UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

Stem, Inc.

(Exact name of registrant as specified in its charter)

Delaware	001-39455
(State or other jurisdiction of incorporation or organization)	(Commission File Number)

100 California St., 14th Floor, San Francisco, California, 94111

(Address of principal executive offices) (zip code)

Saul R. Laureles

Chief Legal Officer and Corporate Secretary

877-374-7836

(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:

☒	Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2023 to December 31, 2023.
☐	Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ______ .

Section 1 — Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit

Conflict Minerals Disclosure

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, Stem, Inc. (the “Company”) has filed this Specialized Disclosure Report and the Conflict Minerals Report attached hereto as Exhibit 1.01 for the year ended December 31, 2023. Both of these documents are publicly available on the investor relations page of the Company’s website at: investors.stem.com.* 

Section 2 — Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

Section 3 – Exhibits

Item 3.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report.

* * * * *

* The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD or the Conflict Minerals Report, nor deemed filed with the Securities and Exchange Commission.

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 duly authorized undersigned.

STEM, INC.

By: /s/ Saul R. Laureles        

Name: Saul R. Laureles

Title: Chief Legal Officer and Corporate Secretary

Date: May 31, 2024