Document
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549
FORM SD
Specialized Disclosure Report
Lattice Semiconductor Corporation
(Exact name of registrant as specified in its charter)
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Delaware | | 000-18032 | | 93-0835214 |
(State or other jurisdiction of incorporation) | | (Commission File Number) | | (IRS Employer Identification No.) |
111 SW Fifth Avenue, Suite 700, Portland, Oregon 97204
(Address of principal executive offices, including zip code)
Byron W. Milstead
Corporate Vice President, General Counsel & Secretary
(503) 268-8000
(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:
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x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016. |
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Lattice Semiconductor Corporation (together with its subsidiaries "Lattice") has evaluated its product lines for the year ending December 31, 2016 and determined that certain products that it contracted to manufacture contain conflict minerals as defined in the 1934 Act Release No. 34-67716.
A copy of Lattice Semiconductor Corporation's Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available at http://www.latticesemi.com/About/CorporateSocialResponsibility
Item 1.02 Exhibit
Lattice Semiconductor Corporation has filed, as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.
Section 2 - Exhibits
Item 2.01 Exhibits
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 duly authorized undersigned.
Lattice Semiconductor Corporation
(Registrant)
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By: | /s/ Byron W. Milstead | Date: May 30, 2017 |
| Byron W. Milstead | |
| Corporate Vice President, General Counsel & Secretary | |
Exhibit
Conflict Minerals Report
This Conflict Minerals Report for Lattice Semiconductor Corporation is prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period that ended December 31, 2016.
Lattice Semiconductor Corporation (collectively with its subsidiaries “Lattice,” “we,” or “our”) designs, develops and markets programmable logic and connectivity solutions. Lattice has adopted a Conflict Minerals Sourcing Policy that expresses our desire to have our products free from conflict minerals sourced from the Democratic Republic of the Congo and its adjoining countries (“Covered Countries”) that finance or benefit armed groups (“DRC Conflict Free”). Conflict minerals are tantalum, tungsten, tin and gold, and their derivatives.
Products and Initiatives
Based on our internal assessment, our semiconductor devices, evaluation boards, and development hardware that we contract to manufacture contain conflict minerals that are necessary to their functionality (the “3TG Products”). In order to achieve a DRC Conflict Free supply chain and to comply with reporting requirements, we established processes designed to determine the source and chain of custody of conflict minerals in the 3TG Products.
Consistent with the OECD Framework, we established a company risk management system that includes a formal Corporate Social Responsibility (“CSR”) initiative. As part of our CSR initiative, we structured our internal processes to support supply chain due diligence by participating in industry-driven programs, including our support and adoption of the Electronic Industry Citizenship Coalition (“EICC”) Code of Conduct. We work closely with our supply chain to identify, assess and respond to risks in our supply chain. We strengthened our engagement with suppliers and adopted our Conflict Minerals Sourcing Policy, which is available on the Corporate Social Responsibility page of our website at http://www.latticesemi.com/About/ CorporateSocialResponsibility.
Diligence on Source and Chain of Custody
We conducted good faith reasonable country of origin inquiries and due diligence to determine whether any conflict minerals in our 3TG Products originated in the Covered Countries. Because we are at least several levels removed from the mining, refining and smelting of conflict minerals, we rely upon certifications from our supply chain concerning the use and source of conflict minerals in our 3TG Products. Our diligence measures can only provide a reasonable assurance regarding the source and chain of custody of conflict minerals in our supply chain.
In order to identify and assess risks in our supply chain, we followed industry standards by requesting all suppliers to identify the processing facilities and other data related to conflict minerals in the 3TG Products using the latest version of the Electronic Industry Citizenship Coalition and Global e-Sustainability (“EICC/GeSI”) Conflict Minerals Reporting Template (the “CMRT”). To bolster our due diligence efforts, we engaged a third party service provider to assist with gathering CMRTs and analyzing our supply chain. We surveyed our suppliers regarding their sourcing of conflict minerals, the smelters in their supply chain, their conflict minerals policy and due diligence process. If a supplier did not respond to our request or provided an insufficient response, we engaged in further discussions with that supplier until we received the requested information. Our policy is to disengage with any supplier where we are concerned about conflict minerals sourced from the Covered Countries that finance or benefit armed groups, which may include suppliers from whom we did not receive a sufficient response after multiple inquiries. In 2016, over 99% of our product related revenues originated from semiconductor devices, and 100% of our suppliers of semiconductor devices provided sufficient responses to our request. Of the remaining 1% of suppliers, approximately 92% provided sufficient responses to our request. We are working with our remaining suppliers to ensure we receive an adequate response for future reporting periods or we will consider taking action to disengage from that supplier.
In order to determine the source and chain of custody of any conflict minerals in our supply chain, we communicated with the relevant suppliers in our supply chain, compiled, validated and analyzed the CMRT results, attempted to confirm reported results where appropriate, identified possible risks in our supply chain, worked with our suppliers to mitigate those risks, and identified smelters and refiners certified by the internationally-recognized Conflict Free Sourcing Initiative (CFSI) Conflict-Free Smelter Program (“CFSP”). The CFSP identifies smelters as either Active, Compliant, or Eligible.
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• | Active smelters have committed to undergo a CFSI third party validation audit and are progressing toward a DRC Conflict Free designation. |
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• | Compliant smelters have been certified DRC Conflict Free. |
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• | Eligible smelters are smelters that have been identified by CFSP but have not yet committed to undergo a validation audit. |
These CFSP designations are an integral part of our risk management process because they provide us with independent third-party audits verifying processing facilities that source DRC Conflict Free. The results of our supply chain due diligence are reported regularly to Lattice management.
Due Diligence Results
As a result of our due diligence, we identified 134 smelters and refiners as potential sources of conflict minerals in our supply chain. Of those smelters identified, 133 are CFSP Compliant and certified to be DRC Conflict Free as of May 8, 2017. The remaining smelter is Active as defined by CFSP.
Appendix I lists the country of origin and the facilities believed to process the conflict minerals contained in Lattice’s 3TG Products. Detailed smelter and refiner information is contained within our CMRT, which is available on our website at http://www.latticesemi.com/en/About/Corporate Social Responsibility.
Future Diligence Efforts
For the reporting period ending December 31, 2017, we continue to engage in the due diligence activities described in this report for all 3TG Products. We intend to further engage with our supply chain to ensure the upstream smelters and refiners that are not yet certified are progressing toward CFSP validation as Compliant and DRC Conflict Free smelters.
This Conflict Minerals Report was not subject to an independent private sector audit.
Appendix I
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Mineral | Smelter | Location of Facility |
Gold | Aida Chemical Industries Co., Ltd. | Japan |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil |
Gold | Argor-Heraeus S.A. | Switzerland |
Gold | Asahi Pretec Corp. | Japan |
Gold | Asaka Riken Co., Ltd. | Japan |
Gold | Aurubis AG | Germany |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
Gold | Boliden AB | Sweden |
Gold | C. Hafner GmbH + Co. KG | Germany |
Gold | CCR Refinery - Glencore Canada Corporation | Canada |
Gold | Chimet S.p.A. | Italy |
Gold | Heimerle + Meule GmbH | Germany |
Gold | Istanbul Gold Refinery | Turkey |
Gold | Jiangxi Copper Co., Ltd. | China |
Gold | Asahi Refining Canada Ltd. | Canada |
Gold | Dowa | Japan |
Gold | Eco-System Recycling Co., Ltd. | Japan |
Gold | Heraeus Ltd. Hong Kong | China |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
Gold | Asahi Refining USA Inc. | United States |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
Gold | Kennecott Utah Copper LLC | 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. | China |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
Gold | Metalor Technologies S.A. | Switzerland |
Gold | Metalor USA Refining Corporation | United States |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | Mexico |
Gold | Mitsubishi Materials Corporation | Japan |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey |
Gold | Nihon Material Co., Ltd. | Japan |
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
Gold | PAMP SA | Switzerland |
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
Gold | PX Précinox S.A. | Switzerland |
Gold | Rand Refinery (Pty) Ltd. | South Africa |
Gold | Royal Canadian Mint | Canada |
Gold | SEMPSA Joyería Platería SA | Spain |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russia |
Gold | Solar Applied Materials Technology Corp. | Taiwan |
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Mineral | Smelter | Location of Facility |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
Gold | Tokuriki Honten Co., Ltd. | Japan |
Gold | Umicore Brasil Ltda. | Brazil |
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 | Yamamoto Precious Metal Co., Ltd. | Japan |
Gold | Yokohama Metal Co., Ltd. | Japan |
Gold | Zhongyuan Gold Smelter Of Zhongjin Gold Corporation | China |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China |
Gold | Umicore Precious Metals Thailand | Thailand |
Gold | Republic Metals Corporation | United States |
Tantalum | F&X Electro-Materials Ltd. | China |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
Tantalum | Solikamsk Magnesium Works OAO | Russia |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
Tantalum | H.C. Starck Co., Ltd. | Thailand |
Tantalum | H.C. Starck GmbH Goslar | Germany |
Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
Tantalum | H.C. Starck Inc. | United States |
Tantalum | H.C. Starck Ltd. | Japan |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
Tantalum | Global Advanced Metals Boyertown | United States |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China |
Tin | Alpha | United States |
Tin | Cooperativa Metalurgica De Rondônia Ltda. | Brazil |
Tin | CV Gita Pesona | Indonesia |
Tin | PT Aries Kencana Sejahtera | Indonesia |
Tin | CV Serumpun Sebalai | Indonesia |
Tin | CV United Smelting | Indonesia |
Tin | Dowa | Japan |
Tin | EM Vinto | Bolivia |
Tin | Fenix Metals | Poland |
Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | China |
Tin | China Tin Group Co., Ltd. | China |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
Tin | Metallic Resources, Inc. | United States |
Tin | Mineração Taboca S.A. | Brazil |
Tin | Minsur | Peru |
Tin | Mitsubishi Materials Corporation | Japan |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
Tin | Operaciones Metalurgical S.A. | Bolivia |
Tin | PT Artha Cipta Langgeng | Indonesia |
Tin | PT Babel Inti Perkasa | Indonesia |
Tin | PT Bangka Tin Industry | Indonesia |
Tin | PT Belitung Industri Sejahtera | Indonesia |
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Mineral | Smelter | Location of Facility |
Tin | PT Bukit Timah | Indonesia |
Tin | PT DS Jaya Abadi | Indonesia |
Tin | PT Eunindo Usaha Mandiri | Indonesia |
Tin | PT Mitra Stania Prima | Indonesia |
Tin | PT Panca Mega Persada | Indonesia |
Tin | PT Prima Timah Utama | Indonesia |
Tin | PT Refined Bangka Tin | Indonesia |
Tin | PT Sariwiguna Binasentosa | Indonesia |
Tin | PT Stanindo Inti Perkasa | Indonesia |
Tin | PT Sumber Jaya Indah | Indonesia |
Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
Tin | PT Timah (Persero) Tbk Mentok | Indonesia |
Tin | PT Tinindo Inter Nusa | Indonesia |
Tin | Rui Da Hung | Taiwan |
Tin | Soft Metais Ltda. | Brazil |
Tin | Thaisarco | Thailand |
Tin | VQB Mineral and Trading Group JSC | Vietnam |
Tin | White Solder Metalurgia E Mineração Ltda. | Brazil |
Tin | Yunnan Chengfeng Non-Ferrous Metals Co., Ltd. | China |
Tin | Yunnan Tin Group (Holding) Company Limited | China |
Tin | CV Venus Inti Perkasa | Indonesia |
Tin | Magnu's Minerais Metais E Ligas Ltda. | Brazil |
Tin | Melt Metais E Ligas S.A. | Brazil |
Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
Tin | PT Inti Stania Prima | Indonesia |
Tin | CV Ayi Jaya | Indonesia |
Tin | Resind Indústria e Comércio Ltda. | Brazil |
Tin | Metallo-Chimique N.V. | Belgium |
Tin | Elmet S.L.U. | Spain |
Tin | PT Bangka Prima Tin | Indonesia |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
Tungsten | Japan New Metals Co., Ltd. | Japan |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
Tungsten | Xiamen Tungsten Co., Ltd. | China |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
The conflict minerals contained in our 3TG Products, to the extent known, are believed to have been sourced from recycled materials or the following countries: Austria, Belgium, Bolivia, Brazil, Canada, China, Germany, Indonesia, Italy, Japan, Kazakhstan, Republic of Korea, Malaysia, Mexico, Peru, Philippines, Poland, Russia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, United States, Vietnam. |