0001104659-14-043408.txt : 20140623 0001104659-14-043408.hdr.sgml : 20140623 20140602172028 ACCESSION NUMBER: 0001104659-14-043408 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20131231 1.02 20131231 FILED AS OF DATE: 20140602 DATE AS OF CHANGE: 20140602 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NORTECH SYSTEMS INC CENTRAL INDEX KEY: 0000722313 STANDARD INDUSTRIAL CLASSIFICATION: ELECTRONIC COMPONENTS, NEC [3679] IRS NUMBER: 411681094 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-13257 FILM NUMBER: 14885119 BUSINESS ADDRESS: STREET 1: 1120 WAYZATA BLVD EAST STREET 2: SUITE 201 CITY: WAYZATA STATE: MN ZIP: 55391 BUSINESS PHONE: 9523452277 MAIL ADDRESS: STREET 1: 1120 WAYZATA BLVD EAST CITY: WAYZATA STATE: MN ZIP: 55391 FORMER COMPANY: FORMER CONFORMED NAME: DSC NORTECH INC DATE OF NAME CHANGE: 19901217 FORMER COMPANY: FORMER CONFORMED NAME: DIGIGRAPHIC SYSTEMS CORP DATE OF NAME CHANGE: 19881113 SD 1 a14-14600_1sd.htm SD

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

 

FORM SD

 

Specialized Disclosure Report

 

Date of Report (Date of earliest event reported):  May 30, 2014

 

NORTECH SYSTEMS INCORPORATED

(Exact name of registrant as specified in charter)

 

Minnesota

 

0-13257

 

41-16810894

(State or other jurisdiction

 

(Commission

 

IRS Employer

of incorporation)

 

File Number)

 

Identification No.)

 

1120 Wayzata Boulevard East, Suite 201

Wayzata, MN 55391

(Address of principal executive offices)

 

(952) 345-2244

(Registrant’s telephone number, including area code)

 

Not Applicable

(Former name or former address, if changed from last 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:

 

o Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013.

 

 

 



 

Item 1.01 Conflict Minerals Disclosure and Report

 

The Conflict Minerals Report for the calendar year ended December 31, 2013 filed herewith as Exhibit 1.02, is available at http://www.nortechsys.com/nortech-advantage/quality-and-compliance.

 

Exhibit 1.02 — Conflict Minerals Report as required by item 1.01 of this form.

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

 

Date: June 2, 2014

 

 

 

 

Nortech Systems Incorporated

 

(Registrant)

 

 

 

/s/ Paula M. Graff

 

Paula M. Graff, CFO

 

2


EX-1.02 2 a14-14600_1ex1d02.htm EX-1.02

Exhibit 1.02

 

Conflict Minerals Report

 

Nortech Systems is a full-service electronics manufacturing (EMS) provider of wire and cable assemblies, printed circuit boards assemblies and higher-level complete box build assemblies for a wide range of industries.  Conflict Minerals are necessary to the functionality of products we manufacture.

 

Part I.   Due Diligence

 

Design of Due Diligence

 

Our due diligence procedures are in compliance with the Organization for Economic Co-operation and Development (OECD) 5 Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain.

 

Due Diligence Measures Performed

 

Nortech’s policy regarding Conflict Minerals was communicated to employees internally and to suppliers externally via e-mail and 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

 

 

Global Sourcing Manager

 

 

Materials Manager

 

 

 

Executive Sponsors:

 

President & CEO

 

 

VP & Chief Financial Officer

 

 

VP Global Supply Chain & EMS Operations

 

Our reasonable country of origin inquiry and due diligence procedures includes the following:

 

·                  Develop a list of components, products and suppliers with the assistance of supply chain personnel at each location.

·                  The components, products and suppliers will be evaluated to identify whether each contain Conflict Minerals, with the understanding that there is no minimum amount for exclusion from the requirement using a multi-layered approach.

·            We will identify and assess risks in the supply chain. For the majority of our parts, Tin, Tantalum, and Gold are necessary to the functionality or production of a product manufactured. To a lesser tungsten is necessary for some parts.

·            Data will be collected directly from suppliers using the conflict minerals reporting template developed by the Conflict-Free Sourcing Initiative.

·           Supplier declarations will be evaluated to determine if supplies, products or components containing Conflict Minerals purchased by Nortech are derived from the Covered Countries.

·           We respond to identified risks and red flags including but not limited to: Conflict Mineral source not on EICC- GeSI Conflict-Free Smelter (CFS); Conflict Minerals from area with limited known reserves; Conflict Minerals originate from or have been transported via a conflict-affected or high-risk area but reported as Conflict Free; supply chain know to have sourced minerals from a red flag locations (as identified above). We then determine if other diligence is necessary such

 



 

as further follow up direct with the supplier or members of their supply chain, audits, or review of third party due diligence audits already performed.

·                  Based upon the results of the evaluation, we will make a determination whether Nortech can be identified as DRC Conflict Free, DRC Not Conflict Free or DRC Conflict Undeterminable.

·                  Audit Requirement: A certified independent private sector audit is required to express a conclusion on whether the design of the issuer’s due diligence measures are in conformity with the criteria set form in a nationally or internationally recognized due diligence framework and whether the issuer’s description of the due diligence measures is performed as set forth in the Conflict Minerals Report and is consistent with the due diligence that the issuer undertook. Currently, the only known such framework is the OECD’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”. An Undeterminable status does not require an audit.

·                  Reporting to the customer.

·           Nortech issues a standard response using the EICC Template unless a customer requests another format, in which case we may customize. If vendors are not found to be DRC Conflict Free, we will communicate this to our customers.

·           Nortech’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 will be made publicly available on our website in accordance with Exchange Act Section 13(p)(1)(E).