UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form SD

Specialized Disclosure Report

Inphi Corporation

(Exact Name of Registrant as Specified in Its Charter)

(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:

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Form SD is being filed pursuant to Rule 13p-1 under the Securities Exchange Act of 1934. A copy of Inphi Corporation’s Conflict Minerals Report for the period from January 1, 2019 through December 31, 2019 is filed as Exhibit 1.01 to this Form SD. The information in this Form SD, including the Conflict Minerals Report, is publicly available on our website at www.inphi.com.

Item 1.02 Exhibit

Inphi Corporation is hereby filing its Conflict Minerals Report as Exhibit 1.01 as required by Item 1.01 of this Form SD.

Section 2 - Exhibits

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report of Inphi Corporation for the year ended December 31, 2019 as required by Items 1.01 and 1.02 of this Form SD.

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.

EXHIBIT INDEX

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Exhibit 1.01

Inphi Corporation

Conflict Minerals Report

For the Year Ended December 31, 2019

Introduction

This is the Conflict Minerals Report of Inphi Corporation (“Inphi” or “we”) for the year ended December 31, 2019 in accordance with the requirements of Rule 13p-1 (17 CFR 240.13p-1) of the Securities Exchange Act of 1934, as amended (the “Rule”). The U.S. Securities and Exchange Commission (“SEC”) approved the Rule to implement the reporting and disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 on some companies that use conflict minerals necessary for the functionality and production of product manufactured or contracted to be manufactured by the company. Under the Rule, such companies are required to disclose the source and chain of custody of its conflict minerals. This report has not been subject to an independent private sector audit as allowed under Rule 13p-1. This report and Form SD can be found on the Inphi Corporation website www.inphi.com. Terms not otherwise defined herein shall have the meanings ascribed to them under Form SD, the Rule and Release No. 34-67716.

Inphi is a leading provider of high-speed analog and mixed signal semiconductor and module solutions for the communications and data center markets. We design and manufacture integrated circuits and modules for optical interconnects and network communications. We are a fabless semiconductor provider. The manufacturing of most of our products is performed by outside semiconductor foundries and electronics assembly subcontractors, although certain low volume products are assembled and tested at our California locations. Therefore, Inphi does not directly purchase most materials for production of its products. We rely on foundries, subcontractors, and suppliers to gather and provide information on the materials used.

Inphi’s goal is to eliminate the use of conflict minerals defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten, from non-conflict-free sources. We are aware that many of our products contain tin, tantalum, tungsten and gold (“3TG”) metals that are necessary to the functionality or production of those products. To this end, Inphi works with its suppliers to identify the sources of all 3TG metals used in our products. If any of these metals originate from the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”), then further investigation is required. Inphi uses the tools provided by the Responsible Minerals Initiative (“RMI”) to gather information from suppliers. The information requested includes the name and location of smelters or refiners used to produce the metals and the origin of the minerals. Our due diligence process and efforts are consistent with the Organization for Economic Co-operation and Development (“OECD”) “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.” Our Conflict Minerals Policy can be found on the Inphi Corporation website at www.inphi.com.

The first step of our conflict mineral investigation was to determine the 3TG usage in our products. We reviewed the bill of materials and material composition of production products sold during 2019 to determine which products contain 3TG metals. Our semiconductor and module products contain one or more of the 3TG metals, tin, tantalum, tungsten, or gold, in varying quantities, which is necessary for their functionality. From this information, we developed a list of direct suppliers/subcontractors to be surveyed who provided 3TG materials for our products sold in 2019. Engineering, pre-production and evaluation materials were not included in the analysis.

Once the list of suppliers was identified, we began the process of surveying our supply chain using the RMI Conflict Mineral Reporting Template (“CMRT”). This template is used universally throughout the electronics industry and requests suppliers to provide information, including details of the smelters/refiners where the materials were processed and the location of mines where the minerals originated. We informed each supplier of our desire to use only materials verified to be conflict-free and asked them to return a completed CMRT form. If suppliers sent incomplete information or did not respond, we followed up with further requests. Based on the responses from the suppliers, we were not able to conclusively determine the complete geographic origin of all 3TG materials used in our products. In addition, some of the 3TG materials were sourced from recycled/scrap metal. Therefore, we proceeded to perform due diligence.

Inphi’s due diligence processes and efforts are based on the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.” Our goal is to establish a low-risk supply chain for 3TG metals.

Management Systems

Inphi has adopted a Conflict Minerals Policy, which is available on the Inphi Corporation website at www.inphi.com, and developed a cross-functional team, including members of management, to guide our efforts. Suppliers are informed of Inphi’s conflict mineral efforts and are expected to investigate their supply chains for conflict minerals information and inform us of the results. We are actively engaged with our suppliers to refine the information provided and work toward a conflict-free supply chain.

Assess Risk in Supply Chain

As a provider of integrated circuits, we have no direct relationship with 3TG suppliers. Thus, we rely upon information provided by our direct suppliers. Our review of this information revealed some inaccuracies and inconsistencies. Follow-up questions and repeated inquiries have helped to refine the responses, but there is still a risk that the final information is incomplete or inaccurate. Some suppliers are unable to gather complete information from their sub-tier suppliers, as some sub-tier suppliers consider this information to be proprietary.

Strategy to Respond to Identified Risks

We continue to engage with our direct suppliers and subcontractors to gather up-to-date conflict mineral information using the CMRT. We request our suppliers procure materials from known conflict-free sources. If a supplier is not identified as conflict-free, we request that they actively proceed to become certified. If this is not possible, we request our direct suppliers to find alternate sources that are certified as conflict-free.

Third Party Audits

Because Inphi does not have direct relationships with suppliers of the 3TG materials, we rely upon third parties to perform audits and certify smelters/refiners as conflict-free. The RMI coordinates audits of 3TG smelters/refiners and publishes lists of those that are found to be conflict-free by following OECD guidelines. The RMI also publishes names of smelters/refiners that are actively in the process of becoming certified conflict-free, but have not completed the process to date. Inphi uses these published lists to determine if the smelters/refiners supplying 3TG materials for our products are conflict-free. If the sources of all 3TG materials for a product have been identified as conflict-free, then Inphi considers such product as conflict-free.

Reporting and Results

Responses from our suppliers using the CMRT have been reviewed, combined and summarized.

Responding parties provided a CMRT, which includes a declaration page and a list of smelter/refiner names. Most provided complete lists of smelters, representing 100% of the 3TG materials they utilized. However, several suppliers provided incomplete lists of smelters/refiners due to their inability to obtain this information from all their sub-tier suppliers. We continue to work with those suppliers with incomplete lists to complete their responses.

Many suppliers declared that a portion of the 3TG materials came from the Covered Countries. However, these suppliers also indicated that such materials came from a smelter/refiner that has been audited and is listed as conflict-free by the RMI. Certain suppliers declared that they are uncertain if any 3TG materials came from the Covered Countries because (a) not all the smelters are identified or (b) not all of the smelters have been audited by an independent party to verify their declaration.

We combined the responses from all suppliers and created a list of unique smelter/refiner names. Inphi uses the RMI compliance lists to determine if the minerals originate from the Covered Countries and could be benefitting armed groups. A majority of the smelters/refiners on our list have been verified as conflict-free compliant by the RMI. However, not all of the smelters/refiners are on the RMI’s conflict-free lists. As such, the source of some of the minerals in our products remains unverified.

Steps to Improve Due Diligence

The information provided by our suppliers is still not complete. Inphi continues to work with its suppliers to improve the quality and completeness of information collected by using the most updated CMRT form. We continue to review supplier responses, provide feedback as necessary, and encourage suppliers to switch to certified conflict-free sources.

Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements. These statements include statements regarding our goals for future improvements to our due diligence process and to mitigate the risk surrounding the sourcing of our conflict minerals. All forward-looking statements involve risk and uncertainty. When considering these statements, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in our most recently filed Annual and Quarterly Reports on Forms 10-K and 10-Q, respectively. Except as required by law, we disclaim any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.

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