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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
Dynasil Corporation of America
(Exact Name of Registrant as Specified in Charter)
DELAWARE | 000-27503 | 22-1734088 |
(State or Other Jurisdiction of | (Commission File Number) | (IRS Employer Identification |
Incorporation) | Number) |
44 Hunt Street, Watertown, MA | 02472 | |
(Address of Principal Executive Offices) | (Zip Code) |
Patricia Kehe | (617) 668-6855 |
(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:
xRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013.
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Dynasil Corporation of America evaluated its current product lines and determined that certain products we manufacture or contract to manufacture contained tin, tungsten, tantalum and/or gold (the “Conflict Minerals”) and that these conflict minerals were necessary to the functionality or production of those products. As a result, Dynasil conducted a reasonable country of origin inquiry (RCOI) to determine whether any of the conflict minerals contained in Dynasil’s products originated in the Democratic Republic of the Congo or any adjoining country (the “Covered Countries”) or were from recycled or scrap sources.
Our RCOI consisted of the following:
1. | Educating our internal employees about Conflict Minerals and our reporting obligation. | |
2. | Listing all products and the component parts and materials containing Conflict Minerals, or using engineering knowledge, would be expected to use Conflict Minerals during production. | |
3. | Excluding parts which were manufactured before 2013 since any Conflict Minerals contained in these products was smelted before 2013 | |
4. | Identifying the suppliers from which we purchase Conflict Minerals. | |
5. | Communicating our sourcing policy and commitments to our suppliers; | |
6. | Educating our suppliers about the Conflict Minerals reporting obligation; | |
7. | Requesting information from our suppliers regarding the Conflict Mineral content of the components they provide, their knowledge on the source of any Conflict Minerals, including whether the Conflict Minerals come from recycled or scrap sources (the “Survey”); and | |
8. | Collecting and analyzing information from suppliers who responded to the Survey. |
We identified and contacted a total of fourteen suppliers of Conflict Mineral related products and materials. Ten of these suppliers responded to our request for information for country of origin information. Upon completion of the RCOI, we were unable to determine that none of the conflict minerals contained in our products originated in the Covered Countries or were from recycled or scrap sources.
For this reason, Dynasil has filed a Conflict Minerals Report as Exhibit 1.01 to this Form SD. A copy of the Conflict Minerals Report is publicly available at:www.dynasil.comunder “Corporate Governance”.
Item 1.02 Exhibit
A copy of our Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD.
Section 2 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.
DYNASIL CORPORATION OF AMERICA | ||
By: | /s/ Thomas C. Leonard | |
Thomas C. Leonard | ||
Chief Financial Officer | ||
Dated: May 28, 2014 |