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, 2015. |
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 Companys Conflict Minerals Report for the calendar year ended December 31, 2015 is provided as Exhibit 1.01 to the Specialized Disclosure Report and is publicly available on the Companys corporate website at http://investor.enphase.com/sec.cfm.
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit Number | Description | |
1.01 | Conflicts Minerals Report for the reporting period January 1, 2015 to December 31, 2015. |
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: May 27, 2016 | 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, 2015 THROUGH DECEMBER 31, 2015
1. INTRODUCTION
This report for the year January 1, 2015 through December 31, 2015 (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 simple, innovative and reliable energy management solutions that advance the worldwide potential of renewable energy. Our semiconductor-based microinverter system converts direct current (DC) electricity to alternating current (AC) electricity at the individual solar module level, and brings a system-based, high technology approach to solar energy generation leveraging our design expertise across power electronics, semiconductors, networking, and cloud-based software technologies. 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 shipped approximately 11 million microinverters representing over 2.8 gigawatts of solar PV generating capacity, and more than 460,000 Enphase residential and commercial systems have been deployed in over 100 countries. Our sales efforts are focused in the United States, Australia, New Zealand, Europe, and Latin America. 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 525 employees located in the United States, Australia, New Zealand, and Europe. 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 Companys 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 Companys 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 Energys internal assessment, the Enphase microinverter products, certain related 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 Energys microinverter products, certain related 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 84 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 companys supply chain. It includes questions regarding a companys 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 CFSIs 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 27, 2016, and were able to determine the country of origin of most of the Conflict Minerals in our supply chain. We received 79 responses from the 84 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 Energys 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 Companys 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
Enphase Energy, Inc. 2015 Conflict Minerals Report | 2 |
supply chain by leveraging the CFSIs 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, came from recycled or scrap sources, or whether they were used directly or indirectly to finance or benefit armed groups in the Covered Countries. There has, however, been significant improvement year over year in the number of suppliers in our supply chain sourcing from smelters that are CFSIs Certified Conflict Free Smelters (CFS) and considered to be conflict free.
6. DUE DILIGENCE PROCESS
6.1 Design of Due Diligence
Enphase Energys 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. The 3rd edition of the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas was published in April 2016 after we had already substantially completed our due diligence for the Reporting Period. 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 Energys 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 Developments (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 Enphases 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.
Enphase Energy, Inc. 2015 Conflict Minerals Report | 3 |
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. |
| 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 Enphases 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. Enphases 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 https://enphase.com/en-us/conflict-minerals-policy.
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 are 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.
Enphase Energy, Inc. 2015 Conflict Minerals Report | 4 |
Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all Enphase Energy 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 CFSPs audit program or have been audited, but are not yet completely certified conflict free. We encourage these suppliers to participate in CFSPs 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.
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.
Enphase Energy, Inc. 2015 Conflict Minerals Report | 5 |
7. DUE DILIGENCE RESULTS
7.1 Survey Response
We received 79 completed Templates from the 84 suppliers surveyed (a 94.05% completion rate). Of the 79 suppliers that provided complete responses to our survey, 11 indicated that they do not source Conflict Minerals at all, and 22 confirmed that the Conflict Minerals they sourced did not originate in the Covered Countries. Of the remaining 46 suppliers who indicated that Conflict Minerals originated from the Covered Countries, 28 of them reported that all (100%) of their Conflict Minerals were sourced solely from smelters and refiners that are certified conflict free. 18 suppliers reported that they are still in the process of completing due diligence or that the origin of the smelters and refiners is unknown.
Supplier Response | 2015 | 2014 | 2013 | |||
Supplier Template Completion Rate |
94.05% (79 of 84) | 92.86% (91 of 98) | 70.63% (89 of 126) |
Status of Suppliers | 2015 | 2014 | ||
Conflict Minerals Not Originating in Covered Countries or Certified Conflict Free |
72.62% (61 of 84) | 70.41% (69 of 98) | ||
Still Completing Due Diligence/Origins Unknown |
21.43% (18 of 84) | 22.45% (22 of 98) | ||
Invalid or No Information Provided |
5.95% (5 of 84) | 7.14% (7 of 98) |
Of the 46 suppliers who required due diligence, eight provided responses on a product basis that was specifically applicable to components or types of components furnished to Enphase Energy. Thirty-eight 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 CFSIs 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, five suppliers (5.95% of total suppliers included in the RCOI scope) either did not complete the Template or provided invalid information. One of those suppliers provided company statements
Enphase Energy, Inc. 2015 Conflict Minerals Report | 6 |
indicating that, to the best of their knowledge, their products do not contain Conflict Minerals. 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, India, Indonesia, Italy, Japan, Kazakhstan, the Republic of Korea, Kyrgyzstan, Malaysia, Mexico, the Netherlands, New Zealand, Peru, Philippines, Poland, Russia, Rwanda, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, the United States, Uzbekistan, and Vietnam.
One hundred and sixty-one smelters and refiners were identified from the eight suppliers that provided responses on a product basis. Among these, 140 are certified conflict free, an improvement from the last reporting period.
Status of Identified Smelters and Refiners Reporting on Product- Basis Only |
2015 | 2014 | 2013 | |||
Certified Conflict Free |
86.96% (140 of 161) | 74% (111 of 150) | 11.07% (31 0f 280) |
In total, 280 smelters and refiners were identified as potentially in our supply chain. Of those 280 smelter and refiners, 208 are currently certified conflict free, 27 are on the CFSP Active List and are currently in the process of becoming compliant, 16 are in communication with CFSP, and three are TI-CMC member companies that have agreed to participate in a CFSP validation audit within the next two years. Twenty-six of the smelters and refiners require outreach. Of the identified smelters, only one is located in a Covered Country, and that smelter is on the CFSP Active List and is currently in the process of becoming compliant. 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 | 2015 | 2014 | ||
Certified Conflict Free |
74.29% (208 of 280) | 54.47% (134 of 246) | ||
Currently Participating, In Communication, or Agreed to Participate in Audit Process |
16.43% (46 of 280) | 23.17% (57 of 246) | ||
Outreach Required |
9.29% (26 of 280) | 22.35% (55 0f 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 Companys 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 Companys ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others.
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ANNEX 1
Mineral |
Smelter or Refiner Name |
Smelter Country |
Comments | |||
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant | |||
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant | |||
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Compliant | |||
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant | |||
Gold | Umicore Brasil Ltda. | BRAZIL | Compliant | |||
Gold | Asahi Refining Canada Limited | CANADA | Compliant | |||
Gold | CCR RefineryGlencore Canada Corporation | CANADA | Compliant | |||
Gold | Royal Canadian Mint | CANADA | Compliant | |||
Gold | Heraeus Ltd. Hong Kong | CHINA | Compliant | |||
Gold | Jiangxi Copper Company Limited | CHINA | Compliant | |||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant | |||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant | |||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant | |||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant | |||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant | |||
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant | |||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
Gold | Aurubis AG | GERMANY | Compliant | |||
Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant | |||
Gold | Doduco | GERMANY | Compliant | |||
Gold | Heimerle + Meule GmbH | GERMANY | Compliant | |||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant | |||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant | |||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant | |||
Gold | Chimet S.p.A. | ITALY | Compliant | |||
Gold | T.C.A S.p.A | ITALY | Compliant | |||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant | |||
Gold | Asahi Pretec Corporation | JAPAN | Compliant | |||
Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant | |||
Gold | Dowa | JAPAN | Compliant | |||
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant | |||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant | |||
Gold | Japan Mint | JAPAN | Compliant |
Enphase Energy, Inc. 2015 Conflict Minerals Report | 8 |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant | |||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant | |||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant | |||
Gold | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
Gold | Nihon Material Co., Ltd. | JAPAN | Compliant | |||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant | |||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant | |||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant | |||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant | |||
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant | |||
Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant | |||
Gold | Kazzinc | KAZAKHSTAN | Compliant | |||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant | |||
Gold | Met-Mex Penoles, S.A. | MEXICO | Compliant | |||
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant | |||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant | |||
Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant | |||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant | |||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant | |||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant | |||
Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant | |||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant | |||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant | |||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant | |||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant | |||
Gold | SEMPSA Joyería Platería SA | SPAIN | Compliant | |||
Gold | Boliden AB | SWEDEN | Compliant | |||
Gold | Argor-Heraeus SA | SWITZERLAND | Compliant | |||
Gold | Metalor Technologies SA | SWITZERLAND | Compliant | |||
Gold | PAMP SA | SWITZERLAND | Compliant | |||
Gold | PX Précinox SA | SWITZERLAND | Compliant | |||
Gold | Valcambi SA | SWITZERLAND | Compliant | |||
Gold | Singway Technology Co., Ltd. | TAIWAN | Compliant | |||
Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant | |||
Gold | Umicore Precious Metals Thailand | THAILAND | Compliant | |||
Gold | Istanbul Gold Refinery | TURKEY | Compliant | |||
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant | |||
Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant |
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Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant | |||
Gold | Materion | UNITED STATES | Compliant | |||
Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant | |||
Gold | Ohio Precious Metals, LLC | UNITED STATES | Compliant | |||
Gold | Republic Metals Corporation | UNITED STATES | Compliant | |||
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant | |||
Tantalum | Plansee SE Liezen | AUSTRIA | Compliant | |||
Tantalum | Plansee SE Reutte | AUSTRIA | Compliant | |||
Tantalum | LSM Brasil S.A. | BRAZIL | Compliant | |||
Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant | |||
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
Tantalum | Changsha Southern | CHINA | Compliant | |||
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant | |||
Tantalum | Duoluoshan | CHINA | Compliant | |||
Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant | |||
Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant | |||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant | |||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant | |||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant | |||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant | |||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant | |||
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant | |||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant | |||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant | |||
Tantalum | Zhuzhou Cemented Carbide | CHINA | Compliant | |||
Tantalum | Molycorp Silmet A.S. | ESTONIA | 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 Smelting GmbH & Co.KG | GERMANY | Compliant | |||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant | |||
Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant | |||
Tantalum | H.C. Starck Ltd. | JAPAN | Compliant | |||
Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant | |||
Tantalum | Taki Chemicals | JAPAN | Compliant | |||
Tantalum | Ulba | KAZAKHSTAN | Compliant |
Enphase Energy, Inc. 2015 Conflict Minerals Report | 10 |
Tantalum | KEMET Blue Metals | MEXICO | Compliant | |||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant | |||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant | |||
Tantalum | D Block Metals, LLC | UNITED STATES | Compliant | |||
Tantalum | Exotech Inc. | UNITED STATES | Compliant | |||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant | |||
Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant | |||
Tantalum | Hi-Temp | UNITED STATES | Compliant | |||
Tantalum | KEMET Blue Powder | UNITED STATES | Compliant | |||
Tantalum | QuantumClean | UNITED STATES | Compliant | |||
Tantalum | Telex Metals | UNITED STATES | Compliant | |||
Tantalum | Tranzact, Inc. | UNITED STATES | Compliant | |||
Tin | Metallo-Chimique N.V. | BELGIUM | Compliant | |||
Tin | EM Vinto | BOLIVIA | Compliant | |||
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant | |||
Tin | Cooper Santa | BRAZIL | Compliant | |||
Tin | Magnus Minerais Metais e Ligas Ltda. | BRAZIL | Compliant | |||
Tin | Melt Metais e Ligas S/A | BRAZIL | Compliant | |||
Tin | Mineração Taboca S.A. | BRAZIL | Compliant | |||
Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
Tin | Soft Metais Ltda. | BRAZIL | Compliant | |||
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant | |||
Tin | China Rare Metal Material Co., Ltd. | CHINA | Compliant | |||
Tin | China Tin Group Co., Ltd. | CHINA | Compliant | |||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant | |||
Tin | Yunnan Tin Company, Ltd. | CHINA | Compliant | |||
Tin | CV Ayi Jaya | INDONESIA | Compliant | |||
Tin | CV Gita Pesona | INDONESIA | Compliant | |||
Tin | CV Justindo | INDONESIA | Compliant | |||
Tin | CV Nurjanah | INDONESIA | Compliant | |||
Tin | CV Serumpun Sebalai | INDONESIA | Compliant | |||
Tin | CV United Smelting | INDONESIA | Compliant | |||
Tin | CV Venus Inti Perkasa | INDONESIA | Compliant | |||
Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant | |||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant | |||
Tin | PT Babel Inti Perkasa | INDONESIA | Compliant | |||
Tin | PT Bangka Prima Tin | INDONESIA | Compliant | |||
Tin | PT Bangka Tin Industry | INDONESIA | Compliant | |||
Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant | |||
Tin | PT BilliTin Makmur Lestari | INDONESIA | Compliant | |||
Tin | PT Bukit Timah | INDONESIA | Compliant | |||
Tin | PT Cipta Persada Mulia | INDONESIA | Compliant |
Enphase Energy, Inc. 2015 Conflict Minerals Report | 11 |
Tin | PT DS Jaya Abadi | INDONESIA | Compliant | |||
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant | |||
Tin | PT Inti Stania Prima | INDONESIA | Compliant | |||
Tin | PT Mitra Stania Prima | INDONESIA | Compliant | |||
Tin | PT Panca Mega Persada | INDONESIA | Compliant | |||
Tin | PT Prima Timah Utama | INDONESIA | Compliant | |||
Tin | PT REFINED BANGKA TIN | INDONESIA | Compliant | |||
Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant | |||
Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant | |||
Tin | PT Sumber Jaya Indah | INDONESIA | Compliant | |||
Tin | PT Tambang Timah | INDONESIA | Compliant | |||
Tin | PT Timah | INDONESIA | Compliant | |||
Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant | |||
Tin | PT Tommy Utama | INDONESIA | Compliant | |||
Tin | PT Wahana Perkit Jaya | INDONESIA | Compliant | |||
Tin | Dowa | JAPAN | Compliant | |||
Tin | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant | |||
Tin | Minsur | PERU | Compliant | |||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant | |||
Tin | Fenix Metals | POLAND | Compliant | |||
Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Compliant | |||
Tin | Rui Da Hung | TAIWAN | Compliant | |||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant | |||
Tin | Thailand Smelting & Refining Co Ltd | THAILAND | Compliant | |||
Tin | Alpha | UNITED STATES | Compliant | |||
Tin | Metallic Resources, Inc. | UNITED STATES | Compliant | |||
Tin | VQB Mineral and Trading Group JSC | VIETNAM | Compliant | |||
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant | |||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant | |||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Fujian Jinxin Tungsten Co., 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 | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | Compliant | |||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant |
Enphase Energy, Inc. 2015 Conflict Minerals Report | 12 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant | |||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | H.C. Starck GmbH | GERMANY | Compliant | |||
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant | |||
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant | |||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant | |||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant | |||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant | |||
Tungsten | Kennametal Huntsville | UNITED STATES | Compliant | |||
Tungsten | Niagara Refining LLC | UNITED STATES | Compliant | |||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | Compliant | |||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | Compliant | |||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Compliant | |||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Compliant | |||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | On CFSP Active List | |||
Gold | Faggi Enrico S.p.A. | ITALY | On CFSP Active List | |||
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | On CFSP Active List | |||
Gold | Do Sung Corporation | KOREA, REPUBLIC OF | On CFSP Active List | |||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | On CFSP Active List | |||
Gold | Torecom | KOREA, REPUBLIC OF | On CFSP Active List | |||
Gold | Cendres + Métaux SA | SWITZERLAND | On CFSP Active List | |||
Gold | Advanced Chemical Company | UNITED STATES | On CFSP Active List | |||
Gold | Geib Refining Corporation | UNITED STATES | On CFSP Active List | |||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | On CFSP Active List | |||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | On CFSP Active List | |||
Tin | Kai Unita Trade Limited Liability Company | CHINA | On CFSP Active List | |||
Tin | The Gejiu cloud new colored electrolytic | CHINA | On CFSP Active List | |||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | On CFSP Active List | |||
Tin | Feinhütte Halsbrücke GmbH | GERMANY | On CFSP Active List | |||
Tin | PT Karimun Mining | INDONESIA | On CFSP Active List | |||
Tin | Phoenix Metal Ltd. | RWANDA | On CFSP Active List | |||
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | On CFSP Active List | |||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM | On CFSP Active List | |||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | On CFSP Active List | |||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM | On CFSP Active List |
Enphase Energy, Inc. 2015 Conflict Minerals Report | 13 |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | On CFSP Active List | |||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | On CFSP Active List | |||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | On CFSP Active List | |||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | On CFSP Active List | |||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | On CFSP Active List | |||
Tungsten | Kennametal Fallon | UNITED STATES | On CFSP Active List | |||
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | TI-CMC Member Company | |||
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | TI-CMC Member Company | |||
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | TI-CMC Member Company | |||
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | In Communication | |||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | In Communication | |||
Gold | Hunan Chenzhou Mining Industry Co. Ltd. | CHINA | In Communication | |||
Gold | Shandong Tarzan Bio-Gold Industry Co., Ltd. | CHINA | In Communication | |||
Gold | Chugai Mining | JAPAN | In Communication | |||
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | In Communication | |||
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | In Communication | |||
Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | In Communication | |||
Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF | In Communication | |||
Gold | Caridad | MEXICO | In Communication | |||
Gold | Morris and Watson | NEW ZEALAND | In Communication | |||
Tin | Estanho de Rondônia S.A. | BRAZIL | In Communication | |||
Tin | Gejiu Zi-Li | CHINA | In Communication | |||
Tin | Linwu Xianggui Smelter Co | CHINA | In Communication | |||
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | In Communication | |||
Tungsten | Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. | CHINA | In Communication | |||
Gold | Anhui Tongling Nonferrous Metal Mining Co., Ltd. | CHINA | Outreach Required | |||
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Outreach Required | |||
Gold | Great Wall Precious Metals Co,. LTD. | CHINA | Outreach Required | |||
Gold | Guangdong Jinding Gold Limited | CHINA | Outreach Required | |||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Outreach Required | |||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Outreach Required | |||
Gold | Lingbao Gold Company Limited | CHINA | Outreach Required | |||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Outreach Required | |||
Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | CHINA | Outreach Required |
Enphase Energy, Inc. 2015 Conflict Minerals Report | 14 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Outreach Required | |||
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Outreach Required | |||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Outreach Required | |||
Gold | L azurde Company For Jewelry | SAUDI ARABIA | Outreach Required | |||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Outreach Required | |||
Gold | Sabin Metal Corp. | UNITED STATES | Outreach Required | |||
Gold | So Accurate Group, Inc. | UNITED STATES | Outreach Required | |||
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Outreach Required | |||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Outreach Required | |||
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Outreach Required | |||
Tin | PT Alam Lestari Kencana | 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 Pelat Timah Nusantara Tbk | INDONESIA | Outreach Required | |||
Tin | PT Seirama Tin Investment | INDONESIA | Outreach Required | |||
Tin | PT Tirus Putra Mandiri | INDONESIA | Outreach Required |
Enphase Energy, Inc. 2015 Conflict Minerals Report | 15 |