TG minerals used in
Square products may have originated in the Covered Countries and may not be exclusively from scrap or recycled sources.
We believe our RCOI process was
reasonably designed and performed in good faith, but there are inherent limitations in the information provided to us by third parties, including the possibility of information being inaccurate, incomplete or falsified despite our efforts to
validate and confirm the information. Furthermore, we relied on industry association sponsored smelter/refiner audits which may have limitations or errors/omissions.
Determination from RCOI
Based on the results of RCOI,
the Company determined that, with respect to necessary 3TG in its Covered Products, the 3TG minerals may have originated in the Covered Countries, and therefore exercised due diligence on the source and chain of custody of the necessary 3TG.
Additional Information
A copy of this Form SD is
publicly available on the Companys website at http://squareup.com/about/investors. The content of any website referenced in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Not applicable.
Section 2 Exhibits
Not applicable.