Exhibit 1.01
Conflict Minerals Report of TransAct Technologies Incorporated
for the Calendar Year Ended December 31, 2019
in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934
This is the Conflict Minerals Report (“CMR”) of TransAct Technologies Incorporated (“TransAct” or “we”) for the year
ended December 31, 2019 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “1934 Act”). Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions to the terms used in this
Report, unless otherwise defined herein.
In accordance with the rules, we undertook due diligence measures to determine the conflict minerals status of the
necessary conflict minerals used in our printers, terminals and other products for transaction-based printing. In conducting our due diligence, we followed the Organisation for Economic Co-operation and Development Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (the “OECD Guidance”), which we believe is an internationally recognized due diligence framework.
Pursuant to SEC guidance issued April 29, 2014 and the SEC order issued May 2, 2014, we are not required to describe
any of our products as “DRC conflict free,” “DRC conflict undeterminable” or “having not been found to be ‘DRC conflict free,’” and therefore make no conclusion in this regard in this CMR. Furthermore, given that we have not voluntarily elected to
describe any of our products as “DRC conflict free,” an independent private sector audit of this CMR is not required.
1. Company, Product Overview & Background
TransAct is a global leader in developing and selling software-driven technology and printing solutions for high
growth markets including restaurant solutions, point of sale automation and banking, casino and gaming, lottery, and oil and gas. Our world-class products are designed from the ground up based on market and customer requirements and are sold under
the BOHA!, AccuDate™, EPICENTRAL™, Epic®, Ithaca®, and Printrex® brand names. Known and respected worldwide for innovative designs and real-world service reliability, our thermal, and inkjet printers and terminals generate top-quality labels, coupons
and transaction records such as receipts, tickets and other documents, as well as printed logging and plotting of data. We sell our products to original equipment manufacturers, value-added resellers, select distributors, as well as directly to
end-users. Our product distribution spans across the Americas, Europe, the Middle East, Africa, Asia, Australia, the Caribbean Islands and the South Pacific. We also offer world-class service, spare parts, accessories and printing supplies to our
growing worldwide base of products currently in use by our customers. Through our TransAct Services Group, we provide a complete range of supplies and consumables used in the printing and scanning activities of customers in the restaurant and
hospitality, banking, retail, casino and gaming, government and oil and gas exploration markets. Through our webstore, www.transactsupplies.com, and our direct selling team, we address the demand for these products. Our primary operating, hardware
research and development, and eastern region service center is located in Ithaca, New York. In addition, we have a casino and gaming sales headquarters, software research and development and western region service center in Las Vegas, Nevada; a
European sales and service center at our subsidiary in the United Kingdom, and a sales office located in Macau, China. Our executive offices are located at One Hamden Center, 2319 Whitney Avenue, Suite 3B, Hamden, Connecticut, 06518, with a
telephone number of (203) 859-6800.
In August 2012, the United States Securities and Exchange Commission (the “SEC”) approved the final rule regarding
the sourcing of conflict minerals as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. Under this rule, publicly traded companies must report annually to the SEC the presence of “conflict minerals” originating
from “Covered Countries” in either the products they manufacture or contract to manufacture, or use in the production process. Conflict minerals are defined as tin, tungsten, tantalum and gold. The Covered Countries are the Democratic Republic of
the Congo (“DRC”) and the nine adjoining countries: Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, Tanzania, South Sudan, Uganda and Zambia.
In 2013, we initiated a process that meets the framework in the OECD Guidance to comply with this regulation. This
includes establishing compliance requirements for our direct suppliers regarding conflict minerals, implementing controls and reporting, undertaking appropriate sourcing efforts, and providing our customers the data necessary to facilitate their SEC
reporting. We aligned our efforts to the practices established by industry peers – including the Electronics Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) – to enable companies to source conflict-free
minerals.
2. Due Diligence Program and Reasonable Country of Origin Inquiry (“RCOI”)
2.1 Conflict Minerals Policy
TransAct Technologies Incorporated Conflict Minerals Policy Statement
As a socially responsible company, we are concerned for the well-being of people and communities. We conduct business
fairly and ethically, respect human rights, comply with laws and regulations, and follow rigorous standards of business conduct.
We rely on our internal factory or contract manufacturers to make various products. We have
integrated responsible sourcing of minerals into our Supplier Policy and Supplier Code of Conduct. Our suppliers and their sub-tier suppliers are expected to provide the conflict minerals sourcing information and avoid using conflict minerals from
the Covered Countries.
Expectations for Suppliers
In support of our policy on conflict minerals, suppliers are expected to supply materials to us that are “DRC
Conflict-Free”. Suppliers are expected to adopt policies and management systems with respect to conflict minerals and to require their suppliers to adopt similar policies and systems. We expect suppliers to establish their own due diligence programs
to ensure conflict-free supply chains.
In the event we determine that a supplier’s efforts to comply with our policy have been deficient and the supplier
fails to cooperate in developing and implementing reasonable remedial steps, we reserve the right to take appropriate actions up to and including discontinuing purchases from the supplier.
It is our policy that (1) products supplied to us do not contain columbite-tantalite (coltan), cassirerite, gold,
wolframite, tantalum, tin, or tungsten as elements necessary to their production or functionality, or (2) if products supplied to us do contain these minerals, the minerals must originate outside the Covered Countries, come from scrap or recycled
sources, or be supplied from smelters that have been validated by an independent private sector party to be conflict-free.
We consider conflict-free smelters to be validated only if they have complied with the conflict free smelter program
(“CFSP”) assessment protocols and appear on the conflict-free smelters & refiners list, available www.conflictfreesmelter.org.
In addition, we will survey direct suppliers as a part of our conflict minerals due diligence program. Suppliers are
expected to respond to survey requests in a timely manner, and with full disclosure, following the specific instructions provided.
2.2 Due Diligence Process
We developed our due diligence processes and efforts to conform to the OECD Guidance. Our conflict
minerals due diligence process includes: developing and implementing our Conflict Minerals Policy and Supplier Code of Conduct, establishing governance structures with senior management’s involvement and engaging suppliers, record keeping and
escalation procedures in the event a supplier is discovered to be sourcing conflict minerals from any Covered Countries.
2.3 Internal Team
We have established a management system for complying with the applicable rules. The management
system includes the development of a Conflict Minerals Task Force led by our Senior Vice President of Operations, Chief Financial Officer and a team of experts in subject matters such as purchasing, engineering and quality assurance. The team of
subject matter experts is responsible for implementing our conflict minerals compliance policy and is led by our Global Sourcing Director who acts as the conflict minerals program manager. Senior management is briefed about the result of our due
diligence efforts on regular basis.
2.4 Product Analysis
We conducted an analysis of our products and found that certain conflict minerals, including tin,
tantalum, tungsten and gold, can be found in our printers and terminals. Therefore, the products we manufacture and contract to manufacture are subject to the reporting obligations of Rule 13p-1.
2.5 Supplier Engagement
To perform the RCOI, we contacted all contract manufacturers and suppliers whose products may
contain conflict minerals. All contract manufacturers and suppliers are required to conduct similar inquiries from their sub-tier suppliers and continue through the supply chain until we have identified the facilities used to process any conflict
minerals, the country of origin of the conflict minerals, and the mine or location of origin of conflict minerals. We used the template developed jointly by EICC and GeSI, known as the CFSI Reporting Template (the “Template”). The Template was
developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. We believe this Template has been widely adopted by companies in their due diligence processes related to
conflict minerals. We have not engaged a third party vendor to collect data, but we believe that some of our contract manufacturers and suppliers may have relied on third party software vendors to collect the data.
3. Conclusion
After conducting a good faith RCOI and pursuant to SEC guidance issued April 29, 2014 and the
SEC order issued May 2, 2014 as previously described, we have declined to describe our products as “DRC conflict free,” “DRC conflict undeterminable” or “having not been found to be ‘DRC conflict free.’” Due to the breadth and complexity of our
products and respective supply chain, it will take time for our suppliers to verify the origin of all these minerals. Based on all returned surveys to date, none of our direct or indirect suppliers source conflict minerals from any Covered
Countries. We plan to improve the transparency of our supply chain (1) using our supply chain due diligence processes, (2) leveraging the industry standard conflict free sourcing initiative (“CFSI”) and CFSP developed by EICC and GeSI, and (3)
continuing our supplier outreach efforts.
The conflict minerals contained in our products, to the extent known, are believed to have been
sourced from the following countries: Austria, Australia, Bolivia, Belgium, Brazil, Canada, Chile, China, Estonia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Kyrgyzstan, Lithuania, Macedonia, Mexico, Netherlands, New Zealand, Peru,
Philippines, Poland, Saudi Arabia, Singapore, Spain, Sweden, Switzerland, Russian Federation, South Africa, South Korea, Taiwan, Thailand, Turkey, United Arab Emirates, the United States of America, and Vietnam.
4. Identification and Assessment of Risk in the Supply Chain
Because of the breadth and complexity of our products and supply chain, it is difficult to identify
all downstream smelters and refineries from our supply chain.
As the result of our due diligence survey, we have identified 322 active smelters and refineries in
our supply chain. Of the 322 smelters and refineries, 247 have been certified by CFSP and are considered to be conflict free. For the remaining 75 smelters and refineries, we contacted such facilities and requested country, mine and/or location of
the necessary conflict minerals processed by them. As of this report we have not received responses from all our inquiries but of the responses received none of our smelters and/or refineries have been found to procure raw material from Covered
Countries.
5. Future Due Diligence Measures
We intend to continue to gather the information noted above as part of our due diligence process
for the reporting period ending December 31, 2020 and to take steps to further mitigate the risk that any conflict minerals we use do not benefit armed groups. These steps include: (1) increasing the response rate of our contract manufacturers’ and
suppliers’ conflict mineral surveys and (2) continuing to influence additional smelters to obtain CFSP status through our supply chain, where possible.
