SD

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 Ave., Lisle, IL	60532
(Address of principal executive offices)	(Zip Code)

Scott L. D’Angelo, Vice President, General Counsel & Secretary (630) 577-8831

(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:

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

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 was unable to determine that the necessary conflict minerals used in certain of the products manufactured by the registrant or contracted by the registrant to be manufactured did not originate in the Democratic Republic of the Congo or an adjoining country or come from recycled or scrap sources.  The registrant conducted due diligence on the source and chain of custody of such conflict minerals that conforms to the nationally 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. 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 its conflict minerals policy 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 this Specialized Disclosure Report and has made a copy of the Conflict Minerals Report and this Specialized Disclosure Report available on its publicly available Internet website at the following link: http://www.ctscorp.com/resource-center/policies-and-certifications/Conflict Form SD.

(c)The definitions set forth in paragraph (d) of the guide and instructions of the United States Securities and Exchange Commission (SEC) for Form SD apply to any of the terms used but not otherwise defined 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

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02.

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 26, 2022		CTS CORPORATION
	By:	/s/ Scott L. D’Angelo
		Scott L. D’Angelo
		Vice President, General Counsel and Secretary

EX-1.01

Exhibit 1.01

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD-Exhibit 1.01

Conflict Minerals Report

Registrant submits the following Conflict Minerals Report as Exhibit 1.01 to the Form SD Specialized Disclosure Report:

I. Due Diligence: A description of the registrant’s reasonable country of origin inquiry and the measures the registrant has taken to conduct due diligence on the source and chain of custody of those conflict minerals is as follows:

A. The registrant’s due diligence process 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.organd included the following elements:

1.    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; and

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.

2.   Registrant’s identification and assessment of risk in the supply chain including:

a. identification of registrant’s relevant first-tier suppliers; and

b. conducting reasonable country of origin inquiries 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.  

Exhibit 1.01

B. Registrant has disclosed in this report the steps it has taken, and 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).

II.  Results of Due Diligence: Registrant’s due diligence measures in connection with all of registrant’s products including conflict minerals resulted in the receipt of 201 complete CMRTs and the identification of 187 RMAP Conformant smelters.

III. Product Description: Registrant’s statement in Item 1.01(b) of the Form SD Specialized Disclosure Report is based on the identification of 23 non-RMAP Conformant smelters by eighteen of registrant’s suppliers of certain of the components used in registrant’s Engineered Frequency, Commodity Frequency, Sensor and Control Products.  

A. The efforts of registrant and its suppliers to determine the mine or location of origin of the conflict minerals used in the Engineered Frequency, Commodity Frequency, Sensor and Control Products included requesting all relevant first-tier suppliers to complete the CMRT.

B. Registrant has set forth below the list of the 23 non-RMAP Conformant facilities used by the eighteen suppliers to process the necessary conflict minerals used in certain components for the Engineered Frequency, Commodity Frequency, Sensor and Control Products.  The country of origin of the conflict minerals used in these facilities was not provided and thus registrant was unable to determine that the conflict minerals used in certain of the components in these facilities did not originate in the Democratic Republic of the Congo or an adjoining country or come from recycled or scrap sources.

Conflict Mineral	Facility	Location
Gold	AngloGold Ashanti Corrego do Sitio Mineracao	BRAZIL
Gold	Chimet S.p.A	ITALY
Gold	Metalor Technologies (Hong Kong) Ltd.	CHINA
Gold	Metalor Technologies (Suzhou) Ltd.	CHINA
Gold	PAMP S.A.	SWITZERLAND
Gold	Great Wall Precious Metals Co,. LTD.	CHINA
Gold	OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)	RUSSIA
Gold	OJSC Novosibirsk Refinery	RUSSIA
Gold	JSC Uralelectromed	RUSSIA
Gold	Moscow Special Alloys Processing Plant	RUSSIA
Gold	Prioksky Plant of Non-Ferrous Metals	RUSSIA
Gold	SOE Shyolkovsky Factory of Secondary Precious Metals	RUSSIA
Tantalum	Mineracao Taboca S.A.	BRAZIL
Tantalum	Mitsui Mining and Smelting Co., Ltd.	JAPAN
Tin	Jiangxi New Nanshan Technology Ltd.	CHINA
Tin	PT Babel Inti Perkasa	INDONESIA
Tin	Melt Metais e Ligas S.A.	BRAZIL
Tin	Gejiu Kai Meng Industry and Trade LLC	CHINA
Tin	Yunnan Yunfan Non-ferrous Metals Co., Ltd.	CHINA
Tungsten	Chenzhou Diamond Tungsten Products Co., Ltd.	CHINA
Tungsten	Ganzhou Seadragon W & Mo Co., Ltd.	CHINA
Tungsten	Global Tungsten & Powders Corp.	USA
Tungsten	Unecha Refractory metals plant	RUSSIA