UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
Specialized Disclosure Report
Integrated Silicon Solution, Inc.
(Exact name of the registrant as specified in its charter)
Delaware | 000-23084 | 77-0199971 | ||
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||
1623 Buckeye Drive, Milpitas, California | 95035 | |||
(Address of principal executive offices) | (Zip Code) |
John M. Cobb (408) 969-6600
(Name and telephone number, including area code, of 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, 2014 to December 31, 2014. |
Section 1—Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Integrated Silicon Solution, Inc. (the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2014 to December 31, 2014. The Company is a fabless semiconductor company that designs and markets high performance integrated circuits primarily low, medium and high density DRAM, high speed and low power SRAM, NOR flash products and a variety of mixed signal and analog products.
Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”). The “Covered Countries” for purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As part of its business, the Company contracts with wafer fabrication foundries and other third parties to manufacture its products and small quantities of tantalum, tin, gold and tungsten are necessary to the functionality or production of such products. The Company has conducted a good faith reasonable country of origin inquiry regarding such Conflict Minerals. This good faith reasonable country of origin inquiry was intended to determine whether any of such Conflict Minerals originated in the Covered Countries and whether any of such Conflict Minerals may be from recycled or scrap sources. Based on this reasonable country of origin inquiry, the Company determined that the Conflict Minerals necessary for the function or manufacture of its products did not originate in the Covered Countries.
The Company’s supply chain with respect to its products is complex, and there are various third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of Conflict Minerals. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its applicable suppliers to provide information regarding the origin of Conflict Minerals that are included in its products. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore has taken steps to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain.
Accordingly, during the past year, the Company engaged with each of its applicable suppliers regarding the source of the Conflict Minerals in the Company’s supply chain. Each such supplier provided information to the Company using the Electronic Industry Citizenship Coalition Global e-Sustainability Initiative (EICC-GeSI) Conflict Minerals Reporting Template, indicating (i) the
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Conflict Minerals contained in each of the parts supplied by that supplier and (ii) the source of the Conflict Minerals, including smelter/refinery information. Responses were reviewed for completeness, reasonableness, and consistency, and we followed up with our contract manufacturers for corrections and clarifications as needed.
Based on our reasonable country of origin inquiry, and in light of the responses we received from our suppliers discussed above, the Company received sufficient information to reasonably determine that Conflict Minerals necessary for the function or manufacture of its products did not originate in the Covered Countries..
The Company is committed to using only DRC conflict free minerals and has adopted a Declaration of Conflict-Free Minerals, available on the Company’s website at http://www.issi.com/WW/pdf/ISSI_Declaration_of_Minerals_Conflict_Free.pdf. To help ensure compliance with applicable laws and Company policies, including the Company’s Declaration of Conflict-Free Minerals, the Company maintains a system that enables Company employees to send a confidential email to the Company’s executives and board of directors with regards to serious concerns that could have a large impact on the Company. The Company also intends to engage in ongoing diligence with its customers, suppliers and other interested parties to ensure continued compliance with the Company’s Declaration of Conflict-Free Minerals, and to identify and mitigate any future risks that the Conflict Minerals in the Company’s supply chain could benefit armed groups Democratic Republic of the Congo or adjoining countries.
A copy of this Conflict Minerals disclosure is available on the Company’s website athttp://www.issi.com/US/investor-sec-filings.shtml. The information on the Company’s website shall not be considered part of this filing.
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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.
Integrated Silicon Solution, Inc. | ||||||
By: | /s/ John M. Cobb | May 29, 2015 | ||||
John M. Cobb | ||||||
Vice President and Chief Financial Officer |
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