Exhibit 1.01
Conflict Minerals Report
This Conflict
Minerals Report (this Report) for Array Technologies, Inc. (the Company, Array, we or us) covers the period from January 1, 2023 to December 31, 2023 (the Reporting
Period) and is presented in accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the Rule).
As used herein and consistent with the Rule, Conflict Minerals or 3TG are columbite- tantalite (coltan), cassiterite, gold,
wolframite, and three specified derivatives: tantalum, tin, and tungsten. 3TG that are necessary to the functionality or production of our products are referred to herein as Necessary 3TG. Our products that contain Necessary 3TG are
referred to herein as In-scope Products. The terms adjoining country and armed group, as used in this Report, have the meanings contained in the Rule.
Executive Summary
Typically, we are many levels removed
from the market participants that source 3TG used in the components of our products and our supply chain is constantly evolving and geographically diverse. As a result, we were unable to determine the origin of all of the Necessary 3TG contained in
our In-scope Products. However, we have no knowledge that even the small amounts of Necessary 3TG in our In-scope Products originated in the Democratic Republic of the
Congo, or any adjoining countries (collectively, the Covered Countries). Due to the complexity and depth of our supply chain, and as described more fully below, we rely on our suppliers to provide information on the origin of the 3TG
contained in our products.
This Report discusses the steps we have taken to ensure that our and our suppliers sourcing practices are consistent
with our commitment to high moral and ethical standards and our Conflict Minerals Policy (the Policy), which is described below.
Applicability of the Conflict Minerals Rule to Our Company
Array is one of the worlds largest manufacturers of ground-mounting tracking systems used in utility and distributed generation solar energy projects
worldwide. Our principal products are a portfolio of integrated solar tracking systems comprised of software and hardware, including steel tubing, steel supports, drivelines, center structures, electric motors, motor control assemblies, bearing
assemblies, gearboxes and electronic controllers commonly referred to as a single-axis tracker. Trackers move solar panels throughout the day to maintain an optimal orientation to the sun, which significantly increases their energy
production. For a further discussion of our products, see our Annual Report on Form 10-K for the fiscal year that ended December 31, 2023. The information contained in our Form 10-K is not incorporated by reference into this Report or our Form SD and should not be considered part of this Report or our Form SD.
We are subject to the Rule because we are a public company with securities registered pursuant to Section 12(g) of the Exchange Act. We are required to
file a Form SD because we manufacture and contract to manufacture certain products that contain Necessary 3TG.
Our Conflict Minerals Policy
Array seeks to avoid using 3TG minerals which directly or indirectly finance or benefit armed groups in the Covered Countries. In furtherance of this
commitment, and in compliance with the Rule, Array adopted the Policy to outline our ethical practices and our efforts to ensure that the 3TG minerals used in our products are sourced from responsible supply chains. The Policy can be found at https://arraytechinc.com/our-story/policies/. Information contained on our website is not incorporated by reference into this report or the Form SD.
The Policy states that we expect suppliers who supply or manufacture components, parts or products for Array to:
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familiarize themselves with the Rule and the Policy, implement policies and systems that are consistent with the
Rule and the Policy and require their direct and indirect suppliers to do the same; |