0000047307-16-000029.txt : 20160513 0000047307-16-000029.hdr.sgml : 20160513 20160513132838 ACCESSION NUMBER: 0000047307-16-000029 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20151231 1.02 20151231 FILED AS OF DATE: 20160513 DATE AS OF CHANGE: 20160513 FILER: COMPANY DATA: COMPANY CONFORMED NAME: HICKOK INC CENTRAL INDEX KEY: 0000047307 STANDARD INDUSTRIAL CLASSIFICATION: INDUSTRIAL INSTRUMENTS FOR MEASUREMENT, DISPLAY, AND CONTROL [3823] IRS NUMBER: 340288470 STATE OF INCORPORATION: OH FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-00147 FILM NUMBER: 161647343 BUSINESS ADDRESS: STREET 1: 10514 DUPONT AVE CITY: CLEVELAND STATE: OH ZIP: 44108 BUSINESS PHONE: 2165418060 MAIL ADDRESS: STREET 1: 10514 DUPONT AVE CITY: CLEVELAND STATE: OH ZIP: 44108 FORMER COMPANY: FORMER CONFORMED NAME: HICKOK ELECTRICAL INSTRUMENT CO DATE OF NAME CHANGE: 19920703 SD 1 formSDfy16q3.htm FORM SD SPECIALIZED DISCLOSURE REPORT Hickok Form SD
UNITED STATES
SECURITIES AND EXCHANGE  COMMISSION
WASHINGTON, DC 20549




FORM SD
Specialized Disclosure Report


                                                 HICKOK INCORPORATED                                                        
(Exact name of registrant as specified in its charter)


                 Ohio              
(State or other jurisdiction
of incorporation or organization)
                 0-147                
(Commission
File Number)
         34-0288470      
(IRS Employer
Identification No.)


    10514 Dupont Avenue      Cleveland, Ohio                                                                                44108
    (Address of principal executive offices)                                                                             (Zip Code)


             Robert L. Bauman                                                 (216) 541-8060                                              
(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:

[ X ] Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the period from January 1, 2015 to December 31, 2015.



Section 1 - Conflict Minerals Disclosure

Item 1.01   Conflict Minerals Disclosure and Report

              
A copy of Hickok Incorporated's Conflict Minerals Report filed on May 13, 2016,  is filed as Exhibit 1.01 hereto and is publicly available at www.hickok-inc.com/about-us/financial-information.html.

Item 1.02   Exhibits

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report:

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.


HICKOK INCORPORATED                    

By:  /s/ Robert L. Bauman                        
Robert L. Bauman                            
President and CEO                
Date:    May 13, 2016


EX-1.01 2 exhibit1.01.htm EXHIBIT 1.01 CONFLICT MINERALS REPORT Exhibit1.01fy16qtr3

Form SD

Exhibit 1.01

Hickok Incorporated
Conflict Minerals Report

For The Year Ended December 31, 2015

Conflict Minerals Report of Hickok Incorporated in Accordance with Rule 13p-I under the Securities Exchange Act of 1934

This is the Conflict Minerals Report of Hickok Incorporated (OTC Pink:HICKA) for calendar year 2015 in accordance with 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, Hickok Incorporated undertook developing a Policy and performing due diligence to determine the conflict minerals status of the necessary conflict minerals used in its' products that use electronic components. In conducting its due diligence, Hickok has continued to review its' suppliers for compliance with its' Dodd-Frank Conflict-Free Minerals Legislation Policy as new items were ordered. In all but several instances the Company has been able to verify that its' suppliers have implemented due diligence efforts to comply with the Conflict Minerals requirements of the Dodd Frank Act. Most of the Company's suppliers are publically held distribution companies required to submit their own Form SDs. In the several instances where compliance could not be verified Hickok has determined in good faith that for calendar year 2015, its conflict minerals status resulting from its due diligence efforts shows a portion to be "DRC conflict undeterminable" and the remainder to be "DRC conflict free" (terms as defined in the 1934 Act).

As a company in the electronic tool assembly business, Hickok is several levels removed from the actual mining of conflict minerals. Hickok does not make purchases of raw ore or unrefined conflict minerals and makes no purchases in the Covered Countries.

This Report has not been subject to an independent private sector audit as allowed under Rule 13p-1, which provides a temporary accommodation for the first four years following November 13, 2012 for Small Reporting Companies.

Hickok's due diligence measures include:

- Conducting supply-chain surveys in accordance with our Policy with our suppliers of components containing conflict minerals. During 2015 we updated our Reporting Form and the revision improved response rates from suppliers.

- Sending due diligence questionnaires to suppliers that could not be verified as having published Conflict Materials Policies or public filings indicating their compliance with the Conflict Materials law.

As a result of the due diligence measures described above, Hickok has determined that the components we purchase from domestic suppliers are conflict mineral free. However for several components that are purchased from foreign suppliers we cannot make this determination due to a lack of information from their suppliers for certain printed circuits and plated screw machine parts to conclude whether the necessary conflict minerals originated in the Covered Countries and, if so, whether the necessary conflict minerals were from recycle or scrap sources, were DRC conflict free or have not been found to be DRC conflict free.

Over this compliance period Hickok updated our questionnaire and took additional steps in an effort to improve the information gathered from its due diligence to further mitigate the risk that its' necessary conflict minerals do not benefit armed groups. The increased efforts improved response rates slightly but did not result in coverage of all suppliers of materials we use within the scope of the Dodd-Frank Conflict Minerals Legislation Policy. Our conclusion is that the suppliers that would not respond are also so far removed from the materials sources that might use conflict minerals from the covered countries they cannot get reliable confirmation that any of the subject mineral sources are not within the covered countries and therefore cannot reply.

The Conflict Minerals Disclosure is available at www.hickok-inc.com/about-us/financial-information.html.