UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549
  
FORM SD
Specialized Disclosure Report 
ATMEL CORPORATION
(Exact name of registrant as specified in its charter)

Delaware
 
0-19032
 
77-0051991
(State or other jurisdiction of incorporation)
 
(Commission File Number)
 
(IRS Employer
Identification No.)

1600 Technology Drive, San Jose, California
(Address of principal executive offices)
95110
(Zip Code)

Scott Wornow
(408) 441-0311
(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

Atmel Corporation (“Atmel” or “we”) conducted a review of its supply chain to determine whether it purchases materials or products that incorporate conflict minerals as defined by the Securities and Exchange Commission. The review of our suppliers determined that our supply chain is “Conflict Free Undeterminable.” A copy of Atmel Corporation’s Conflict Minerals Report is filed as Exhibit 1.01 hereto, is incorporated herein by reference, and is publicly available at http://ir.atmel.com/governance.cfm.

Item 1.02    Exhibit

The Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form is filed as Exhibit 1.01 to this Form.

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.

 
 
ATMEL CORPORATION
 
 
 
 
 
 
May 29, 2015
By:
/s/ Scott Wornow
 
 
Scott Wornow
Senior Vice President and Chief Legal Officer







Exhibit 1.01

Conflict Minerals Report of Atmel Corporation
in Accordance with Rule 13p-1 under
the Securities Exchange Act of 1934

This Conflict Minerals Report (“Report”) is being filed by Atmel Corporation (“Atmel,” “we,” or the “Company”) for the year ended December 31, 2014 in compliance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “1934 Act”). Unless otherwise defined herein, capitalized terms used without definition in this Report have their respective definitions as set forth in Rule 13p-1, Form SD or Release No. 34-67716 under the 1934 Act.

As a result of the effectiveness of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Company undertakes an annual review of its supply chain to determine whether the Company purchases or purchased materials or products that incorporate or incorporated “conflict minerals,” as defined by the Securities and Exchange Commission.

The Company does not purchase any products directly from smelters, and we, therefore, did not contact smelters in our review. We contacted our direct suppliers and, where known to us, our suppliers’ suppliers. We do not refine ores and do not make purchases in any Covered Country.

In conducting our due diligence, we relied on practices outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2012 Second Edition) (“OECD Framework”), an internationally recognized standard that provides the basis on which we seek to conduct operations. We support, and adhere to, the Electronic Industry Citizenship Coalition (“EICC“) and Global e-Sustainability Initiative (“GeSI”) Conflict-Free Sourcing Initiative (“CFSI”). We obtained the data on which we relied for certain statements in this declaration through our membership in the CFSI, using the Reasonable Country of Origin Inquiry (“RCOI”). As part of its diligence process, the Company conducts ongoing inquiries and surveys of its supply chain, requests supplier certifications regarding the use of conflict minerals, and consistently reviews and analyzes CFSI data. The Company’s supply contracts generally require its suppliers to disclose whether they use conflict minerals; the Company expects to modify legacy supply contracts to request this additional information when, and if, those supply contracts are subject to renegotiation. The Company also expects that its ability to monitor, track and eliminate the use of conflict minerals will improve as the general availability of industry information, such as that obtained through the CFSI, improves, as supply chain compliance improves and as industry organizations and audit programs gain greater market acceptance and effectiveness.

Based on this diligence review and investigation of our supply chain, and the information received from that exercise, we have concluded, for the year ended December 31, 2014, that our products, or our use of materials that may be incorporated into our products, are DRC Conflict Undeterminable. We have, therefore, not audited this report, as permitted by Rule 13p-1.

Consistent with the foregoing, and the information available to the Company, the Company is unable to determine conclusively whether the following products are DRC Conflict Free:

Semiconductor devices using die that contain trace amounts of Tungsten or Tantalum;
Semiconductor devices that use Gold bond wire;
Semiconductor devices that use Gold Pre Plate Lead Frames (PPF), Tin Plated Lead Frames or Solder Balls; or
Semiconductor devices that use substrates containing Gold.

The Company intends to continue to monitor closely the use of conflict minerals, to enhance its diligence process and to seek continued access to industry developed information and data regarding conflict minerals.




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