UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
IEC ELECTRONICS CORP.
(Exact name of registrant as specified in its charter)
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Delaware | 001-34376 | 13-3458955 |
(State or other jurisdiction | (Commission | (I.R.S. Employer |
of incorporation or organization) | File Number) | Identification No.) |
105 Norton Street, Newark, New York 14513
(Address of Principal Executive Offices) (Zip Code)
Thomas L. Barbato
Chief Financial Officer
315-331-7742
(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 period from January 1 to December 31, 2020.
Section 1Conflict Minerals Disclosure
Item 1.01Conflict Minerals Disclosure and Report
Introduction
Our Business
IEC Electronics Corp. (“IEC Electronics,” “we,” “our,” “us,” or the “Company”) provides electronic manufacturing services to advanced technology companies that produce life-saving and mission critical products for the medical, industrial, aerospace and defense sectors. We specialize in delivering technical solutions for the custom manufacture of complex full system assemblies by providing on-site analytical testing laboratories, custom design and test engineering services combined with a broad array of manufacturing services encompassing electronics, interconnect solutions, and precision metalworking. We manufacture complex printed circuit boards and system- level assemblies, a wide array of cable and wire harness assemblies and precision metal components. We are headquartered in Newark, NY and also have operations in Rochester, NY and Albuquerque, NM. Conflict Minerals are necessary to the functionality or production of the products that we manufacture for our advance technology customers pursuant to the designs they provide to us.
Our Conflict Minerals Program
Our Conflict Minerals Program conforms to the Organisation for Economic Co-operation and Development (“OECD”) “Five- Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain” as reasonable within the context of our business and supply chain:
STEP 1: Establish strong company management systems. STEP 2: Identify and assess risk in the supply chain.
STEP 3: Design and implement a strategy to respond to identified risks.
STEP 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
STEP 5: Report on supply chain due diligence.
Our Conflict Minerals Sourcing Policy
Our Conflict Minerals Sourcing Policy is available at https://www.iec-electronics.com/about/social-responsibility.
Our Supply Chain
As a provider of electronic manufacturing services, IEC Electronics is generally directed by our many customers to procure specific materials and components from a large number of specific manufacturers. In many cases, IEC Electronics purchases these materials and components from approved distributors and not directly from manufacturers. Due to this supply chain design, IEC Electronics has no direct interaction with smelters/refiners and no direct influence on smelter/refiner selection.
Reasonable Country of Origin Inquiry
IEC Electronics conducted a reasonable country of origin inquiry (“RCOI”) in good faith and in accordance with an internationally recognized framework. The RCOI included engaging a third-party vendor to assist in supplier data collection, management, and aggregation. As a result of the RCOI, IEC Electronics was unable to definitively determine if the conflict minerals used in the production of applicable products benefited armed groups in the Covered Countries.
The Conflict Minerals Report for the calendar year ended December 31, 2020 filed herewith as Exhibit 1.01, is available at https://www.iec-electronics.com/about/social-responsibility.
Item 1.02Exhibit
A copy of the Conflict Minerals Report for the year end December 31, 2020 is filed herewith as Exhibit 1.01.
Section 2Exhibits
Item 2.01Exhibits
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.
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IEC Electronics Corp. | |||
| (Registrant) | ||
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May 28, 2021 | By: | /s/ Thomas L. Barbato | |
Thomas L. Barbato | |||
Chief Financial Officer | |||
Exhibit 1.01
Conflict Minerals Report
IEC Electronics Corp. (“IEC Electronics,” “we,” “our,” “us,” or the “Company”) provides electronic manufacturing services to advanced technology companies that produce life-saving and mission critical products for the medical, industrial, aerospace and defense sectors. We specialize in delivering technical solutions for the custom manufacture of complex full system assemblies by providing on-site analytical testing laboratories, custom design and test engineering services combined with a broad array of manufacturing services encompassing electronics, interconnect solutions, and precision metalworking. We manufacture complex printed circuit boards and system- level assemblies, a wide array of cable and wire harness assemblies and precision metal components. We are headquartered in Newark, NY and also have operations in Rochester, NY and Albuquerque, NM. Conflict Minerals are necessary to the functionality or production of the products that we manufacture for our advance technology customers pursuant to the designs they provide to us.
Section I. Due Diligence
Design of Due Diligence
Our due diligence procedures conform to the Organisation for Economic Co-operation and Development (“OECD”) “Five- Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain.”
Establish Strong Company Management Systems
| ● | 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: | Director of Quality |
| Director of Supply Chain |
| Supplier Quality Engineer |
| Buyer |
Executive Sponsor: | 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. |
Identify and Assess Risk in the Supply Chain
| ● | 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 product manufactured. 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 are derived from the Covered Countries. |
Design and Implement a Strategy to Respond to Identified Risks
| ● | 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. |
Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
| ● | IEC Electronics utilizes IHS Markit’s iPoint software which includes information from the Global Smelter List. |
Report on Supply Chain Due Diligence
| ● | IEC Electronics files the Form SD and CMR with the SEC annually. |
| ● | We post the Form SD and CMR on our website. |
| ● | IEC Electronics issues a standard response using the CMRT. |
| ● | IEC’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). |
Steps taken to mitigate the risk that necessary conflict minerals benefit armed groups include the following:
| ● | 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. |
Section II.
Product Description
IEC Electronics has facilities located in Newark, NY; Rochester, NY; and Albuquerque, NM. At these facilities, we manufacture complex printed circuit boards and system-level assemblies, a wide array of cable and wire harness assemblies and precision metal components. Products are built to specifications provided by our customers.
Product Determination
IEC Electronics conducted due diligence on the products listed above, and as a result of that due diligence, IEC Electronics was unable to definitively determine if the conflict minerals used in the production of applicable products originated from the Covered Countries. Through our due diligence and reasonable country of origin efforts, the greatest possible specificity IEC is able to provide is the following list of countries of origin.
Reasonable Country-of-Origin Inquiry Results
The following countries were reported to IEC Electronics by our supply chain for the 2020 Reporting Year:
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Andorra | Germany | Netherlands | Sudan |
Australia | Ghana | New Zealand | Sweden |
Austria | India | Norway | Switzerland |
Belgium | Indonesia | Peru | Taiwan |
Bolivia | Italy | Philippines | Thailand |
Brazil | Japan | Poland | Turkey |
Canada | Kazakhstan | Russia | Uganda |
Chile | Kyrgyzstan | Rwanda | United Arab Emirates |
China | Lithuania | Saudi Arabia | United States of America |
Colombia | Malaysia | Singapore | Uzbekistan |
Czechia | Mauritania | South Africa | Vietnam |
Estonia | Mexico | South Korea | Zambia |
France | Myanmar | Spain | Zimbabwe |
Efforts used to determine the country of origin are described in “Section I. Due Diligence,” above.
Consistent with the provisions of the Rule, the SEC’s Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule dated April 29, 2014, and the SEC’s Order Issuing Stay dated May 2, 2014, this Report has not been audited by a third party. Notwithstanding anything to the contrary in this Report, for purposes of clarification and without limitation, IEC does not claim, nor are we implying, that any of our Covered Products are “DRC Conflict-Free.” An audit is not required for the reporting period from January 1, 2020 to December 31, 2020.