SD

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

SYNAPTICS INCORPORATED

(Exact name of registrant as specified in its charter)

DELAWARE	000-49602	77-0118518
(State or other jurisdiction of incorporation)	(Commission File Number)	(I.R.S. Employer Identification No.)

1251 McKay Drive

San Jose, California 95131

(Address of principal executive offices, including zip code)

(408) 904-1100

(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:

☒ 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.

Conflict Minerals Disclosure

Synaptics Incorporated (including its consolidated subsidiaries, the “Registrant”) is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period from January 1, 2016 to December 31, 2016 (the “Reporting Period”).

For the Reporting Period, the Registrant conducted, in good faith, a reasonable country of origin inquiry regarding the conflict minerals that are necessary to the functionality or production of products that the Registrant manufactures or contracts to manufacture (the “Minerals”). The inquiry was reasonably designed to determine if the Minerals originated in the Democratic Republic of the Congo or an adjoining country or are from recycled or scrap sources.

The Registrant has determined that it is required to file a Conflict Minerals Report, which is attached as Exhibit 1.01 to this report. The Conflict Minerals Report is also publicly available at http://www.synaptics.com. The content on, or accessible through, any website referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.

Item 1.02. Exhibit.

The Registrant’s Conflict Minerals Report is included as Exhibit 1.01 to this report.

Section 2 – Exhibits

Item 2.01. Exhibits.

Exhibit Number	Description
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 undersigned hereunto duly authorized.

Synaptics Incorporated

By: /s/ Alex Wong

Alex Wong

Senior Vice President of Worldwide Operations

May 31, 2017

EX-1.01

EXHIBIT 1.01

CONFLICT MINERALS REPORT

This Conflict Minerals Report (“Report”) of Synaptics Incorporated and its consolidated subsidiaries (“Synaptics,” the “Registrant” or “we”) for the year ended December 31, 2016 (the “Reporting Period”), is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), the instructions to Form SD, and the Public Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the Securities and Exchange Commission on April 29, 2014. Please refer to the Rule, Form SD, and the Securities and Exchange Commission’s (“SEC”) Release No. 34-67716 issued by the SEC on August 22, 2012 for definitions to the terms used in this Report, unless otherwise defined herein.

Synaptics is a leading worldwide developer and supplier of custom-designed human interface product solutions that enable people to interact more easily and intuitively with a wide variety of mobile computing, communications, entertainment, and other electronic devices. Synaptics currently generates revenue from the markets for smartphones, tablets, personal computer, or PC, products, primarily notebook computers, and other select electronic devices, including devices in automobiles, with our customized human interface solutions. Every solution we deliver either contains or consists of our touch-, display driver- or fingerprint authentication-based semiconductor solutions, which includes our chip, customer-specific firmware, and software. We generally supply our human interface product solutions to our original equipment manufacturer (OEM) customers through their contract manufacturers, which take delivery of our products and pay us directly for such products.

Synaptics does not engage in the actual mining of conflict minerals (the “Minerals”), does not make purchases of raw ore or unrefined Minerals from mines, and is many steps removed in the supply chain from the mining of the Minerals. We purchase the materials used in our products from a large network of suppliers, who may contribute necessary Minerals to our products. The smelters and refiners used by our suppliers are in the best position in the total supply chain to know the origin of ores, which cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullions or other Minerals-containing derivatives. We rely on our suppliers to assist with our due diligence efforts, including our suppliers’ self-identification of the smelters and refiners used in their supply chain, and the countries from which the Minerals used in their supply chain may originate.

I. Products

The following products were identified during the Reporting Period as products that may contain conflict minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by Synaptics:

• Our mobile solutions include our ClearPad^TM product line, designed for clear, capacitive touchscreen solutions that enable the user to interact directly with the

display on electronic devices, such as mobile smartphones and tablets, and our family of ClearView^TM Liquid Crystal Display (LCD) and Organic Light Emitting Diode (OLED) display drivers. We typically sell our ClearPad products as a chip, together with customer-specific firmware, to sensor manufacturers or OLED or LCD manufacturers to integrate into their touch-enabled products. A discrete touchscreen product typically consists of a transparent, thin capacitive sensor that can be placed over any display, such as an LCD or OLED and combined with a flexible circuit material and a touch controller chip. A display integrated touchscreen product typically consists of a capacitive touch sensor embedded into the LCD panel, combined with a flexible circuit material and a touch controller chip.

• Our personal computer, or PC, solutions, include our TouchPad^TM, ClickPad^TM, ForcePad^TM, SecurePad^TM, Dual Pointing Solutions, and TouchStyk^TM product lines, which are touch-sensitive pads and other interfaces that sense the position, movement, force, or a combination thereof, applied by one or more fingers on its surface through the measurement of capacitance. We typically sell our PC solutions as a module to the contract manufacturers of OEMs for assembly into notebook computers or other PC products.

• Our ClearView^TM display driver products offer advanced image processing and low power technology for entry-level smartphones through high-resolution tablets. The adaptive image processing works in concert with proprietary customization options enabling development of efficient and cost-effective high performance solutions and faster time to market.

• Our TouchView^TM products integrate touch and display technologies to deliver advanced performance and simplified design. Our proprietary algorithms synchronize touch sensing with display driving, effectively eliminating display-induced noise and improving capacitive sensing performance. TouchView is available in two-chip and single-chip (touch and display integration (TDDI)) configurations; both configurations reduce manufacturing complexity and simplify the supply chain for OEM manufacturers.

• Our Natural ID^TM Fingerprint Identification products, used in both our mobile and PC solutions, are fingerprint authentication solutions that use capacitive imaging technology, along with sophisticated digital image processing to unlock devices and access online services such as retail, banking, and social media portals. We typically sell our Natural ID Fingerprint products as a module to the contract manufacturers of OEMs or directly to the OEM for assembly into mobile or PC products.

II. Due Diligence

Based on the OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas (Third Edition OECD 2016) and the due diligence framework published by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI), including the Conflict-Free Sourcing Initiative (CFSI) current template for calendar year 2016 as developed jointly by the EICC-GeSI (the “Template”), the Registrant took the following measures, during

the Reporting Period, to determine the source and chain of custody for the Minerals which the Registrant believed necessary to the functionality or production of products manufactured, or contracted to be manufactured, by the Registrant in the Reporting Period.

1. The Registrant identified 65 suppliers, whom the Registrant believed could provide materials containing the Minerals necessary to the functionality or production of products manufactured by the Registrant, or contracted by the Registrant to be manufactured.

2. The Registrant sent out a Conflict Minerals survey, based on the Template, to the suppliers described in No. 1 above requesting them to (a) determine whether they supplied the Registrant with metals or materials containing the Minerals; (b) conduct independent due diligence on their own supply chain; (c) using EICC-GeSI resources, identify all smelters in their supply chain that supply products containing the Minerals to Registrant; and (d) download, complete and return the Template to the Registrant identifying all smelters and determining whether such smelters were certified as conflict-free. For any non-conflict free certified smelters identified, the Registrant strongly recommended the supplier remove such non-conflict free certified smelters from the supplier’s supply chain and required the supplier to submit a plan detailing its efforts to remove or replace the non-conflict free certified smelter. In addition, Registrant’s suppliers were required to establish and document a policy on conflict minerals.

3. All suppliers identified in No. 1 above completed the steps described in No. 2 above. Nine suppliers declared that their products did not contain any conflict minerals. Of the 56 suppliers who stated their products may contain conflict minerals, approximately 67% stated gold may be in the products supplied to Registrant; approximately 79% stated tin may be in the products supplied to Registrant; approximately 19% stated tantalum may be in the products supplied to Registrant; and approximately 30% stated tungsten may be in the products supplied to Registrant.

4. All of the suppliers who responded identified all smelters used in their supply chain in accordance with the Template and its instructions and of these suppliers, 97% certified that the metals or materials they supplied to Synaptics were conflict-free Minerals. The two suppliers who could not certify that 100% of their smelters were CFSI-compliant sourced from a combined 174 different smelters, of which four smelters had operations which were closed or idle during calendar year 2016, resulting in such smelters’ removal from the CFSI-compliant list, as idle or closed operations do not meet the CFSI’s definition of a smelter. All four of these smelters were valid CFSI-compliant smelters prior to idling operations or closure.

5. Synaptics compared the smelters identified by each of our suppliers to the list of smelters identified as conflict-free or “Active” by CFSI. Approximately 98% of the smelters used by our suppliers appeared on this list and are certified by the CFSI as conflict-free smelters. Based on the information provided by our suppliers, Synaptics believes that the facilities used to process the Minerals contained in Synaptics’ products include the smelters listed in Exhibit A below.

6.        a. Our suppliers used approximately 35 different smelters located in 11 different countries for tantalum. These countries include Austria, Brazil, China, Estonia, Germany, Japan, Kazakhstan, Mexico, Russian Federation, Thailand and the United States of America. Of these smelters, 91% are certified conflict-free smelters as defined by the CFSI. The three smelters who were not certified conflict-free smelters had operations which closed or became idle during calendar year 2016.

b. Our suppliers used approximately 68 different smelters located in 25 different countries for gold. Those countries include Australia, Austria, Belgium, Brazil, Canada, China, Germany, India, Indonesia, Italy, Japan, Mexico, Netherlands, Philippines, Russian Federation, Singapore, South Africa, South Korea, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, and the United States of America. Of these smelters, 100% are certified conflict-free smelters as defined by the CFSI.

c. Our suppliers used approximately 57 different smelters located in 15 different countries for tin. These countries include Belgium, Bolivia, Brazil, China, Indonesia, Japan, Malaysia, Peru, Philippines, Poland, Spain, Taiwan, Thailand, the United States of America, and Vietnam. Of these smelters, approximately 98% are certified conflict-free smelters as defined by the CFSI. The only smelter who was not certified conflict-free had operations which closed or became idle during calendar year 2016.

d. Our suppliers used approximately 27 different smelters located in 7 different countries for tungsten. These countries include Austria, China, Germany, Japan, Russian Federation, the United States of America, and Vietnam. Of these smelters, 100% are certified conflict-free smelters as defined by the CFSI.

7. The Registrant’s reasonable country of origin inquiry is based on surveys of its smelters. Certain smelters’ country of origin information was not available because the particular smelter had, among other reasons, gone out of operation before the end of calendar year 2016. Therefore, the Registrant is unable, at this time, to conclusively determine the countries of origin of all the Minerals used in its products.

During the Reporting Period, we conducted the due diligence efforts described in this Report to determine the mine or location of the Minerals in our products. We relied on the information provided by independent third party audit programs, such as the CFSI, to determine whether the smelters disclosed by our suppliers had been conflict-free certified or were “Active smelters” who had committed to undergo a Conflict-Free Smelter Program audit, according to the CFSI’s standards. For the current Reporting Period, certain smelters, who had previously been listed as CFSI conflict-free smelters, were no longer listed as CFSI conflict-free smelters due to closure of the smelter or the smelter idling its operations during calendar year 2016.

We continue to recommend to, and put pressure on, our suppliers who had non-conflict free certified smelters in their supply chain in calendar year 2016 to remove such non-conflict free certified smelters from their supply chain as soon as possible and we require such suppliers to submit a plan to the Registrant detailing their efforts to either remove or replace such smelter. We also have an audit plan in place, which was created to specifically audit the design, performance and effectiveness of our due diligence framework and due diligence measures as they relate to the Minerals.

As discussed above, where possible, the Registrant has relied on third party assurances and certifications. For example, the Registrant accepts as reliable any smelter that is a member of the CFSI program. To the extent that other audited supplier certifications are provided to the Registrant, the Registrant may consider reliance on such certifications on a case-by-case basis.

III. Additional Due Diligence and Risk Mitigation

We will continue to monitor our supply chain, including smelters used by our suppliers, to ensure that all smelters used by our suppliers continue to remain conflict-free. We will continue to monitor and pressure our supply chain to provide complete and accurate information regarding their smelters who provide the Minerals; continue to pressure our supply chain to either remove or replace non-conflict free certified smelters from their own supply chain; remove from our supply chain those suppliers who refuse to or who are unable to provide complete information regarding their smelters; remove from our supply chain those suppliers who continue to maintain non-conflict free certified smelters in their supply chain; and audit the results of supplier responses to the Template, including potential site visits to our supplier locations around the world, as required.

Due to the size, breadth and complexity of our supply chain, the process of successfully tracing all of the necessary Minerals used in our products back to their country of origin will require additional time and resources. Our ability to make determinations about the presence and source of origin of such Minerals in our products depends upon a number of factors including, but not limited to: (i) the respective due diligence efforts of our tier one suppliers and their supply chain, as well as their willingness to disclose such information to us, and (ii) the ability and willingness of our supply chain to adopt the OECD Guidance and other initiatives or guidance that may develop over time with respect to responsible sourcing. The inability to obtain reliable information from any level of our supply chain could have a material impact on our

ability to provide meaningful information on the presence and origin of necessary Minerals in our products’ supply chain with any reasonable degree of certainty. There can be no assurance that our suppliers will continue to cooperate with our diligence inquiries and our requests for certifications, or to provide us with the documentation or other evidence that we consider reliable in a timeframe sufficient to allow us to make a reasonable and reliable assessment following appropriate further diligence measures, as may be required.

Exhibit A

Smelters reported in Registrant’s Supply Chain as of December 31, 2016:

Smelter Name	Smelter Country
A.L.M.T. TUNGSTEN Corp.	Japan
Aida Chemical Industries Co., Ltd.	Japan
Allgemeine Gold-und Silberscheideanstalt A.G.	Germany
Alpha	United States
AngloGold Ashanti Córrego do Sítio Mineração	Brazil
Argor-Heraeus S.A.	Switzerland
Asahi Pretec Corp.	Japan
Asahi Refining Canada Ltd.	Canada
Asahi Refining USA Inc.	United States
Asaka Riken Co., Ltd.	Japan
Aurubis AG	Germany
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)	Philippines
Boliden AB	Sweden
C. Hafner GmbH + Co. KG	Germany
CCR Refinery - Glencore Canada Corporation	Canada
Changsha South Tantalum Niobium Co., Ltd.	China
Chenzhou Diamond Tungsten Products Co., Ltd.	China
Chimet S.p.A.	Italy
China Tin Group Co., Ltd.	China
Chongyi Zhangyuan Tungsten Co., Ltd.	China
Conghua Tantalum and Niobium Smeltry	China
Cooperativa Metalurgica de Rondônia Ltda.	Brazil
CV Ayi Jaya	Indonesia
CV Gita Pesona	Indonesia
CV Serumpun Sebalai	Indonesia
CV United Smelting	Indonesia
CV Venus Inti Perkasa	Indonesia
D Block Metals, LLC	United States
DODUCO GmbH	Germany
Dowa	Japan
Duoluoshan	China
Eco-System Recycling Co., Ltd.	Japan
Elemetal Refining, LLC	United States
Elmet S.L.U.	Spain
EM Vinto	Bolivia
Exotech Inc.	United States

F&X Electro-Materials Ltd.	China
Fenix Metals	Poland
Fujian Jinxin Tungsten Co., Ltd.	China
Ganzhou Huaxing Tungsten Products Co., Ltd.	China
Ganzhou Seadragon W & Mo Co., Ltd.	China
Gejiu Non-Ferrous Metal Processing Co., Ltd.	China
Global Advanced Metals Aizu	Japan
Global Advanced Metals Boyertown	United States
Global Tungsten & Powders Corp.	United States
Guangdong Xianglu Tungsten Co., Ltd.	China
Guangdong Zhiyuan New Material Co., Ltd.	China
H.C. Starck Co., Ltd.	Thailand
H.C. Starck GmbH	Germany
H.C. Starck GmbH Goslar	Germany
H.C. Starck GmbH Laufenburg	Germany
H.C. Starck Hermsdorf GmbH	Germany
H.C. Starck Inc.	United States
H.C. Starck Ltd.	Japan
H.C. Starck Smelting GmbH & Co. KG	Germany
H.C. Starck Smelting GmbH & Co.KG	Germany
Heimerle + Meule GmbH	Germany
Hengyang King Xing Lifeng New Materials Co., Ltd.	China
Heraeus Metals Hong Kong Ltd.	China
Heraeus Precious Metals GmbH & Co. KG	Germany
Hi-Temp Specialty Metals, Inc.	United States
Hunan Chenzhou Mining Co., Ltd.	China
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji	China
Hunan Chunchang Nonferrous Metals Co., Ltd.	China
Hydrometallurg, JSC	Russian Federation
Ishifuku Metal Industry Co., Ltd.	Japan
Istanbul Gold Refinery	Turkey
Japan New Metals Co., Ltd.	Japan
Jiangwu H.C. Starck Tungsten Products Co., Ltd.	China
Jiangxi Copper Co., Ltd.	China
Jiangxi Gan Bei Tungsten Co., Ltd.	China
Jiangxi Ketai Advanced Material Co., Ltd.	China
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.	China
Jiangxi Xinsheng Tungsten Industry Co., Ltd.	China
JiuJiang JinXin Nonferrous Metals Co., Ltd.	China
Jiujiang Tanbre Co., Ltd.	China

JX Nippon Mining & Metals Co., Ltd.	Japan
KEMET Blue Metals	Mexico
KEMET Blue Powder	United States
Kennametal Fallon	United States
Kennametal Huntsville	United States
Kennecott Utah Copper LLC	United States
Kojima Chemicals Co., Ltd.	Japan
LSM Brasil S.A.	Brazil
LS-NIKKO Copper Inc.	South Korea
Magnu’s Minerais Metais e Ligas Ltda.	Brazil
Malaysia Smelting Corporation (MSC)	Malaysia
Materion	United States
Matsuda Sangyo Co., Ltd.	Japan
Melt Metais e Ligas S.A.	Brazil
Metallic Resources, Inc.	United States
Metallo-Chimique N.V.	Belgium
Metalor Technologies (Hong Kong) Ltd.	China
Metalor Technologies (Singapore) Pte., Ltd.	Singapore
Metalor Technologies S.A.	Switzerland
Metalor USA Refining Corporation	United States
Metalúrgica Met-Mex Peñoles S.A. De C.V.	Mexico
Mineração Taboca S.A.	Brazil
Minsur	Peru
Mitsubishi Materials Corporation	Japan
Mitsui Mining & Smelting	Japan
Mitsui Mining and Smelting Co., Ltd.	Japan
MMTC-PAMP India Pvt., Ltd.	India
Molycorp Silmet A.S.	Estonia
Nadir Metal Rafineri San. Ve Tic. A.Ş.	Turkey
Niagara Refining LLC	United States
Nihon Material Co., Ltd.	Japan
Ningxia Orient Tantalum Industry Co., Ltd.	China
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC	Vietnam
O.M. Manufacturing (Thailand) Co., Ltd.	Thailand
O.M. Manufacturing Philippines, Inc.	Philippines
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH	Austria
Ohura Precious Metal Industry Co., Ltd.	Japan
Operaciones Metalurgical S.A.	Bolivia
PAMP S.A.	Switzerland
Plansee SE Liezen	Austria

Plansee SE Reutte	Austria
PT Aneka Tambang (Persero) Tbk	Indonesia
PT Aries Kencana Sejahtera	Indonesia
PT Artha Cipta Langgeng	Indonesia
PT ATD Makmur Mandiri Jaya	Indonesia
PT Babel Inti Perkasa	Indonesia
PT Bangka Prima Tin	Indonesia
PT Bangka Tin Industry	Indonesia
PT Belitung Industri Sejahtera	Indonesia
PT Bukit Timah	Indonesia
PT Cipta Persada Mulia	Indonesia
PT DS Jaya Abadi	Indonesia
PT Eunindo Usaha Mandiri	Indonesia
PT Inti Stania Prima	Indonesia
PT Justindo	Indonesia
PT Mitra Stania Prima	Indonesia
PT Panca Mega Persada	Indonesia
PT Prima Timah Utama	Indonesia
PT Refined Bangka Tin	Indonesia
PT Sariwiguna Binasentosa	Indonesia
PT Stanindo Inti Perkasa	Indonesia
PT Sukses Inti Makmur	Indonesia
PT Sumber Jaya Indah	Indonesia
PT Timah (Persero) Tbk Kundur	Indonesia
PT Timah (Persero) Tbk Mentok	Indonesia
PT Tinindo Inter Nusa	Indonesia
PT Wahana Perkit Jaya	Indonesia
PX Précinox S.A.	Switzerland
Rand Refinery (Pty) Ltd.	South Africa
Republic Metals Corporation	United States
Resind Indústria e Comércio Ltda.	Brazil
Royal Canadian Mint	Canada
Rui Da Hung	Taiwan
Schone Edelmetaal B.V.	Netherlands
SEMPSA Joyería Platería S.A.	Spain
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.	China
Sichuan Tianze Precious Metals Co., Ltd.	China
SOE Shyolkovsky Factory of Secondary Precious Metals	Russian Federation
Soft Metais Ltda.	Brazil
Solar Applied Materials Technology Corp.	Taiwan

Solikamsk Magnesium Works OAO	Russian Federation
Sumitomo Metal Mining Co., Ltd.	Japan
Taki Chemical Co., Ltd.	Japan
Tanaka Kikinzoku Kogyo K.K.	Japan
Tejing (Vietnam) Tungsten Co., Ltd.	Vietnam
Telex Metals	United States
Thaisarco	Thailand
The Refinery of Shandong Gold Mining Co., Ltd.	China
Tokuriki Honten Co., Ltd.	Japan
Ulba Metallurgical Plant JSC	Kazakhstan
Umicore Brasil Ltda.	Brazil
Umicore Precious Metals Thailand	Thailand
Umicore S.A. Business Unit Precious Metals Refining	Belgium
United Precious Metal Refining, Inc.	United States
Valcambi S.A.	Switzerland
VQB Mineral and Trading Group JSC	Vietnam
Western Australian Mint trading as The Perth Mint	Australia
White Solder Metalurgia e Mineração Ltda.	Brazil
Wolfram Bergbau und Hütten AG	Austria
Xiamen Tungsten (H.C.) Co., Ltd.	China
Xiamen Tungsten Co., Ltd.	China
Yamamoto Precious Metal Co., Ltd.	Japan
Yichun Jin Yang Rare Metal Co., Ltd.	China
Yokohama Metal Co., Ltd.	Japan
Yunnan Tin Company Limited	China
Zhongyuan Gold Smelter of Zhongjin Gold Corporation	China
Zhuzhou Cemented Carbide Group Co., Ltd.	China
Zijin Mining Group Co., Ltd. Gold Refinery	China