UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
NAPCO SECURITY TECHNOLOGIES, INC.
(Exact name of the registrant as specified in its charter)
| Delaware | 0-10004 | 11-2277818 |
| (State or other jurisdiction of incorporation or organization) | (Commission File Number) |
(IRS Employer Identification No.) |
| 333 Bayview Avenue, Amityville, New York | 11701 |
| (Address of principal executive offices) | (Zip code) |
| Kevin S. Buchel | (631) 842-9400 |
| (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 (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
The Conflict Minerals Report of Napco Security Technologies, Inc., filed as Exhibit 1.01 hereto, is publically available at www.napcosecurity.com.
Item 1.02 Exhibit
Napco Security Technologies, Inc. is filing the Conflict Minerals Report required by Item 1.01 of Form SD.
Section 2 - Exhibits
Item 2.01 Exhibit
Exhibit 1.01 – Conflict Minerals Report
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.
| NAPCO SECURITY TECHNOLOGIES, INC. | ||
| (Registrant) | ||
| /s/ KEVIN S. BUCHEL | May 30, 2019 | |
|
By: Kevin S. Buchel Chief Financial Officer |
Date |
Exhibit 1.01
Conflict Minerals Report
Napco Security Technologies, Inc.
2018 Calendar Year
Overview
Napco Security Technologies, Inc., headquartered in Amityville, N.Y. was incorporated in Delaware in 1971. “The Company,” "Napco,” "we," "our" and "us" are used interchangeably to refer to Napco Security Technologies, Inc. and its subsidiaries.
The Company is a diversified manufacturer of security products, encompassing electronic door-locking devices, intrusion and fire alarms and building access control systems. These products are used for commercial, residential, institutional, industrial and governmental applications, and are sold worldwide principally to independent distributors, dealers and installers of security equipment.
This report for the year ended December 31, 2018 is filed to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), which was adopted by the Securities and Exchange Commission to implement reporting and disclosure requirements related to Conflict Minerals, as defined in Item 1.01(d)(3) of the Form SD, “Conflict Minerals,” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 imposes certain reporting obligations on certain SEC reporting companies whose manufactured products contain Conflict Minerals.
Part I. Due Diligence
Design of Conflict Minerals Program
The Company has integrated into its supply chain management programs the Organization for Economic Co-operation and Development five-step framework for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
Description of Due Diligence Measures Performed
Below is a description of the measures performed for this reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products which we had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources:
| · | Compared any smelters or refiners which were included in the supplier responses from our survey to the list of smelters and refiners maintained by the CFSI (conflict-free sourcing initiative). Appendix A contains a list of these smelters and refiners as well as the certification status as reported by the CFSI. |
| · | Contacted surveyed suppliers on responses to supply chain surveys that we identified contained incomplete or potentially inaccurate information to seek additional clarifying information. |
| · | Compared smelters and refiners identified by surveyed suppliers against the list of facilities that have received a “conflict-free” designation from the CFSP (conflict-free smelter program). |
| · | Napco provided 5 progress reports to Napco’s Senior Vice President of Operations and Finance. These progress reports summarized the status of the applicable conflict minerals program. |
Results of our Due Diligence Efforts
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of products which contain conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information, as well as the smelters and refiner facility visits, may yield inaccurate or incomplete information and may be subject to fraud.
Results of Reasonable Country of Origin Inquiry Efforts
Based on the survey responses received, we have identified 144 smelters and refiners that are certified conflict-free. The remaining 2 are not yet confirmed as conflict-free. We have determined that these two facilities are low-risk based primarily on their country of origin. Based on the surveys provided and diligence efforts that were completed, we do not have sufficient information to conclusively determine all smelters and refiners or countries of origin of the conflict minerals. However, we have not obtained any supplier responses that indicate sourcing from conflict mines.
Future Due Diligence Measures
| · | We are continuing to develop a risk mitigation response plan to address business relationships with suppliers that are not DRC conflict free (as defined in Item 1.01(d)(4) of Form SD), which mitigation may include identifying an alternate supply. Our program will include continuous monitoring to adjust our strategies as sourcing data improves and new information is received. |
| · | We will continue to assess and update future due diligence activities, including our efforts to determine smelter and mine locations, transit routes, and countries of origin. We tracked results of our supply chain diligence process and periodically reported the results to our executive leadership team. |
Part II. Product Description
For this reporting period, we identified the following products which we manufactured or purchased from others for resale that may contain necessary conflict minerals (defined as any tantalum, tin, tungsten or gold that is necessary to the functionality or production of our products):
Access Control Systems. Various types of identification readers (e.g. card readers, hand scanners), control panels, PC-based computers and electronically activated door-locking devices.
Door Security Products. Various metal door locking devices including microprocessor-based electronic door locks with push button, card reader and bio-metric operation, door alarms, mechanical door locks and simple dead bolt locks.
Intrusion and Fire Alarm Systems. Various detectors, control panels, digital keypads and signaling equipment.
Video Surveillance Systems. Video cameras, control panels, video monitors and recording devices.
Appendix A lists the facilities identified to us by our suppliers that were used to process the associated minerals that were used in manufacturing the component parts that we use in assembling our products.
This report is not subject to an independent private sector audit as allowed under Rule 13p-1.
Appendix A:
The following smelters and refiners were reports by our suppliers as being in their supply chains and, therefore, potentially in ours. Some suppliers responded at the company level, therefore some of the smelters or refiners listed below may not be related to the products that we source from these suppliers. The certification status of each smelter and refiner as indicated by the Conflict-Free Sourcing Initiative is contained in column four.
| Metal | Standard Smelter Name | Smelter Facility Location | Conflict Free? |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes |
| Gold | Asahi Pretec Corp. | JAPAN | Yes |
| Gold | Asahi Refining USA Inc. | UNITED STATES | Yes |
| Gold | Bangalore Refinery | INDIA | Unknown |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes |
| Gold | Boliden AB | SWEDEN | Yes |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes |
| Gold | Chimet S.p.A. | ITALY | Yes |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Yes |
| Gold | Istanbul Gold Refinery | TURKEY | Yes |
| Gold | Italpreziosi | ITALY | Yes |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Unknown |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Yes |
| Gold | L'Orfebre S.A. | ANDORRA | Yes |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Yes |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Yes |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes |
| Gold | Planta Recuperadora de Metales SpA | CHILE | Yes |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes |
| Gold | Remondis Argentia B.V. | NETHERLANDS | Yes |
| Gold | Republic Metals Corporation | UNITED STATES | Yes |
| Gold | SAAMP | FRANCE | Yes |
| Gold | Safimet S.p.A | Italy | Yes |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Yes |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Yes |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes |
| Gold | T.C.A S.p.A | ITALY | Yes |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes |
| Gold | Torecom | KOREA, REPUBLIC OF | Yes |
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Yes |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Yes |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes |
| Tantalum | Exotech Inc. | UNITED STATES | Yes |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes |
| Tantalum | H.C. Starck Ltd. | JAPAN | Yes |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Yes |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Yes |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | KEMET Blue Metals | MEXICO | Yes |
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Yes |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes |
| Tantalum | NPM Silmet AS | ESTONIA | Yes |
| Tantalum | Power Resources Ltd. | MACEDONIA | Yes |
| Tantalum | QuantumClean | UNITED STATES | Yes |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Yes |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes |
| Tantalum | Taki Chemicals | JAPAN | Yes |
| Tantalum | Telex Metals | UNITED STATES | Yes |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes |
| Tin | Alpha | UNITED STATES | Yes |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Yes |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Yes |
| Tin | China Tin Group Co., Ltd. | CHINA | Yes |
| Tin | CV Ayi Jaya | INDONESIA | Yes |
| Tin | CV Tiga Sekawan | INDONESIA | Yes |
| Tin | CV United Smelting | INDONESIA | Yes |
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes |
| Tin | Dowa | JAPAN | Yes |
| Tin | EM Vinto | BOLIVIA | Yes |
| Tin | Fenix Metals | POLAND | Yes |
| Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CHINA | Yes |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Yes |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Yes |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Yes |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Yes |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Yes |
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes |
| Tin | Metallo Belgium N.V. | BELGIUM | Yes |
| Tin | Metallo Spain S.L.U. | SPAIN | Yes |
| Tin | Mineracao Taboca S.A. | BRAZIL | Yes |
| Tin | Minsur | PERU | Yes |
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes |
| Tin | Modeltech Sdn Bhd | MALAYSIA | Yes |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes |
| Tin | PT Bangka Prima Tin | INDONESIA | Yes |
| Tin | PT Bangka Serumpun | INDONESIA | Yes |
| Tin | PT Bangka Tin Industry | INDONESIA | Yes |
| Tin | PT DS Jaya Abadi | INDONESIA | Yes |
| Tin | PT Inti Stania Prima | INDONESIA | Yes |
| Tin | PT Panca Mega Persada | INDONESIA | Yes |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes |
| Tin | PT Tirus Putra Mandiri | INDONESIA | Yes |
| Tin | PT Tommy Utama | INDONESIA | Yes |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Yes |
| Tin | Rui Da Hung | TAIWAN | Yes |
| Tin | Soft Metais Ltda. | BRAZIL | Yes |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Yes |
| Tin | Thaisarco | THAILAND | Yes |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Yes |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Yes |
| Tin | Yunnan Tin Company Limited | CHINA | Yes |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes |
| Tungsten | ACL Metais Eireli | BRAZIL | Yes |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Yes |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Kennametal Fallon | UNITED STATES | Yes |
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Yes |
| Tungsten | Niagara Refining LLC | UNITED STATES | Yes |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Yes |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Yes |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Yes |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Yes |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Yes |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |