0001628280-15-004331.txt : 20150520 0001628280-15-004331.hdr.sgml : 20150520 20150519174455 ACCESSION NUMBER: 0001628280-15-004331 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20141231 1.02 20141231 FILED AS OF DATE: 20150520 DATE AS OF CHANGE: 20150519 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Super Micro Computer, Inc. CENTRAL INDEX KEY: 0001375365 STANDARD INDUSTRIAL CLASSIFICATION: ELECTRONIC COMPUTERS [3571] IRS NUMBER: 770353939 STATE OF INCORPORATION: CA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-33383 FILM NUMBER: 15877575 BUSINESS ADDRESS: STREET 1: 980 ROCK AVENUE CITY: SAN JOSE STATE: CA ZIP: 95131 BUSINESS PHONE: 408-503-8000 MAIL ADDRESS: STREET 1: 980 ROCK AVENUE CITY: SAN JOSE STATE: CA ZIP: 95131 SD 1 formsd-2014.htm FORM SD Form SD - 2014





UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
 

FORM SD
Specialized Disclosure Report
 

SUPER MICRO COMPUTER, INC.
(Exact name of registrant specified in its charter)
 



 
 
 
 
 
Delaware
 
001-33383
 
77-0353939
(State or other jurisdiction
of incorporation)
 
(Commission File Number)
 
(I.R.S. Employer
Identification No.)
980 Rock Avenue, San Jose, California
 
95131
(Address of principal executive offices)
 
(Zip Code)

Howard Hideshima, telephone: (408) 546-8288
(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 Conflict Minerals Disclosure and Report

Reasonable Country of Origin Inquiry:

Brief description of inquiry:

To satisfy the reasonable country of origin inquiry ("RCOI") requirement of the Conflict Minerals Rule adopted by the SEC under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), Super Micro Computer, Inc. ("Supermicro" or "we") has, in good faith, surveyed its suppliers using the Electronic Industry Citizen Coalition ("EICC") and the Global e-Sustainability Initiative ("GeSI") Conflict Minerals Reporting Template. The scope of the survey was to determine whether any of the conflict minerals (defined in Section 1502(e)(4) of the Act to include columbite-tantatlite, cassiterite, wolframite and gold) that are not from recycled or scrap sources originated in the Covered Countries, which include the Democratic Republic of the Congo (the “DRC”) or an adjoining country as defined in Section 1502(e)(1) of the Act. Such inquiry included an understanding of our products for which conflict minerals are necessary to the functionality or production of such products. As part of the RCOI process, we performed a scoping exercise to understand our supply chain including the relevant supplier and sub-supplier population and the products or components procured from such suppliers. We adopted a framework for evaluating responses from suppliers and identifying potential red flags in suppliers’ responses. We have also adopted a company level policy on conflict minerals which has been published on our website. An analysis of our products was performed on the basis of which we concluded that they each contain one or more of the conflict minerals, which are necessary to their functionality or production. Therefore, the products that we manufacture or contract to manufacture are subject to the reporting obligations of Rule 13p-1 under the Securities Exchange Act of 1934.

Based on the approach described above, we believe that we have conducted a good faith reasonable country of origin inquiry for the calendar year ended December 31, 2014. We have documented the performance of the RCOI and our analysis of the supplier responses and the scoping of our products and suppliers for our internal record keeping purposes.

Results of inquiry:

As of the date of this filing, based on the RCOI responses and an analysis of such responses, as it applies to the calendar year ended December 31, 2014, we cannot ascertain the source mine and country of origin of all of the relevant conflict minerals which are necessary to the functionality or production of our products. Therefore, we proceeded with additional due diligence measures for the purpose of determining the source and chain of custody of such conflict minerals.

Exercise Due Diligence on the Source and Chain of Custody of Our Conflict Minerals:

We are required to exercise due diligence on the conflict minerals' source and chain of custody and to follow a nationally or internationally recognized due diligence framework. Our due diligence measures have been designed to conform, in all material respects, with the framework in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas (the "OECD Guidance"). We have adopted and communicated our conflict mineral policy to our suppliers and customers and implemented RCOI procedures to collect additional information from our new and existing suppliers. In addition, we have established programs to encourage our suppliers to source their conflict minerals from certified conflict-free smelters.

This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available at http://ir.supermicro.com/sec.cfm.

Item 1.02 Exhibit

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

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report:
Exhibit 1.01 -- Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.








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.
 
SUPER MICRO COMPUTER, INC.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
By:
 
/s/ Howard Hideshima
 
 
 
Date: May 19, 2015
 
 
Senior VP and Chief Financial Officer
 
 
 
 







EXHIBIT INDEX
 

 
 
 
Exhibit
Number
 
Description
 
 
1.01
 
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.





EX-1.01 2 conflictmineralreport-2014.htm EXHIBIT 1.01 conflictmineralreport-2014

Exhibit 1.01

Super Micro Computer, Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2014


Introduction

This report for the year ended December 31, 2014 has been prepared pursuant to Rule 13p-1 and the Specialized Disclosure Report on Form SD ("Form SD") under the Securities Exchange Act of 1934 (collectively, the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "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 (the "Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG").

If a registrant determines that conflict minerals are necessary to the functionality or production of products manufactured or contracted by the registrant to be manufactured, the registrant must submit a Form SD which describes the reasonable country of origin inquiry (“RCOI”) that it undertook to determine whether such necessary conflict minerals originated from the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”).

If, on the basis of its RCOI, a registrant knows or has reason to believe that any of the necessary conflict minerals in its supply chain may have originated in any of the Covered Countries, or if it is unable to determine the country of origin of those conflict minerals, the issuer must exercise due diligence on the conflict minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.

This report has been prepared by Super Micro Computer, Inc. (herein referred to as “Super Micro” the “Company,” “we,” “us,” or “our”). The information contained in this report includes the activities of all of the Company's majority-owned subsidiaries and variable interest entities that are required to be consolidated.

Company Overview

We are a global leader in high-performance, high-efficiency server technology and innovation. We develop and provide end-to-end green computing solutions to the Data Center, Cloud Computing, Enterprise IT, Big Data, HPC and Embedded markets. Our solutions range from complete server, storage, blade and workstations to full racks, networking devices, server management software and technology support and services.

We conduct our operations principally from our headquarters in California and facilities of our subsidiaries in Taiwan, the Netherlands and China. We sell our server systems and subsystems and accessories primarily through distributors and OEMs, as well as through our direct sales force.

Conflict Minerals Policy

We are committed to complying with Section 1502 of the Dodd-Frank Act and achieving the goal of confirming that the materials used in our products are procured from conflict-free sources. We have considered the Rule’s requirements and related guidance from the Organisation for Economic Cooperation and Development (the “OECD”), and we expect our suppliers to comply with the Code of Conduct of the Electronics Industry Citizenship Coalition (the “EICC”) and conduct their business in accordance with our supply chain responsibility expectations.

In support of this policy, we will:

Exercise due diligence with suppliers of products containing or suspected to contain conflict minerals consistent with the OECD's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 2nd Edition and the related supplements on gold, tin, tantalum and tungsten, (the “OECD Guidance”) and encourage our suppliers to do likewise with their suppliers;

Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm that the tantalum, tin, tungsten and gold in our supply chain are procured from conflict free sources; and


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Collaborate with our suppliers and others on industry-wide solutions to encourage the manufacture of products that are DRC conflict free.

The full text of our Conflict Minerals Policy is available at http://www.supermicro.com/about/policies/Supermicro_Conflict_Minerals_Statement.pdf.

Efforts to Determine the Mine or Location of Origin of the Conflict Minerals in Our Products

Tracing materials back to their mine and source country of origin is a complex endeavor, but an important aspect of responsible sourcing. To help establish our supply chain sourcing programs, we have followed currently established industry guidelines, such as those developed by the EICC and the Global e-Sustainability Initiative ("GeSI"), which are taking action to address responsible sourcing through the development of the Conflict-Free Smelter ("CFS") program that enables companies to source minerals from conflict-free sources. The data on which we relied to determine the country of origin of the minerals was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report for member SMCI.

Facilities Used to Process the Conflict Minerals in Our Products

We procure server components from the following four major types of suppliers:

Manufacturers or direct suppliers;

Contract manufacturers producing items to match specifications and standards set by us;

Distributors or resellers of manufactured components for other manufacturers; and

Customers providing us certain parts and materials to be used to fulfill their orders.

Based on representations from these suppliers, we have determined that they obtain conflict minerals used in our products from the following types of processing facilities:
 
Tin, Tungsten, Tantalum - From smelters which procure the relevant ore and then pass it through smelting and/ or refining, as applicable.

Gold - From smelters/ refiners which either obtain gold from the mines or through recycling.
    

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The table below lists the facilities which, to the extent known, were identified by our supply chain as conflict free smelters as defined by the EICC and GeSI Conflict-Free Sourcing Initiative ("CFSI").
Metal
Smelter
Gold
Aida Chemical Industries Co., Ltd.
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Gold
AngloGold Ashanti Córrego do Sítio Minerção
Gold
Argor-Heraeus SA
Gold
Asahi Pretec Corporation
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
Boliden AB
Gold
C. Hafner GmbH + Co. KG
Gold
CCR Refinery - Glencore Canada Corporation
Gold
Chimet S.p.A.
Gold
Dowa
Gold
Eco-System Recycling Co., Ltd.
Gold
Heimerle + Meule GmbH
Gold
Heraeus Ltd. Hong Kong
Gold
Heraeus Precious Metals GmbH & Co. KG
Gold
Ishifuku Metal Industry Co., Ltd.
Gold
Istanbul Gold Refinery
Gold
Japan Mint
Gold
Johnson Matthey Inc.
Gold
Johnson Matthey Limited
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
JSC Uralectromed
Gold
JX Nippon Mining & Metals Co., Ltd.
Gold
Kazzinc
Gold
Kennecott Utah Copper LLC
Gold
Kojima Chemicals Co., Ltd.
Gold
L'azurde Company For Jewelry
Gold
LS-NIKKO Copper Inc.
Gold
Materion
Gold
Matsuda Sangyo Co., Ltd.
Gold
Metalor Technologies (Hong Kong) Ltd.
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Gold
Metalor Technologies SA
Gold
Metalor USA Refining Corporation
Gold
Metalurgica Met-Mex Penoles, S.A. De C.V.
Gold
Mitsubishi Materials Corporation
Gold
Mitsui Mining and Smelting Co., Ltd.
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Gold
Nihon Material Co., Ltd.
Gold
Ohio Precious Metals, LLC
Gold
Ohura Precious Metal Industry Co., Ltd.
Gold
OJSC Krasnoyarsk
Gold
PAMP SA
Gold
Western Australian Mint trading as The Perth Mint

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Gold
PT Aneka Tambang (Persero) Tbk
Gold
PX Précinox SA
Gold
Rand Refinery (Pty) Ltd.
Gold
Royal Canadian Mint
Gold
Schone Edelmetaal B.V.
Gold
SEMPSA Joyería Platería SA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold
Solar Applied Materials Technology Corp.
Gold
Sumitomo Metal Mining Co., Ltd.
Gold
Tanaka Kikinzoku Kogyo K.K.
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
Gold
Tokuriki Honten Co., Ltd.
Gold
Umicore Brasil Ltda.
Gold
Umicore Precious Metals Thailand
Gold
Umicore SA Business Unit Precious Metals Refining
Gold
United Precious Metal Refining, Inc.
Gold
Valcambi SA
Gold
Yamamoto Precious Metal Co., Ltd.
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
Tantalum
Conghua Tantalum and Niobium Smeltry
Tantalum
Duoluoshan
Tantalum
Exotech Inc.
Tantalum
F&X Electro-Materials Limited
Tantalum
Global Advanced Metals Aizu
Tantalum
Global Advanced Metals Boyertown
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
Tantalum
H.C. Starck Co., Ltd.
Tantalum
H.C. Starck GmbH Goslar
Tantalum
H.C. Starck GmbH Laufenburg
Tantalum
H.C. Starck Hermsdorf GmbH
Tantalum
H.C. Starck Inc.
Tantalum
H.C. Starck Ltd.
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum
Hi-Temp Speciality Metals, Inc.
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum
Jiujiang Tanbre Co., Ltd.
Tantalum
KEMET Blue Metals
Tantalum
KEMET Blue Powder
Tantalum
King-Tan Tantalum Industry Ltd.
Tantalum
LSM Brasil S.A.
Tantalum
Metallurgical Products India Pvt., Ltd.
Tantalum
Mineração Taboca S.A.
Tantalum
Mitsui Mining & Smelting
Tantalum
Molycorp Silmet A.S.
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.

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Tantalum
Plansee SE Liezen
Tantalum
Plansee SE Reutte
Tantalum
QuantumClean
Tantalum
RFH Tantalum Smeltry Co., Ltd.
Tantalum
Solikamsk Magnesium Works OAO
Tantalum
Taki Chemicals
Tantalum
Telex Metals
Tantalum
Ulba Metallurgical Plant JSC
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
Tantalum
Zhuzhou Cement Carbide
Tin
Alpha
Tin
CV United Smelting
Tin
Dowa
Tin
EM Vinto
Tin
Magnu's Minerais Metais e Ligas Ltda.
Tin
Malaysia Smelting Corporation (MSC)
Tin
Melt Metais e Ligas S/A
Tin
Metallo-Chemique N.V.
Tin
Mineração Taboca S.A.
Tin
Minsur
Tin
Mitsubishi Materials Corporation
Tin
PT Artha Cipta Langgeng
Tin
PT ATD Makmur Mandiri Jaya
Tin
PT Babel Inti Perkasa
Tin
PT Bangka Putra Karya
Tin
PT Bangka Tin Industry
Tin
PT Belitung Industri Sejahtera
Tin
PT Bukit Timah
Tin
PT DS Jaya Abadi
Tin
PT Eunindo Usaha Mandiri
Tin
PT Mitra Stania Prima
Tin
PT Panca Mega Persada
Tin
PT Prima Timah Utama
Tin
PT Refined Bangka Tin
Tin
PT Sariwiguna Binasentosa
Tin
PT Stanindo Inti Perkasa
Tin
PT Timah (Persero) Tbk Mentok
Tin
PT Tinindo Inter Nusa
Tin
PT Wahana Perkit Jaya
Tin
Thaisarco
Tin
White Solder Metalurgia e Mineração Ltda.
Tin
Yunnan Tin Group (Holding) Company Limited
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.

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Tungsten
Global Tungsten & Powders Corp.
Tungsten
Hunan Chunchang Nonferrous Metals Metals Co., Ltd.
Tungsten
Japan New Metals Co., Ltd.
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
Tungsten
Wolfram Bergbau und Hütten AG
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
Xiamen Tungsten Co., Ltd.

Countries of origin of the conflict minerals these facilities process are believed to include: Angola, Argentina, Australia, Austria, Belgium, Brazil, Burundi, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, The Democratic Republic of Congo, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Congo, Republic of Korea, Republic of Namibia, Russian Federation, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Switzerland, Taiwan, United Kingdom of Great Britain and Northern Ireland, Tanzania, Uganda, United States of America, Vietnam, Zambia and Zimbabwe.

Exercise Due Diligence on the Source and Chain of Custody of Our Conflict Minerals Following Recognized Framework:

Due Diligence Framework

We have exercised due diligence on the source and chain of custody of the necessary conflict minerals used in our products to identify minerals originating from the Covered Countries that are not from scrap or recycled sources. The due diligence processes and efforts have been developed based on the five-step framework proposed by the OECD Guidance and the related supplements for gold, tin, tantalum and tungsten.

Our conflict minerals due diligence process includes:

Establishment of strong company management systems;

Identify and assess risks in the supply chain;

Design and implement a strategy to respond to identified risks;

Carry out independent third-party audit of smelter/refiner’s due diligence practices; and

Report annually on supply chain due diligence.

Inherent Limitations on Due Diligence Measures
 
As a downstream purchaser of conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information, as well as our smelters, may yield inaccurate or incomplete information and may be subject to fraud.

Brief Description of Due Diligence Measures Taken

1.0Establishment of Strong Company Management Systems:

We have established a management system for complying with applicable conflict minerals reporting and disclosure rules. Our management system includes the development of a Conflict Minerals Oversight Committee led by our Senior VP of Operations, Senior VP and Chief Financial Officer and General Counsel, and a team of subject matter experts from relevant functions such as purchasing, quality compliance, finance, and legal. The team of subject matter experts is responsible for

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implementing our conflict mineral compliance policy and strategy. The Oversight Committee is briefed periodically about the results of our due diligence efforts and reports periodically to the Audit Committee of our Board of Directors. We have provided training to all compliance team members. We have also engaged with our suppliers to enable them to train their employees regarding conflict minerals compliance and reporting processes and our policies.

2.0Identification and Assessment of Risks in the Supply Chain:

We have made reasonable efforts to identify suppliers that supply products that may potentially contain conflict minerals by conducting a supply chain survey using the EICC and GeSI Conflict Minerals Reporting Template; requesting our direct suppliers to identify smelters and refiners and countries of origin of the conflict minerals in products they supply to us; following up with direct suppliers that do not respond to the Conflict Minerals Reporting Template by requesting their responses; comparing smelters and refiners identified by our supply chain survey against the list of facilities that have received a “conflict-free” designation from the CFS Program, which designations provide country of origin; and maintaining documentation of reasonable efforts we have made to identify and assess supply chain risks. We have also reviewed the responses to identify potential red flags for further follow-up.

3.0Strategic Response to Identified Risks:

We have implemented a risk mitigation response plan to monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements. We will continuously make reasonable efforts to encourage suppliers who are sourcing from non-conflict-free smelters to move towards the use of conflict-free smelters. If a supplier fails to remedy the risks identified by our compliance risk assessment, we will escalate the matter to the Conflict Minerals Oversight Committee to determine whether to approve or reject the supplier based on the following factors: a cost and benefit analysis; evaluation of potential risk factors; any existing competitive bids; and whether the supplier is a single source supplier to the Company. If the Oversight Committee decides to continue a business relationship with a non-compliant supplier due to inherent limitations of our supply chain, we will use reasonable efforts to follow up with the supplier for its correction plan, and encourage the supplier to work with smelters that are certified through CFSI's CFS program. We also provide periodic compliance updates or reports to our Conflict Minerals Oversight Committee summarizing our risk mitigation efforts.

4.0Independent 3rd Party Audit of Smelter/Refiner’s Due Diligence Practices:

We do not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain the 3TG. However, we do rely upon industry efforts, including EICC and CFSI, to influence smelters and refiners to get audited and certified through CFSI’s CFS program.

5.0Annual report on Supply Chain Due Diligence:

In addition to this report, for further information about our Conflict Minerals policy, please see it at http://www.supermicro.com/about/policies/Supermicro_Conflict_Minerals_Statement.pdf.

Results of Due Diligence Measures Taken

Due to the level of complexity of our products and the respective supply chain, it will take additional time and resources for a number of our suppliers to verify the source mines and country of origin of all of the minerals used by their smelters. We are committed to continuing the use of our supply chain due diligence processes, leveraging the industry standard CFS program, and the ongoing update of our supplier RCOI information as we continue to develop additional transparency into our supply chain. However, as of the date of this filing, based on the performance of our due diligence procedures described above for the calendar year ended December 31, 2014, we are not able to accurately trace and identify the source mine, country of origin and chain of custody of the 3TG metals, which are necessary to the functionality or production of our products, or determine whether such 3TG metals, are procured from conflict free sources.







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