Maxwell Technologies Inc

For almost 50 years, our world-class research and product development teams have established Maxwell Technologies as a global leader in developing, manufacturing and marketing energy storage and power delivery solutions for automotive, heavy transportation, renewable energy, backup power, wireless communications and industrial and consumer electronics applications as well as for radiation-hardened microelectronic components and systems for satellites and spacecraft. Maxwell products are designed and built to provide failure-free performance for the life of the most demanding applications.

As a market leader and innovator, Maxwell Technologies is committed to providing cost-effective, energy-efficient, environmentally-conscious energy storage and power delivery solutions that extend the limits of current conventions. Our success is built on providing unmatched total solutions to our customers – solutions that deliver superior performance, reliability and value, backed by extraordinary application engineering and field support. Our goal is to build long-term customer relationships by listening, understanding customer-specific requirements and exceeding expectations for value and performance.

Maxwell’s global organization, deep experience and proven track record spanning nearly five decades give customers the confidence that comes with dealing with an acknowledged leader in each of the markets we serve with the following lines of high-reliability products:

Our Products

Ultracapacitors

Maxwell’s primary focus is on ultracapacitors, energy storage devices that are characterized by high power density, long operational life, the ability to charge and discharge very rapidly, and reliable performance at extreme temperatures. Maxwell ultracapacitor products provide energy storage and power delivery solutions for applications in many industries, including automotive, heavy transportation, renewable energy, backup power, wireless communications and consumer and industrial electronics.

Microelectronics

Maxwell’s radiation-hardened microelectronic products for satellites and spacecraft include single board computers and components such as high-density memory and power modules. Many of these products incorporate Maxwell proprietary RADPAK® packaging and shielding technology and novel architectures that enable them to withstand the effects of environmental radiation and perform reliably in space.

High Voltage

Maxwell’s CONDIS® high-voltage capacitors are designed and manufactured to perform reliably for decades in all climates. These products include grading and coupling capacitors and capacitive voltage dividers that are used to ensure the safety and reliability of electric utility infrastructure and other applications involving transport, distribution and measurement of high-voltage electrical energy.

SUMMARY

Maxwell Technologies is a customer-focused, service-oriented developer and producer of advanced energy storage and power delivery products for the global marketplace. We are committed to continuous innovation through research and product development to create and deliver products that enable our customers to improve the performance and value of their products. In addition to providing superior products, we support our customers with sophisticated applications engineering services and responsive global field support. As an organization, we are dedicated to collaborating with our customers around the world to lead the way to a greener, more prosperous future with efficient, reliable and cost-effective energy storage and power-delivery solutions.

Regulatory Overview

In August 2012, the Securities and Exchange Commission ('SEC”) published its final rule implementing the conflict minerals reporting requirements of Section 1502 of the U.S. Dodd-Frank Wall Street Reform Act. The rule, in essence, requires U.S. public companies who manufacture or contract to manufacture products that include tin, tantalum, tungsten or gold, or their derivatives, ('Conflict Minerals”) to disclose the measures it has taken to determine whether those minerals originated from the Democratic Republic of the Congo or adjoining countries ('DRC”) and whether the mining or sourcing of those minerals funded conflict as defined under the rule. 

To the extent that Conflict Minerals are necessary to the functionality or production of products that Maxwell Technologies, Inc. ('Maxwell”) manufactures or contracts to manufacture, Maxwell is required to conduct supply chain procedures to conclude whether or not the Conflict Minerals originated in the DRC, and ultimately whether the sourcing of those minerals from the DRC funded conflict. The results of these procedures are to be disclosed annually on Maxwell’s website and in a specialized disclosure report on Form SD to be filed with the SEC no later than May 31 of each year.

Our Commitment

As a responsible corporate citizen, Maxwell is committed to sourcing responsibly and takes its legal compliance responsibilities under the SEC ruling seriously. Maxwell considers sourcing activities within its supply chain that fuel armed conflict and serious human rights abuses as unacceptable.

Maxwell strives to obtain a high degree of transparency in its supply chain sourcing activities for Conflict Minerals and to determine whether these sourcing activities fund conflict in the DRC. Maxwell does not directly source these minerals from mines, smelters or refiners, and, therefore, is many layers removed in the supply chain hierarchy from the original sources of Conflict Minerals. Consequently, Maxwell relies on the support of each party within its supply chain in order to trace the source of these minerals back to their origins. This process is complex and Maxwell expects that the completion of tracing the sources of its Conflict Minerals will be a multi-year effort within its supply chain.

Maxwell will strive to source from certified conflict-free sources when possible and practical. Currently, based on its size and place near the top of its supply chain, Maxwell is essentially depending on the Conflict-Free Smelter Program, sponsored by the Electronics Industry Citizen Coalition and the Global e-Sustainability Initiative ('EICC-GeSI”), which provides an independent certification as to whether a smelter’s or refiner’s sourcing practices are free of conflict, in order to conclude on the conflict status of its supply chain. Other similar certification programs may be developed in the future. Through its recent due diligence efforts, Maxwell has identified the existence of hundreds of smelters and refiners within its supply chain of materials containing Conflict Minerals. To date, a small proportion of these smelters and refiners have been certified as conflict-free under the EICC-GeSI Conflict-Free Smelter Program1. Maxwell believes that the goal of attaining conflict-free DRC sourcing will only be reached as more and more smelters and refiners are certified as conflict-free.

Maxwell expects to meet its SEC compliance obligations to conduct due diligence on DRC Conflict Mineral sourcing, however, Maxwell recognizes that these due diligence efforts will take multiple years to implement throughout the supply chain in which Maxwell participates.

Our Due Diligence Measures

Maxwell is working on implementing the five-step framework described in the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ('OECD Due Diligence Guidance”).

In 2012, we began surveying our direct suppliers to assess their usage of Conflict Minerals and to identify the smelters and refiners of Conflict Minerals in our supply chain. These supplier surveys are essentially ongoing as we attempt to gather additional information on the use and source of Conflict Minerals as it becomes available from our supply chain. We are diligently following up with our suppliers to obtain the necessary information in order to complete the tracing of Conflict Minerals in our products to the smelters and refiners of the minerals. To date, we have not identified any sourcing of Conflict Minerals from the DRC, however, complete sourcing information has not been received from all suppliers of materials, components and products containing Conflict Minerals. Maxwell evaluates supplier responses using a risk-based approach to assess our suppliers’ mineral sourcing practices with respect to funding or possible funding of armed conflict in the DRC. Risk mitigation measures are being developed to address the risks that sourcing practices within our supply chain may fund conflict in the DRC. When possible and practical, we aim to source from suppliers wherein the smelters and refiners in the supply chain have been certified as DRC conflict-free by the EICC-GeSI sponsored Conflict-Free Smelter Program. However, a small proportion of these smelters and refiners have been certified to date under this program.

Supplier Expectations

We expect our suppliers to strive to source from socially responsible sources that do not directly or indirectly contribute to conflict or human rights abuses.

In furtherance of this policy, suppliers who supply or manufacture materials, components or products containing Conflict Minerals are expected to:

• familiarize themselves with the SEC’s Conflict Minerals rule and the OECD Due Diligence;
• implement and communicate to their personnel and suppliers Conflict Minerals policies that are consistent with this policy, and require their direct and indirect suppliers to do the same;
• put in place procedures and management systems designed to prevent sourcing that is not DRC Conflict Free;
• put in place procedures for the traceability of Conflict Minerals at least to the smelter or refiner level, working with their direct and indirect suppliers as applicable;
• use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being conflict free, and require their direct and indirect suppliers to do the same;
• advise Maxwell in a timely manner of any determination that the supplier either has concluded or has a reasonable basis to believe that products it currently sells or has sold to Maxwell are not DRC Conflict Free;
• from time to time, at Maxwell’s request, provide to Maxwell written certifications and other information concerning the origin of Conflict Minerals included in products supplied to Maxwell and the supplier's compliance with this policy, and require their direct and indirect suppliers to do the same; and
• maintain reviewable business records for a period not less than five (5) years supporting the source of Conflict Minerals, as required under the OECD Due Diligence Guidance.

If we determine that a supplier is not in compliance with this policy, Maxwell will request such supplier to devise and implement a corrective action plan, and may terminate or suspend our relationship with such supplier at any time.