Delaware | 001-34376 | 13-3458955 |
(State or other jurisdiction | (Commission | (I.R.S. Employer |
of incorporation or organization) | File Number) | Identification No.) |
Section 1 | Conflict Minerals Disclosure | |
Item 1.01 | Conflict Minerals Disclosure and Report |
Item 1.02 | Exhibit |
Section 2 | Exhibits | |
Item 2.01 | Exhibits |
IEC Electronics Corp. | ||
(Registrant) | ||
May 29, 2019 | By: | /s/ Thomas L. Barbato |
Thomas L. Barbato | ||
Senior Vice President and Chief Financial Officer |
• | Our policy regarding Conflict Minerals is posted to our website. |
• | Our cross-functional conflict minerals team was established to carry out the necessary due diligence and reporting requirements. The team currently includes the following roles: |
Team Members: | Corporate Director of Quality and Operational Excellence | |
Director of Supply Chain | ||
Supplier Quality Engineer | ||
Buyer | ||
Executive Sponsor: | Senior Vice President and Chief Financial Officer |
• | Develop a list of applicable suppliers with the assistance of supply chain personnel at each location. |
• | Request potential vendors to complete a Conflict Minerals Reporting Template (“CMRT”) prior to them being established as a vendor. |
• | Develop a list of applicable suppliers with the assistance of supply chain personnel at each location. |
• | We identify and assess risks within the supply chain based on commodity type and sourcing requirements and availability. For the majority of our parts, tin is necessary to the functionality or production of the manufactured product. To a lesser extent, tantalum, tungsten, and gold are also necessary for some parts. |
• | Data is collected directly from applicable suppliers using the CMRT. |
• | IEC has engaged with IHS Markit to assist in supplier data collection, management, and aggregation. |
• | Supplier declarations are evaluated, compiled, and tested for conformity by IHS Markit’s iPoint software to determine if supplies, products, or components containing Conflict Minerals purchased by IEC Electronics are derived from the Covered Countries. |
• | IHS Markit’s iPoint software is used to assess the status of supplier responses and facilitate responses to customer inquiries. |
• | Non-responses are followed up with additional requests and/or direct contact (email, phone, or in person) depending on risk. |
• | IEC Electronics utilizes IHS Markit’s iPoint software which includes information from the global smelter library. |
• | IEC Electronics files the Form SD and Conflict Minerals Report (“CMR”) with the Securities and Exchange Commission annually. |
• | We post the Form SD and CMR on our website. |
• | IEC Electronics issues a standard response using the CMRT. |
• | IEC Electronic’s corporate policy regarding Conflict Minerals and disclosure regarding whether any Conflict Minerals necessary to the functionality or production of a product originated in Covered Countries are made publicly available on our website in accordance with the Securities Exchange Act Section 13(p)(1)(E). |
• | Require potential vendors to complete a CMRT prior to them being established as a vendor. |
• | Working with customers when it is discovered that a component we source to support their product may benefit armed groups in the Covered Countries. |
Andorra | Indonesia | South Africa | ||
Australia | Italy | Spain | ||
Austria | Japan | Sweden | ||
Belgium | Kazakhstan | Switzerland | ||
Bolivia | Republic of Korea | Taiwan | ||
Brazil | Kyrgyzstan | Thailand | ||
Canada | Mexico | Turkey | ||
Chile | Malaysia | United Arab Emirates | ||
China | Peru | United States of America | ||
Estonia | Philippines | Uzbekistan | ||
France | Poland | Vietnam | ||
Germany | Russian Federation | |||
India | Singapore |