UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized Disclosure Report
ENPHASE ENERGY, INC.
(Exact name of registrant as specified in its charter)
| Delaware | 001-35480 | 20-4645388 | ||
| (State of incorporation) | (Commission File No.) |
(IRS Employer Identification No.) |
1420 N. McDowell Blvd
Petaluma, CA 94954
(Address of principal executive offices and zip code)
| Kris Sennesael, Vice President and Chief Financial Officer | (707) 774-7000 | |
| (Name and telephone number, including area code, of the person to contact in connection with this report) | ||
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:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
Section 1 - Conflict Minerals Disclosure
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report
Enphase Energy, Inc. (the “Company”) evaluated its current products and determined that certain products it manufactures or contracts to manufacture contain conflict minerals originating in the Democratic Republic of the Congo or adjoining countries. As a result, the Company has prepared, and is filing with this Form, a Conflict Minerals Report. A copy of the Company’s Conflict Minerals Report for the calendar year ended December 31, 2014 is provided as Exhibit 1.01 to the Specialized Disclosure Report and is publicly available on the Company’s corporate website at www.enphase.com/company.
Section 2 - Exhibits
Item 2.01 Exhibits
| Exhibit Number |
Description | |
| 1.01 | Conflicts Minerals Report for the reporting period January 1, 2014 to December 31, 2014. | |
SIGNATURES
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 undersigned hereunto duly authorized.
| Date: June 1, 2015 | ENPHASE ENERGY, INC. | |||||
| By: | /s/ Taylor Browning | |||||
| Taylor Browning | ||||||
| Associate General Counsel and Assistant Secretary | ||||||
Exhibit 1.01
ENPHASE ENERGY, INC.
CONFLICT MINERALS REPORT
FOR THE YEAR JANUARY 1, 2014 THROUGH DECEMBER 31, 2014
| 1. | INTRODUCTION |
This report for the year January 1, 2014 through December 31, 2014 (the Reporting Period) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the 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). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. Conflict minerals are defined as tin, tantalum, tungsten, and gold (3TG or Conflict Minerals) for the purposes of this assessment. These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
If a registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the Covered Countries), or from recycled and scrap sources, it must submit a Form SD that describes the Reasonable Country of Origin Inquiry (the RCOI) completed.
If a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the registrant must perform due diligence on the Conflict Minerals’ source and chain of custody. The registrant must annually submit a Conflict Minerals Report (CMR) to the SEC that includes a description of those due diligence measures.
| 2. | COMPANY OVERVIEW |
This report has been prepared by management of Enphase Energy, Inc. (herein referred to as Enphase Energy, the Company, we, us, or our). The information includes the activities of all majority-owned subsidiaries.
Enphase Energy delivers microinverter technology for the solar industry that increases energy production, simplifies design and installation, improves system uptime and reliability, reduces fire safety risk and provides a platform for intelligent energy management. We were founded in March 2006 and have grown rapidly to become the market leader in the microinverter category. Since our first commercial shipment in mid-2008, we have sold nearly 8 million microinverters as of March 31, 2015. Our sales efforts are focused in the United States, Canada, France, the United Kingdom, Italy, the Benelux Region, Australia and New Zealand. We sell our microinverter systems primarily to distributors who resell them to solar installers. We also sell directly to large installers, through original equipment manufacturers and strategic partners. We have approximately 570 employees located in the United States, Europe, Australia and New Zealand. Our principal executive offices are located at 1420 N. McDowell Blvd., Petaluma, CA 94954.
| 3. | PRODUCTS OVERVIEW |
Enphase Energy designs, develops, and sells microinverter systems for the solar photovoltaic industry. The Company’s microinverter system consists of: (i) an Enphase microinverter and related accessories that convert direct current (DC) power to grid-compliant alternating current (AC) power; (ii) an Envoy communications gateway device that collects and transmits performance information from each solar
module to the Company’s hosted data center; and (iii) the Enlighten web-based software platform that collects and processes this information to enable customers to monitor and manage their solar power systems.
Based upon Enphase Energy’s internal assessment, the Enphase microinverter products, certain related microinverter accessories and the Enphase Envoy contain Conflict Minerals that are necessary to the functionality or production of those products. Accordingly, for the purposes of this assessment, only Enphase Energy’s microinverter products, certain related microinverter accessories and the Enphase Envoy (the Covered Products) were considered.
| 4. | REASONABLE COUNTRY OF ORIGIN INQUIRY |
Enphase Energy relies upon its suppliers to provide information on the origin of 3TG contained in components and materials supplied to it, including sources of 3TG that are supplied to them from sub-tier suppliers. Our suppliers are expected to provide the 3TG sourcing information to us per our Conflict Minerals Policy and Supplier Code of Conduct.
We performed a comprehensive analysis of our product components and the role that suppliers play throughout our manufacturing and product delivery processes. We defined the scope of our Conflict Minerals RCOI by identifying and reaching out to suppliers that provided components or engaged in manufacturing activities that are likely to contain 3TG during the Reporting Period. During the process of our review, we identified 98 suppliers who were within the scope of RCOI.
We, through our outside agent Flextronics International Ltd. who is assisting us in our RCOI and due diligence efforts, conducted a survey of our active suppliers and sub-suppliers using the template developed jointly by the companies of Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the Conflict Free Sourcing Initiative (CFSI) Reporting Template (the Template). The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the Template contains questions about the origin of Conflict Minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on CFSI’s website. The Template is widely adopted by many companies in their due diligence processes related to Conflict Minerals.
We continued to seek supply chain responses through April 14, 2015, and were able to determine the country of origin of most of the Conflict Minerals in our supply chain. We received 91 responses from the 98 suppliers surveyed. The responses were reviewed against criteria developed to determine which suppliers required further engagement.
Due to the breadth, complexity and constant evolution of Enphase Energy’s products and supply chain, it will take time for all of the remaining suppliers to verify the origin of all of the Conflict Minerals. In addition, the information provided by suppliers may be inaccurate, incomplete or subject to other irregularities. Moreover, because of the Company’s relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited. By using our supply chain due diligence processes, driving accountability within the supply chain by leveraging the CFSI’s Conflict-Free Smelter Program (CFSP), and continuing our outreach efforts, we hope to further develop transparency into our supply chain.
| 5. | CONFLICT MINERALS STATUS ANALYSIS AND CONFLICT STATUS CONCLUSION |
Enphase Energy has been unable to reasonably determine whether all of the 3TG used in our Covered Products either originated in the Covered Countries or came from recycled or scrap sources, or whether
| 2 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |
they were used directly or indirectly to finance or benefit armed groups in the Covered Countries. There has, however, been significant improvement in the number of suppliers in our supply chain sourcing from smelters that are CFSI’s certified Conflict Free Smelters (CFS) and considered to be conflict free between this Reporting Period and the 2013 Reporting Period.
| 6. | DUE DILIGENCE PROCESS |
| 6.1 | Design of Due Diligence |
Enphase Energy’s due diligence processes have been designed in conformity with, in all material respects, the 2nd edition of The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten (OECD Guidance), consistent with our position as a downstream company. Our Conflict Minerals due diligence process includes: the development of a Conflict Minerals Policy, establishment of governance structures with cross-functional team members and senior executives, communication to, and engagement of, suppliers, due diligence compliance process and measurement on the supplier source and chain of custody, record-keeping and escalation procedures. We periodically report to the Audit Committee and the Board of Directors with respect to our due diligence process and compliance obligations.
| a. | Management Systems – Conflict Minerals Policy |
Enphase Energy’s Conflict Minerals Policy is as follows:
There has been increased awareness regarding the human rights violations in the mining of certain minerals from an area known as the “Conflict Region”: the Democratic Republic of the Congo (“DRC”) and the surrounding countries. Through the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), publically traded companies have been chartered to practice reasonable due diligence with their supply chain to determine if tin, tantalum, tungsten and gold (“Conflict Minerals”) used in their products are being sourced from mines controlled by non-government or unlawful military groups within the Conflict Region. Enphase Energy, Inc. (“Enphase”) is committed to taking all steps to comply with the legislation and is committed to sourcing components and materials from companies that share our values around human rights, ethics and environmental responsibility.
Tracing materials back to their mine of origin is a complex endeavor but an important aspect of responsible sourcing. Enphase Energy looks to industry guidelines to help establish its programs such as the Organization for Economic Co-operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas, the joint Electronic Industry Citizen Coalition and the Global e-Sustainability Initiative, which is taking action to address responsible sourcing through the development of the Conflict-Free Smelter program aiming to enable companies to source conflict-free minerals. Given the complexity of Enphase’s and its suppliers’ respective supply chains, it will take time for many suppliers and sub-suppliers to verify the origin of conflict minerals. We intend to use our supply chain due diligence process to drive accountability within the supply chain to further our goal of conflict-free sourcing.
We are in the process of developing and implementing a strategy to support the objectives of the U.S. regulations on the supply of Conflict Minerals. Our commitment includes:
| • | Developing policies and processes toward preventing the use of Conflict Minerals or derivative metals necessary to the functionality or production of our product(s) that finance or benefit armed groups in the Conflict Region. |
| • | Not knowingly procuring specified minerals that originate from facilities in the Conflict Region that are not certified as conflict free. |
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| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| • | Expecting our suppliers to: (i) provide Enphase with Conflict Mineral content and country of origin information on the products it supplies to Enphase; (ii) cooperate with Enphase (or an independent third party auditor) in any review of its supply chain and procurement process, Conflict Mineral audits, and due diligence on its suppliers as required for Enphase’s annual SEC disclosure in compliance with the Dodd-Frank Act; and (iii) collaborate with Enphase in developing a chain of custody for these Conflict Minerals in the supply chain and identifying and sourcing conflict-free sources for the minerals used in Enphase products. |
| • | Expecting suppliers whose products contain conflict minerals to establish policies, due diligence frameworks, and management systems consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High Risk-Areas that are designed to accomplish this goal, and requiring their suppliers to do the same. |
Enphase believes in establishing and maintaining long-term relationships with suppliers whenever possible. However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating this Policy, then we will require the supplier to commit to devise and undertake suitable corrective action to move to a conflict free source. If suitable action is not taken, we will look for alternative sources for the product. Enphase’s efforts are not to ban procurement of minerals from the Conflict Region, but to assure procurement from responsible sources in the region. If we determine that any of the components of our products contain minerals from a mine or facility that is “non-conflict free,” we will work towards transitioning to products that are “conflict free.”
This policy is publicly available on our website at www.Enphase.com/company.
| b. | Internal Team |
Enphase Energy has established a management system for complying with the applicable rules. Our management system includes a task force led by our Associate General Counsel and Compliance Officer and our Vice President of Supply Chain Management, with oversight by our Chief Financial Officer, Vice President of Manufacturing and Operations and our Audit Committee. They are supported by a team of subject matter experts from relevant functions such as, purchasing, quality assurance, manufacturing and environmental health and safety. The Associate General Counsel and Compliance Officer and our Vice President of Supply Chain Management are responsible for implementing our Conflict Minerals compliance strategy. Senior management and our Audit Committee is briefed about the results of our due diligence efforts on a regular basis.
| c. | Supply Chain Controls |
As we do not typically have a direct relationship with 3TG smelters and refiners, we utilize industry-wide initiatives such as the EICC-GeSI and CFSI to disclose upstream actors in the supply chain.
Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all Enphase employees and our Supplier Code of Conduct, which outlines expected behaviors for all Enphase Energy suppliers.
| d. | Supplier Engagement |
Enphase Energy has reached out, and will continue to reach out, to suppliers and sub-suppliers who have yet to participate in CFSP’s audit program or have been audited, but are not yet completely certified conflict free. We encourage these suppliers to participate in CFSP’s audit program and move towards a conflict free designation as soon as possible. We will endeavor to continually improve our supply chain due diligence by seeking from our material suppliers annual acknowledgments of our Supplier Code of Conduct and other corporate policies, and, to the extent practicable, incorporating Conflict Minerals language in supplier agreements, as they arise.
| 4 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| e. | Grievance Mechanism |
Enphase Energy has established a Conflict Minerals Policy and a Supplier Code of Conduct in addition to multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of our policies.
| f. | Records Maintenance |
Enphase Energy has established our due diligence compliance process and set forth a documentation and record maintenance mechanism to ensure the retention of relevant documentation in a secured electronic database.
| 6.2 | Identification and Assessment of Risk in the Supply Chain |
Because of the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify sources upstream from our direct suppliers. Accordingly, we stay abreast of a number of industry-wide initiatives as described above. Some of the largest suppliers are also SEC registrants and subject to the Rule. We compare the CFSP validated smelter list against those smelters identified by our suppliers and, as described in our Conflict Minerals Policy, we intend to engage any of our suppliers that we have reason to believe are supplying us with 3TG from sources that may support conflict in the Covered Countries to request that they establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.
| 6.3 | Design and Implementation of a Strategy to Respond to Risks |
As we move towards further developing our due diligence program, we intend to further enhance supplier communication, training and escalation processes to improve due diligence data accuracy and completion and continue to influence additional smelters to be designated as “conflict-free” through an independent third-party audit program such as the CFSP through our supply chain, where possible. To the extent we are able to determine in the future that we are sourcing from non-conflict free smelters, we plan to move toward using conflict free smelters within a reasonable time frame.
| 6.4 | Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
Enphase Energy does not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide 3TG to our supply chain. However, we do rely upon the industry initiatives (for example, the CFSI), as well as industry efforts to influence smelters and refiners to be certified through independent third-party audit programs, such as the CFSP.
| 7. | DUE DILIGENCE RESULTS |
| 7.1 | Survey Response |
We received 91 completed Templates from the 98 suppliers surveyed (a 92.86% completion rate). Of the 91 suppliers that provided complete responses to our survey, 53 (54% of total suppliers included in the RCOI scope) confirmed that the Conflict Minerals they sourced did not originate in the Covered Countries. Of the remaining 38 suppliers who indicated that Conflict Minerals originated from the Covered Countries, 16 (16.33%) of them reported that all (100%) of their Conflict Minerals were sourced solely from smelters and refiners that are certified conflict free. 22 suppliers (22.45%) reported that they are still in the process of completing due diligence or that the origin of the smelters and refiners is unknown.
| 5 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Supplier Response | 2014 | 2013 | ||
| Supplier Template Completion Rate |
92.86% (91 of 98) | 70.63% (89 of 126) |
| Status of Suppliers | 2014 | |
| Conflict Minerals Not Originating in Covered Countries or Certified Conflict Free |
70.41% (69 of 98) | |
| Still Completing Due Diligence/Origins Unknown |
22.45% (22 of 98) | |
| Invalid Information Provided |
7.14% (7 of 98) |
Of the 38 suppliers who required due diligence, 9 provided responses on a product basis that was specifically applicable to components or types of components furnished to Enphase Energy. 29 of the suppliers that responded to our survey provided responses on a company-wide or user defined basis that was not specifically applicable to components or types of components furnished to the Company. That is, they were unable to represent to us that 3TG from the smelters or refiners they identified had actually been included in the components they supplied to us or our direct suppliers.
| 7.2 | Efforts to Determine Country of Origin of Mine or 3TG |
Tracing materials back to the mine of origin is a complex aspect of responsible sourcing in our supply chain. By adopting methodology outlined by the CFSI’s joint industry programs and outreach initiatives and requiring that our suppliers conform with standards that meets the OECD guidelines and report to us using the Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or location of origin of the 3TG in our supply chain and responses to such inquiries represents the most reasonable known mine of origin information available. Through this industry joint effort, we have made reasonable efforts to make a reasonable determination of the mines or locations of origin of the 3TG in our supply chain.
| 7.3 | Smelters or Refiners Identified |
We were unable to ascertain the specific country of origin and/or chain of custody of all necessary Conflict Minerals processed by the facilities that contributed to our Covered Products because, for this Reporting Period, 7 suppliers (7.14% of total suppliers included in the RCOI scope) either did not complete the Template or provided invalid information. 2 of those suppliers provided company statements indicating that, to the best of their knowledge, their products do not contain Conflict Minerals, and 22 suppliers (22.45%) reported that they are still in the process of completing due diligence, or that the origin of the smelters is unknown. From the data we were able to obtain from our suppliers, the countries of origin of the Conflict Minerals processed in facilities in our supply chain are believed to include: Australia, Austria, Belgium, Bolivia, Brazil, Canada, China, Estonia, Germany, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, the Republic of Korea, Kyrgyzstan, Malaysia, Mexico, the Netherlands, Peru, Philippines, Poland, Russia, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, the United States, Uzbekistan, and Vietnam.
150 smelters and refiners were identified from the 9 suppliers that provided responses on a product basis. Of those, 145 (96.67%) of the smelters and refiners are identified as CFSI’s known smelters and refiners. Among these 150 smelters and refiners, 111 (74%) are certified conflict free, a significant improvement from the last reporting period.
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| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Status of Identified Smelters and Refiners Reporting on Product-Basis Only | 2014 | 2013 | ||
| Certified Conflict Free |
74% (111 of 150) | 11.07% (31 of 280) |
In total, 246 smelters and refiners were identified as potentially in our supply chain. Of those 246 smelter and refiners, 134 (54.47%) are currently certified conflict free, 37 are on the CFSP “Active List” and are currently in the process of becoming compliant, 10 are in communication with CFSP, and 10 are TI-CMC member companies that have agreed to participate in a CFSP validation audit within the next two years. 55 (22.23%) of the smelters and refiners require outreach. Enphase Energy found no reasonable basis for concluding that any of these smelters or refiners sourced Conflict Minerals that finance or benefit armed groups. Set forth in Annex 1 is the list of all known smelters and refiners identified as potentially being in our supply chain.
| Status of All Identified Smelters and Refiners | 2014 | |
| Certified Conflict Free |
54.47% (134 of 246) | |
| Currently Participating, In Communication, or Agreed to Participate in Audit Process |
23.17% (57 of 246) | |
| Outreach Required |
22.35% (55 of 246) |
CAUTIONARY NOTE ON FORWARD-LOOKING STATEMENTS
Forward-looking statements in this CMR are made pursuant to the safe harbor provisions of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this CMR that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement and risk mitigation efforts and strategy, constitute forward-looking statements that involve risks and uncertainties. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others.
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| Enphase Energy, Inc. 2014 Conflict Minerals Report |
ANNEX 1
| Mineral |
Smelter or Refiner Name |
Smelter Country |
Comments | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | BRAZIL | Compliant | |||
| Gold | Argor-Heraeus SA | SWITZERLAND | Compliant | |||
| Gold | Asahi Pretec Corporation | JAPAN | Compliant | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Compliant | |||
| Gold | Aurubis AG | GERMANY | Compliant | |||
| Gold | Boliden AB | SWEDEN | Compliant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant | |||
| Gold | CCR Refinery – Glencore Canada Corporation (Xstrata Canada Corporation) | CANADA | Compliant | |||
| Gold | Chimet S.p.A. | ITALY | Compliant | |||
| Gold | Dowa | JAPAN | Compliant | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Compliant | |||
| Gold | Heraeus Ltd. Hong Kong | HONG KONG | Compliant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Compliant | |||
| Gold | Japan Mint | JAPAN | Compliant | |||
| Gold | Johnson Matthey Inc | UNITED STATES | Compliant | |||
| Gold | Johnson Matthey Ltd | CANADA | Compliant | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant | |||
| Gold | Kazzinc Ltd | KAZAKHSTAN | Compliant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant | |||
| Gold | Kojima Chemicals Co., Ltd | JAPAN | Compliant | |||
| Gold | L’ azurde Company For Jewelry | SAUDI ARABIA | Compliant | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Materion | UNITED STATES | Compliant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant | |||
| Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG | Compliant | |||
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | SINGAPORE | Compliant | |||
| Gold | Metalor Technologies SA | SWITZERLAND | Compliant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant | |||
| Gold | Met-Mex Peñoles, S.A. | MEXICO | Compliant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant | |||
| Gold | Nihon Material Co. LTD | JAPAN | Compliant |
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| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Gold | Ohio Precious Metals, LLC | UNITED STATES | Compliant | |||
| Gold | Ohura Precious Metal Industry Co., Ltd | JAPAN | Compliant | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION | Compliant | |||
| Gold | PAMP SA | SWITZERLAND | Compliant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant | |||
| Gold | PX Précinox SA | SWITZERLAND | Compliant | |||
| Gold | Rand Refinery (Pty) Ltd | SOUTH AFRICA | Compliant | |||
| Gold | Royal Canadian Mint | CANADA | Compliant | |||
| Gold | Schone Edelmetaal | NETHERLANDS | Compliant | |||
| Gold | SEMPSA Joyería Platería SA | SPAIN | Compliant | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | CHINA | Compliant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant | |||
| Gold | The Refinery of Shandong Gold Mining Co. Ltd | CHINA | Compliant | |||
| Gold | Tokuriki Honten Co., Ltd | JAPAN | Compliant | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Compliant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant | |||
| Gold | Valcambi SA | SWITZERLAND | Compliant | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant | |||
| Tantalum | Duoluoshan | CHINA | Compliant | |||
| Tantalum | Exotech Inc. | UNITED STATES | Compliant | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | Compliant | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant | |||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Compliant | |||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Compliant | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Compliant | |||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Hi-Temp | UNITED STATES | Compliant |
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| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant | |||
| Tantalum | KEMET Blue Metals | MEXICO | Compliant | |||
| Tantalum | KEMET Blue Powder | UNITED STATES | Compliant | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Compliant | |||
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | INDIA | Compliant | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Compliant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Compliant | |||
| Tantalum | Plansee SE Reutte | AUSTRIA | Compliant | |||
| Tantalum | QuantumClean | UNITED STATES | Compliant | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd | CHINA | Compliant | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant | |||
| Tantalum | Taki Chemicals | JAPAN | Compliant | |||
| Tantalum | Telex | UNITED STATES | Compliant | |||
| Tantalum | Ulba | KAZAKHSTAN | Compliant | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | CHINA | Compliant | |||
| Tantalum | Zhuzhou Cement Carbide | CHINA | Compliant | |||
| Tin | Alpha (Cookson) | UNITED STATES | Compliant | |||
| Tin | CV United Smelting | INDONESIA | Compliant | |||
| Tin | Dowa | JAPAN | Compliant | |||
| Tin | EM Vinto (Empresa Metullurgica Vinto/Empressa Nacionnal de Fundiciones (ENAF)) | BOLIVIA | Compliant | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CHINA | Compliant | |||
| Tin | Magnu’s Minerais Metais e Ligas LTDA | BRAZIL | Compliant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant | |||
| Tin | Melt Metais e Ligas S/A | BRAZIL | Compliant | |||
| Tin | Metallo Chimique | BELGIUM | Compliant | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Compliant | |||
| Tin | Minsur | PERU | Compliant | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Tin | OMSA | BOLIVIA | Compliant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Compliant | |||
| Tin | PT Bangka Putra Karya | INDONESIA | Compliant | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Compliant | |||
| Tin | PT Bukit Timah | INDONESIA | Compliant | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Compliant | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant | |||
| Tin | PT REFINED BANGKA TIN | INDONESIA | Compliant | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant |
| 10 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant | |||
| Tin | PT Tambang Timah | INDONESIA | Compliant | |||
| Tin | PT Timah (Persero), Tbk | INDONESIA | Compliant | |||
| Tin | Thaisarco | THAILAND | Compliant | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant | |||
| Tin | Yunnan Tin Company, Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | VIET NAM | Compliant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant | |||
| Gold | Aida Chemical Industries Co. Ltd. | JAPAN | On CFSP Active List | |||
| Gold | Asaka Riken Co Ltd | JAPAN | On CFSP Active List | |||
| Gold | Cendres + Métaux SA | SWITZERLAND | On CFSP Active List | |||
| Gold | Sabin Metal Corp. | UNITED STATES | On CFSP Active List | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | On CFSP Active List | |||
| Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN | On CFSP Active List | |||
| Gold | Yokohama Metal Co Ltd | JAPAN | On CFSP Active List | |||
| Tantalum | King-Tan Tantalum Industry Ltd | CHINA | On CFSP Active List | |||
| Tin | China Rare Metal Materials Company | CHINA | On CFSP Active List | |||
| Tin | China Tin Group Co., Ltd. | CHINA | On CFSP Active List | |||
| Tin | Cooper Santa | BRAZIL | On CFSP Active List | |||
| Tin | CV JusTindo | INDONESIA | On CFSP Active List | |||
| Tin | CV Nurjanah | INDONESIA | On CFSP Active List | |||
| Tin | CV Serumpun Sebalai | INDONESIA | On CFSP Active List | |||
| Tin | Fenix Metals | POLAND | On CFSP Active List | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | On CFSP Active List | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | On CFSP Active List | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | On CFSP Active List | |||
| Tin | PT BilliTin Makmur Lestari | INDONESIA | On CFSP Active List | |||
| Tin | PT Inti Stania Prima | INDONESIA | On CFSP Active List | |||
| Tin | PT Karimun Mining | INDONESIA | On CFSP Active List | |||
| Tin | PT Mitra Stania Prima | INDONESIA | On CFSP Active List | |||
| Tin | PT Panca Mega Persada | INDONESIA | On CFSP Active List |
| 11 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Tin | PT Prima Timah Utama | INDONESIA | On CFSP Active List | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | On CFSP Active List | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | On CFSP Active List | |||
| Tin | Rui Da Hung | TAIWAN | On CFSP Active List | |||
| Tin | Soft Metais, Ltda. | BRAZIL | On CFSP Active List | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | CHINA | On CFSP Active List | |||
| Tungsten | A.L.M.T. Corp. | JAPAN | On CFSP Active List | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | On CFSP Active List | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | On CFSP Active List | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | On CFSP Active List | |||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | On CFSP Active List | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | On CFSP Active List | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | On CFSP Active List | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | On CFSP Active List | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | TI-CMC member company | |||
| Tungsten | H.C. Starck GmbH | GERMANY | TI-CMC member company | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | TI-CMC member company | |||
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | TI-CMC member company | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | TI-CMC member company | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | TI-CMC member company | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | TI-CMC member company | |||
| Tungsten | Kennametal Fallon | UNITED STATES | TI-CMC member company | |||
| Tungsten | Kennametal Huntsville | UNITED STATES | TI-CMC member company | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | TI-CMC member company | |||
| Gold | Chugai Mining | JAPAN | In Communication | |||
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | In Communication | |||
| Gold | Hwasung CJ Co. Ltd | REPUBLIC OF KOREA | In communication | |||
| Gold | Korea Metal Co. Ltd | KOREA, REPUBLIC OF | In communication | |||
| Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF | In communication | |||
| Gold | Torecom | KOREA, REPUBLIC OF | In communication | |||
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | CHINA | In Communication | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | In communication | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | In communication | |||
| Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION | In communication | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Outreach Required |
| 12 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Outreach Required | |||
| Gold | Bauer Walser AG | GERMANY | Outreach Required | |||
| Gold | Caridad | MEXICO | Outreach Required | |||
| Gold | Daejin Indus Co. Ltd | KOREA, REPUBLIC OF | Outreach Required | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Outreach Required | |||
| Gold | Doduco | GERMANY | Outreach Required | |||
| Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION | Outreach Required | |||
| Gold | Gansu Seemine Material Hi-Tech Co Ltd | CHINA | Outreach Required | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Outreach Required | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | Outreach Required | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Outreach Required | |||
| Gold | Jiangxi Copper Company Limited | CHINA | Outreach Required | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Outreach Required | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Outreach Required | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | CHINA | Outreach Required | |||
| Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | CHINA | Outreach Required | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Outreach Required | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Outreach Required | |||
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Outreach Required | |||
| Gold | Penglai Penggang Gold Industry Co Ltd | CHINA | Outreach Required | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Outreach Required | |||
| Gold | So Accurate Group, Inc. | UNITED STATES | Outreach Required | |||
| Gold | So Accurate Refing Group* | UNITED STATES | Outreach Required | |||
| Gold | So Accurate Refing Group* | UNITED STATES | Outreach Required | |||
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA | Outreach Required | |||
| Gold | Tongling nonferrous Metals Group Co., Ltd | CHINA | Outreach Required | |||
| Gold | Yunnan Copper Industry Co Ltd | CHINA | Outreach Required | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Outreach Required | |||
| Gold | Zijin Mining Group Co. Ltd | CHINA | Outreach Required | |||
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA | Outreach Required | |||
| Tin | Coopersanta* | BRAZIL | Outreach Required | |||
| Tin | CV Makmur Jaya | INDONESIA | Outreach Required | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | Outreach Required | |||
| Tin | Gejiu Zi-Li | CHINA | Outreach Required | |||
| Tin | Huichang Jinshunda Tin Co. Ltd | CHINA | Outreach Required | |||
| Tin | Jean Goldschmidt International* | BELGIUM | Outreach Required | |||
| Tin | Linwu Xianggui Smelter Co | CHINA | Outreach Required | |||
| Tin | Metallic Resources Inc* | UNITED STATES | Outreach Required |
| 13 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |
| Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION | Outreach Required | |||
| Tin | PT Alam Lestari Kencana | INDONESIA | Outreach Required | |||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | Outreach Required | |||
| Tin | PT Bangka Kudai Tin | INDONESIA | Outreach Required | |||
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Outreach Required | |||
| Tin | PT Fang Di MulTindo | INDONESIA | Outreach Required | |||
| Tin | PT HANJAYA PERKASA METALS | INDONESIA | Outreach Required | |||
| Tin | PT HP Metals Indonesia | INDONESIA | Outreach Required | |||
| Tin | PT Koba Tin | INDONESIA | Outreach Required | |||
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Outreach Required | |||
| Tin | PT Supra Sukses Trinusa | INDONESIA | Outreach Required | |||
| Tin | PT Tommy Utama | INDONESIA | Outreach Required | |||
| Tin | PT Yinchendo Mining Industry | INDONESIA | Outreach Required | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Outreach Required | |||
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA | Outreach Required |
| * | Smelters not listed as CFSI’s known smelters and refiners |
| 14 | ||
| Enphase Energy, Inc. 2014 Conflict Minerals Report |