0000026058-20-000040.txt : 20200515 0000026058-20-000040.hdr.sgml : 20200515 20200515153835 ACCESSION NUMBER: 0000026058-20-000040 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20191231 1.02 20191231 FILED AS OF DATE: 20200515 DATE AS OF CHANGE: 20200515 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CTS CORP CENTRAL INDEX KEY: 0000026058 STANDARD INDUSTRIAL CLASSIFICATION: PRINTED CIRCUIT BOARDS [3672] IRS NUMBER: 350225010 STATE OF INCORPORATION: IN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-04639 FILM NUMBER: 20884570 BUSINESS ADDRESS: STREET 1: 4925 INDIANA AVENUE CITY: LISLE STATE: IL ZIP: 60532 BUSINESS PHONE: 6305778800 MAIL ADDRESS: STREET 1: 4925 INDIANA AVENUE CITY: LISLE STATE: IL ZIP: 60532 SD 1 a2019formsd.htm SD Document


 
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
 
 
FORM SD
 
Specialized Disclosure Report
 
CTS CORPORATION
(Exact name of registrant as specified in its charter)
 
INDIANA
 
1-4639
 
35-0225010
(State or other jurisdiction
 
(Commission
 
(IRS Employer
of incorporation or organization)
 
File Number)
 
Identification No.)
 
4925 Indiana Avenue, Lisle, IL
 
60532
(Address of principal executive offices)
 
(Zip Code)
 
Luis F. Machado, Vice President, General Counsel & Secretary (630) 577-8800
(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:
 
ý          Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.






























Section 1 - Conflict Minerals Disclosure

Item 1.01. Conflict Minerals Disclosure and Report

(a)Conflict minerals are necessary to the functionality or production of certain of the products manufactured by the registrant or contracted by the registrant to be manufactured and are required to be reported in the calendar year covered by this specialized disclosure report. Registrant does not purchase the conflict minerals directly from smelters or mines and as a result registrant conducted in good faith a reasonable country of origin inquiry with its suppliers and undertook due diligence measures reasonably designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo or an adjoining country or are from recycled or scrap sources.

(b)Based on its reasonable country of origin inquiry and due diligence measures, the registrant determined that its necessary conflict minerals used in certain of the products manufactured by the registrant or contracted by the registrant to be manufactured did or may have originated in the Democratic Republic of the Congo or an adjoining country and that they may not be from recycled or scrap sources. The registrant exercised due diligence on the source and chain of custody of such conflict minerals that conforms to the nationally due diligence framework as set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The reasonable country of origin inquiry and due diligence measures that registrant undertook included requesting all relevant first-tier suppliers to complete the RMI Conflict Minerals Reporting Template (CMRT) which can be found at http://www.responsiblemineralsinitiative.org, reviewing the information and smelter data provided by relevant first-tier suppliers, and comparing smelters and refiners identified by the supply chain to the RMAP Conformant Smelters list which can be found at http://www.responsiblemineralsinitiative.org. The registrant has disclosed this information on its publicly available Internet website at the following link: http:/www.ctscorp.com/resource-center/policies-and-certifications/Conflict Minerals Policy. The registrant is also filing a Conflict Minerals Report as an exhibit to its specialized disclosure report and has provided that report on its publicly available Internet website at the following link: http:/www.ctscorp.com/resource-center/policies-and-certifications/Conflict Minerals Form SD.

(c)    The definitions set forth in paragraph (d) of the guide and instructions of the United States Securities and Exchange Commission for Form SD apply to the terms used in this Specialized Disclosure Report.

Item 1.02. Exhibit

Registrant has filed, as exhibit 1.01 to this Form SD, the Conflict Minerals Report required by Item 1.01.

Section 2 - Exhibits

Item 2.01. Exhibits



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.

Date: May 15, 2020    
CTS CORPORATION

 
By:
/s/ Luis F. Machado
 
 
Luis F. Machado
 
 
Vice President, General Counsel, and Secretary
 


 EX-1.01 2 a2019formsdexhibit101.htm EXHIBIT 1.01 Exhibit


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD-Exhibit 1.01
Conflict Minerals Report

Registrant submits this Conflict Minerals Report as Exhibit 1.01 to FORM SD Specialized Disclosure Report and provides the following information:

(1)Due Diligence: A description of the registrant’s reasonable country of origin inquiry and the measures the registrant has taken to exercise due diligence on the source and chain of custody of those conflict minerals follows:

(i)The registrant’s due diligence conforms to the nationally or internationally recognized due diligence framework as set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas which can be found at http://www.oecd.org and included the following:
    
(A)     Registrant’s implementation of an execution plan for a company-wide conflict minerals program including:

(a)Registrant’s adoption of a conflict minerals policy which can be found on registrant’s publicly available Internet website at the following link: http://www.ctscorp.com/resource-center/policies-and-certifications/Conflict Minerals Policy.

(b)Registrant’s assembly of an internal team to implement, manage and execute registrant’s conflict minerals policy.

(c)Registrant’s adoption of a system designed to allow engagement and communication with the supply-chain and request information relating to the identity of the conflict mineral smelters and refiners used by the supply-chain.

(d)Registrant’s incorporation of registrant’s expectations regarding suppliers’ conflict minerals policies, processes and information disclosures into relevant registrant documents including for example registrant’s conflict minerals policy, registrant’s supplier purchase order terms and conditions, registrant’s supplier contract clauses, and registrant’s correspondence and communication with suppliers.

(B)     Registrant’s identification and assessment of risk in the supply chain including:

(a)
Identification of registrant’s relevant first-tier suppliers.
        
(b)    Conducting a reasonable country of origin and undertaking due diligence measures including requesting all relevant first-tier suppliers to complete the RMI Conflict Minerals Reporting Template (CMRT) which can be found at http://www.responsiblemineralsinitiative.org, reviewing the information and smelter data provided by relevant first-tier suppliers, and comparing smelters and refiners identified by the supply chain to the RMAP Conformant Smelters list which can be found at http://www.responsiblemineralsinitiative.org to assess possible risk.

(ii)The due diligence measures did not include and do not require an independent private sector audit of this Conflict Minerals Report.

(iii)Registrant has disclosed above the steps it has taken, and discloses below the steps which registrant will take, to mitigate the risk that its necessary conflict minerals benefit armed groups, including the adoption, monitoring, and tracking of a risk management, mitigation, and corrective action plan including follow-up letters to relevant first-tier suppliers requesting validation of such suppliers or the smelters or refiners used by such suppliers as RMAP Conformant in accordance with, for example, the Responsible Minerals Assurance Process (RMAP).






(2) Product Description: Registrant provides the following general description of the products identified in Item 1.01(b) of Form SD Specialized Disclosure Report:

Automotive Components: actuators, seat belt tension sensors, seat belt buckle switch sensors, wheel speed sensors, and fuel card sensors.

Registrant also provides below a list of the non-RMAP Conformant facilities used to process the necessary conflict minerals in certain of the products identified above. The country of origin of the conflict minerals is unknown. The efforts to determine the mine or location of origin of the conflict minerals included requesting all relevant first tier suppliers to complete the Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT) which required identification of the mine or location of origin of the conflict minerals, if known.

Conflict Mineral
Facility
Location
Gold
Pease & Curren
US
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Co.
VIETNAM