0000031347-14-000023.txt : 20140530 0000031347-14-000023.hdr.sgml : 20140530 20140530131649 ACCESSION NUMBER: 0000031347-14-000023 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20131231 1.02 20131231 FILED AS OF DATE: 20140530 DATE AS OF CHANGE: 20140530 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ECHELON CORP CENTRAL INDEX KEY: 0000031347 STANDARD INDUSTRIAL CLASSIFICATION: COMPUTER COMMUNICATIONS EQUIPMENT [3576] IRS NUMBER: 770203595 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-29748 FILM NUMBER: 14878914 BUSINESS ADDRESS: STREET 1: 550 MERIDIAN AVENUE CITY: SAN JOSE STATE: CA ZIP: 95126 BUSINESS PHONE: 4089385200 MAIL ADDRESS: STREET 1: 550 MERIDIAN AVENUE CITY: SAN JOSE STATE: CA ZIP: 95126 SD 1 formsd-conflictmineralsdis.htm FORM SD FORM SD- Conflict Minerals Disclosure 2013


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
 
SPECIALIZED DISCLOSURE REPORT

 
ECHELON CORPORATION
(Exact name of registrant as specified in its charter)
 
 
 
 
 
 
 
 
 
 
 
 
Delaware
 
000-29748
 
77-0203595
(State or other jurisdiction
of incorporation)
 
(Commission
File Number)
 
(IRS Employer
Identification No.)

550 Meridian Avenue, San Jose, California
 
95126
(Address of principal executive offices)
 
(Zip code)
 
 
 
 
 
(408) 938-5200
(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:
þ
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013


1



Section 1 - Conflict Minerals Disclosure
Item 1.01
Conflict Minerals Disclosure and Report

With respect to the reporting period from January 1, 2013 to December 31, 2013, Echelon Corporation (the “Company”) has determined that (i) “conflict minerals” (as defined in Section 1, Item 1.01(d)(3) of Form SD) are necessary to the functionality or production of products that the Company has manufactured and contracted to manufacture, and (ii) based upon a reasonable country of origin inquiry, the Company is unable to determine whether and if so, the extent to which any of its necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo or an adjoining country (as defined in Section 1, Item 1.01(d)(1) of Form SD) or from recycled or scrap sources.

In accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”), and this Specialized Disclosure Report on Form SD (this “Form”), the Company has filed a Conflict Minerals Report, which is attached as Exhibit 1.02 to this Form. A copy of this Form and the Conflict Minerals Report are publicly available at http://www.echelon.com/company/investor/corpgov/

Item 1.02
Exhibit

In accordance with Rule 13p-1, and this Form SD, the Company has filed a Conflict Minerals Report, which is attached as Exhibit 1.02 to this Form.

Section 2- Exhibits

Item 2.01
Exhibits

Exhibit No.
 
Description
Exhibit 1.02
 
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

2



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.
 
 
 
 
 
 
 
ECHELON CORPORATION
 
 
 
 
 
 
 
 
By:
 
/s/ William R. Slakey
 
 
 
 
 
 
William R. Slakey
Executive Vice President and
Chief Financial Officer
 
 
 
 
Date: May 30, 2014
 
 
 
 
 
 

3



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


4
EX-1.02 2 exhibit102.htm EXHIBIT Exhibit 1.02


Exhibit 1.02


Echelon Corporation
Conflict Minerals Report
For The Year Ended December 31, 2013

This Conflict Minerals Report (this “Report”) for Echelon Corporation (the “Company”, “Echelon”, “our” or “we”) covers the reporting period from January 1, 2013 to December 31, 2013, and is presented in accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”).

This Report is filed as Exhibit 1.02 to the Company’s Specialized Disclosure Report on Form SD (the “Form”), and a copy of this Report and the Form are publicly available at http://www.echelon.com/company/investor/corpgov/

We use the term “conflict free” in this Report in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries. For purposes of this Report, the term “conflict minerals” means columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. Numerous terms in this Report are defined in the Rule and the reader is referred to that source and to SEC Release No. 34-67716 issued by the Securities and Exchange Commission on August 22, 2012 for such definitions.

Introduction
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Pursuant to Section 1502 of the Act, the United States Securities and Exchange Commission (“SEC”) promulgated regulations requiring companies covered under the Act annually to file a Specialized Disclosure Report on Form SD with the SEC to disclose whether certain specified conflict minerals (as described below) used in their products directly or indirectly benefited armed groups in the Democratic Republic of the Congo and adjoining countries (collectively, the “Covered Countries”). This Report, which is an exhibit to the Form, describes the design of Echelon’s conflict minerals due diligence measures and provides an account of how these measures were implemented in 2013 to determine, to our knowledge, the source mines, the country of origin and the facilities used to process the conflict minerals used in our products. A description of our products covered by this Report is described under “Part 2: Product Determination” of this Report below.

Part 1: Due Diligence

Reasonable Country of Origin Inquiry Process
In accordance with Rule 13p-1 and Form SD, Echelon determined that conflict minerals are necessary to the functionality or production of our products, and undertook a reasonable country of origin inquiry (“RCOI”) with respect conflict minerals reasonably designed to determine whether any of the conflict minerals originated in the Covered Countries.

Due Diligence Process
In conducting our RCOI, Echelon employed a combination of measures to determine whether the conflict minerals in our products originated from the Covered Countries, and determined that the Company would survey direct suppliers that represented an aggregate of at least 95% of sales revenue generated from our products that contain or may be manufactured using conflict minerals. Echelon employed the Electronics Industry Citizenship Coalition (“EICC”) - Global eSustainability Initiative (“GeSI”) Extractives industry tools to collect due diligence information on the source and chain of custody of conflict minerals.

To maximize the efficiency and effectiveness of our efforts to identify smelters and refiners in our supply chain ,as a standardized protocol, we, along with other participants in the electronics industry, rely on the Conflict-Free Sourcing Initiative (CFSI)’s Conflict-Free Smelter Program (“CFSP”) or equivalent industry-wide program for audits of smelters and/or refiners. The CFSP is a voluntary initiative in which an independent third party audits smelter procurement and processing activities and determines if the smelter has provided sufficient documentation to demonstrate with reasonable confidence that the minerals it processed originated from conflict-free sources.

In addition, we designed our due diligence to conform, in all relevant material respects given our position in the supply chain, to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Framework”) as it pertains to downstream companies. We believe the Framework is an internationally recognized due diligence framework and meets the requirements of the Rule.


1



Establishment of a Management System.

Echelon established a management system for addressing the sourcing of conflict minerals in our products, and implemented a conflict minerals governance structure that includes executive sponsors and a cross-functional team comprised of individuals from Operations, Finance, Accounting, Sales and Legal.

A copy of Echelon’s Supply Chain Policy for Conflict Minerals can be viewed at http://www.echelon.com/company/investor/docs/ech_corpgov_conflictmineralspolicy.pdf. Echelon has a worldwide whistleblower policy and hotline, and we accept and encourage reporting of illegal or unethical activity. We believe that our whistleblower hotline is an appropriate mechanism for our employees and employees of our suppliers to report known or suspected false information concerning conflict minerals in our supply chain.

Identification and Assessment of Risks in the Supply Chain
In 2013, Echelon selected and surveyed five first-tier direct suppliers, representing an aggregate of over 95% of our sales revenue generated from products containing or produced using conflict minerals. Echelon provided the Conflict Minerals Reporting Template (the “CMRT”) designed by the CFSI to all such suppliers in order to gather information about their use of conflict minerals, their mineral sourcing practices and the smelters and refiners in their supply chain. We elected to use the CMRT as we believe that it is a commonly used reporting template used in numerous industries, thereby easing the potential for confusion or misunderstanding by our suppliers and helping to foster even more widespread adoption of the CMRT.

Given our position in the supply chain, we relied heavily on our first-tier suppliers to provide information about the sources of conflict minerals used in our products. Upon receipt of responses to our CMRT request, we reviewed supplier responses for completeness, reasonableness, and acceptability in order to validate the smelters and refiners listed on the provided CMRTs.

Based on the data collected, the main risks that we have identified are suppliers providing incomplete or inconsistent responses in the CMRT, and suppliers providing the names of smelters or refiners that are unrecognized by the CFSI or not certified by the CFSP. As of the date of this Report, we have not identified a supplier, smelter or refiner which we have reason to believe may be sourcing conflict minerals from a Covered Country that, directly or indirectly, finances or benefits armed groups, but given the uncertainty in the provenance of materials from a variety of smelters that may be present in materials used by our suppliers, we are unable to determine with certainty whether or not any minerals used in our products are so sourced.

Conducting Independent Audits of Supply Chain Due Diligence
Echelon does not have a direct relationship with any smelters or refiners in our supply chain and, as a result, we do not directly conduct audits. Instead, Echelon identified conflict-free smelters and refiners reported from our first-tier direct suppliers by confirming with the published list from third party audits (the CFSP).

Part 2: Product Determination
Products
During the reporting period from January 1, 2013 to December 31, 2013, we identified the following products that may contain conflict minerals that Echelon contracted to manufacture:

Integrated Circuit (IC) and Module Products
Meter Products
Control Nodes
Tools
Interconnectivity Products

DRC Conflict Status
In 2013 and 2014, we conducted the due diligence process described above for the reporting period from January 1, 2013 to December 31, 2013 in order to ascertain source and chain of custody information for the necessary conflict minerals in our supply chain. Based on the subsequent information we gathered, Echelon has determined that (i) certain smelters and refiners in the supply chain that are sources of the necessary conflict minerals for our products have received a “conflict free” designation from the CFSP or other third party audit program, and (ii) we are unable to determine the country of origin of conflict minerals and or chain of custody of all necessary conflict minerals procured by all smelters in our supply chain that contributed to our products because, for this reporting period, certain smelter and refiner facilities (1) had not yet received a “conflict free” designation from an independent third party audit program, and (2) did not respond to our requests for country of origin or chain or custody inquiries.

Table 1 below lists the facilities which, to the extent known, processed the necessary conflict minerals in our products:

2





Metal
Smelter Names
Country
Gold
Allgemeine Gold- und Silberscheideanstalt A.G. *
Germany
Gold
AngloGold Ashanti Mineração Ltda *
Brazil
Gold
Argor-Heraeus SA *
Switzerland
Gold
Asahi Pretec Corp *
Japan
Gold
Chimet SpA *
Italy
Gold
Dowa *
Japan
Gold
Heimerle + Meule GmbH *
Germany
Gold
HERAEUS HONG KONG *
Hong Kong
Gold
Heraeus Precious Metals GmbH & Co. KG *
Germany
Gold
Ishifuku Metal Industry Co., Ltd. *
Japan
Gold
Johnson Matthey Inc *
United States
Gold
Johnson Matthey Limited *
Canada
Gold
JX Nippon Mining & Metals Co., Ltd *
Japan
Gold
Kennecott Utah Copper *
United States
Gold
Kojima Chemicals Co. Ltd *
Japan
Gold
LS-Nikko Copper Inc *
Korea, Republic Of
Gold
Materion *
United States
Gold
Matsuda Sangyo Co. Ltd *
Japan
Gold
Metalor Technologies (Hong Kong) Ltd *
Hong Kong
Gold
Metalor Technologies SA *
Switzerland
Gold
Metalor USA Refining Corporation *
United States
Gold
Mitsubishi Materials Corporation *
Japan
Gold
Mitsui Mining and Smelting Co., Ltd. *
Japan
Gold
Nihon Material Co. LTD *
Japan
Gold
Ohio Precious Metals LLC. *
United States
Gold
PAMP SA *
Switzerland
Gold
Rand Refinery (Pty) Ltd *
South Africa
Gold
Royal Canadian Mint *
Canada
Gold
SEMPSA Joyeria Plateria SA *
Spain
Gold
Solar Applied Materials Technology Corp. *
Taiwan
Gold
Sumitomo Metal Mining Co. Ltd. *
Japan
Gold
Tanaka Kikinzoku Kogyo K.K. *
Japan
Gold
Tokuriki Honten Co. Ltd *
Japan
Gold
Umicore SA Business Unit Precious Metals Refining *
Belgium
Gold
United Precious Metal Refining, Inc. *
United States
Gold
Valcambi SA *
Switzerland
Gold
Western Australian Mint trading as The Perth Mint *
Australia
Gold
AIDA Chemical Industories Co.,Ltd
Japan
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
Gold
Asaka Riken Co Ltd
Japan
Gold
Aurubis AG
Germany
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Gold
Caridad
Mexico
Gold
Chugai Mining
Japan
Gold
Codelco
Chile
Gold
Daejin Indus Co. Ltd
Korea, Republic Of
Gold
DaeryongENC
Korea, Republic Of

3



Gold
Do Sung Corporation
Korea, Republic Of
Gold
Faggi Enrico Spa
Italy
Gold
Harima Smelter
Japan
Gold
Henan Zhongyuan Gold Smelter Co., Ltd.

China
Gold
Heraeus USA
United States
Gold
Hisikari Mine
Japan
Gold
Hwasung CJ Co. Ltd
Korea, Republic Of
Gold
Jiangxi Copper Company Limited
China
Gold
Jinlong Copper Co., Ltd.
China
Gold
Korea Metal
Korea, Republic Of
Gold
LBMA
Japan
Gold
Mitsui & Co. Precious Metals Inc. Hong Kong Branch
Hong Kong
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
Gold
Niihama Nickel Refinery
Japan
Gold
Nippon Mining & Mtetals
Japan
Gold
Orelec
France
Gold
Pan Pacific Copper Co. LTD
Japan
Gold
Sabin Metal Corp.
United States
Gold
Samwon Metals Corp.
Korea, Republic Of
Gold
Senju Metal Industry Co.,Ltd.
Japan
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
China
Gold
So Accurate Refining Group
United States
Gold
The Refinery of Shandong Gold Mining Co. Ltd
China
Gold
Torecom
Korea, Republic Of
Gold
UBS AG
Switzerland
Gold
United Refining
United States
Gold
UYEMURA
United States
Gold
Xstrata Canada Corporation
Canada
Gold
Yamamoto Precious Metal Co., Ltd.
Japan
Gold
Yokohama Metal Co Ltd
Japan
Gold
YOKOHAMA METAL CO.,LTD.
Japan
Gold
Zhaojin Group&Gold Mineral China Co., Ltd.
China
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Gold
Zijin Mining Group Co. Ltd
China
Tantalum
Duoluoshan *
China
Tantalum
Exotech Inc. *
United States
Tantalum
F&X *
China
Tantalum
Global Advanced Metals *
United States
Tantalum
H.C. Starck GmbH *
Germany
Tantalum
Hi-Temp *
United States
Tantalum
JiuJiang JinXin Nonferrous Metals Co. Ltd. *
China
Tantalum
Mitsui Mining & Smelting Co., Ltd *
Japan
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd. *
China
Tantalum
RFH *
China
Tantalum
Solikamsk Metal Works *
Russian Federation
Tantalum
Taki Chemicals *
Japan
Tantalum
Tantalite Resources *
South Africa
Tantalum
Telex *
United States
Tantalum
Ulba *
Kazakhstan
Tantalum
Zhuzhou Cement Carbide *
China

4



Tantalum
CIF
Brazil
Tantalum
Ethiopian Minerals Development Share Company
Ethiopia
Tantalum
Fujian Nanping
China
Tantalum
Jiangxi Yichun
China
Tantalum
Metal Do
Japan
Tantalum
Niotan
United States
Tantalum
NTET, Thailand
Thailand
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd. *
China
Tin
Malaysia Smelting Corporation (MSC) *
Malaysia
Tin
Mineração Taboca S.A. *
Brazil
Tin
Minsur *
Peru
Tin
Mitsubishi Materials Corporation *
Japan
Tin
OMSA *
Bolivia
Tin
PT Bukit Timah *
Indonesia
Tin
PT Tambang Timah *
Indonesia
Tin
PT Timah *
Indonesia
Tin
Thaisarco *
Thailand
Tin
White Solder Metalurgia *
Brazil
Tin
Yunnan Tin Company Limited *
China
Tin
Cookson Electronics - Alpha Metals Korea
Bangka,Indonesia
Tin
Senju Metal
Japan
Tin
Alpha Metals Korea Ltd.
Korea, Republic Of
Tin
Alpha Metals Taiwan
United States
Tin
Amalgamet
United States
Tin
An Xin Xuan Xin Yue You Se Jin Shu Co. Ltd.
China
Tin
Baoshida Swissmetall
Switzerland
Tin
CFC Cooperativa dos Fundidores de Cassiterita da Amazônia Ltda.
Brazil
Tin
China Tin Smelter Co.Ltd
China
Tin
CNMC (Guangxi) PGMA Co. Ltd.
China
Tin
Cooper Santa
Brazil
Tin
Corporation Berhad (MSC)
Malaysia
Tin
CV Duta Putra Bangka
Indonesia
Tin
CV JusTindo
Indonesia
Tin
CV Makmur Jaya
Indonesia
Tin
CV Nurjanah
Indonesia
Tin
CV Serumpun Sebalai
Indonesia
Tin
CV United Smelting
Indonesia
Tin
Electro.oy Metal Pte.
Singapore
Tin
EM Vinto
Bolivia
Tin
Fenix Metals
Poland
Tin
FSE Novosibirsk Refinery
Russian Federation
Tin
Fuji Metal Mining
Thailand
Tin
Gebrueder Kemper GMBH
Germany
Tin
Gejiu Gold Smelter Minerals Co.,Ltd
China
Tin
Gejiu Yunxin Colored Electrolytic Co.,Ltd
China
Tin
Gejiu Zi-Li
China
Tin
Gold Bell Group
China
Tin
Gomat-e-K.
Germany
Tin
GUANGXI CHINA TIN GROUP CO.,LTD
China
Tin
Heraeus Technology Center
Hong Kong

5



Tin
Huichang Jinshunda Tin Co. Ltd
China
Tin
Jean Goldschmidt International
Belgium
Tin
Jiangxi Nanshan
China
Tin
Kai Unita Trade Limited Liability Company
China
Tin
Linwu Xianggui Smelter Co
China
Tin
Liuzhou China Tin
China
Tin
Malaysia Smelting Corp
Malaysia
Tin
Metahub Industries Sdn. Bhd.
Malaysia
Tin
Metallo Chimique
Belgium
Tin
Minmetals Ganzhou Tin Co. Ltd.
China
Tin
Minsur
China
Tin
Mitsubishi Electric Metecs Co., Ltd.
Japan
Tin
Novosibirsk Integrated Tin Works
Russian Federation
Tin
OM Manufacturing Phils. Inc.
Philippines
Tin
PT Alam Lestari Kencana
Indonesia
Tin
PT Artha Cipta Langgeng
Indonesia
Tin
PT Babel Inti Perkasa
Indonesia
Tin
PT Babel Surya Alam Lestari
Indonesia
Tin
PT Bangka Kudai Tin
Indonesia
Tin
PT Bangka Putra Karya
Indonesia
Tin
PT Bangka Timah Utama Sejahtera
Indonesia
Tin
PT Bangka Tin Industry
Indonesia
Tin
PT Belitung Industri Sejahtera
Indonesia
Tin
PT BilliTin Makmur Lestari
Indonesia
Tin
PT DS Jaya Abadi
Indonesia
Tin
PT Eunindo Usaha Mandiri
Indonesia
Tin
PT Fang Di MulTindo
Indonesia
Tin
PT HP Metals Indonesia
Indonesia
Tin
PT Koba Tin
Indonesia
Tin
PT Mitra Stania Prima
Indonesia
Tin
PT Refined Banka Tin
Indonesia
Tin
PT Sariwiguna Binasentosa
Indonesia
Tin
PT Stanindo Inti Perkasa
Indonesia
Tin
PT Sumber Jaya Indah
Indonesia
Tin
PT Timah Nusantara
Indonesia
Tin
PT Tinindo Inter Nusa
Indonesia
Tin
PT Yinchendo Mining Industry
Indonesia
Tin
Pure Technology
Russian Federation
Tin
Richard Stenzhorn GmbH
Germany
Tin
Samhwa non-ferrorus Metal ind.co.ltd
Korea, Republic Of
Tin
Singapore LME Tin
Singapore
Tin
Sundwigger Messingwerk
Germany
Tin
Tamura
Japan
Tin
The Miller Company
United States
Tin
XiHai
China
Tin
Yunnan Chengfeng
China
Tin
Yunnan Chengo Electric Smelting Plant
China
Tin
Yunnan Tin
China
Tin
Yuntinic Chemical GmbH
Germany
Tin
YunXi
China

6



Tungsten
Central Glass @Co.,Ltd Ube, Yamaguchi
Japan
Tungsten
Dayu Weiliang Tungsten Co.,Ltd
China
Tungsten
A.L.M.T. Corp.
Japan
Tungsten
ATI Tungsten Materials
United States
Tungsten
Buffalo Tungsten
China
Tungsten
Chaozhou Xianglu Tungsten Industry Co Ltd
China
Tungsten
China Minmetals Nonferrous Metals Co Ltd
China
Tungsten
China National Non-ferrous
China
Tungsten
Chongyi Zhangyuan Tungsten Co Ltd
China
Tungsten
Ganzhou Grand Sea W & Mo Group Co Ltd
China
Tungsten
Global Tungsten & Powders Corp *
United States
Tungsten
HC Starck
Russian Federation
Tungsten
HC Starck GmbH
Germany
Tungsten
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.
China
Tungsten
Jiangxi Rare Earth & Rare Metals Tungsten Group Corp
China
Tungsten
Jiangxi Tungsten Industry Group Co Ltd
China
Tungsten
Kennametal Inc.
United States
Tungsten
Kyoritsu Gokin Co., Ltd.
Japan
Tungsten
Mitsubishi Materials Corp.
Japan
Tungsten
Mitsui Mining & Smelting Co., Ltd
Japan
Tungsten
Nanchang Cemented Carbide Limited Liability Company
China
Tungsten
North American Tungsten
Canada
Tungsten
Plansee
Austria
Tungsten
Sandvik Material Technology
Sweden
Tungsten
Sumitomo
China
Tungsten
Wolfram Bergbau und Hütten AG
Austria
Tungsten
Wolfram Company CJSC
Russian Federation
Tungsten
Xiamen Golden Egret Special Alloy Co. Ltd.
China
Tungsten
Xiamen Tungsten Co Ltd
China
Tungsten
Zhuzhou Cemented Carbide Group Co Ltd
China
* Denotes smelters and refiners which have received a "conflict free" designation from an independent third party audit as updated by the CFSI after the Reporting Period.

Efforts to Determine Mine Location
Echelon has very limited engagement with the majority of parties beyond our first-tier direct suppliers in our supply chain. Consequently, identifying, with certainty, the smelters, refiners and recyclers and the source of the conflict minerals they process is an extraordinary challenge. In 2013, the primary focus of our due diligence on the source and chain of custody of the necessary conflict minerals in our supply chain was on the collection and assessment of the data gathered, consolidated and provided by our direct first-tier suppliers. As a downstream supplier, we base our due diligence program on current industry guidance and practices for implementing the Framework, Echelon’s primary means of determining mine location is through the CFSP audits, industry lists and reports that we expect to gather through our participation in the various organizations identified above.

Future Steps
We recognize that this is a complicated process given the complexity of our supply chain, and that Echelon has very limited engagement with the majority of our supply chain beyond our first-tier direct suppliers. As a result, in 2014, we expect to continue to focus our efforts on collaborating with our first tier direct suppliers to improve the systems of transparency and control in our supply chain, including through our use of the CMRT in connection with our diligence of our supply chain.


7