0001173382-14-000015.txt : 20140521 0001173382-14-000015.hdr.sgml : 20140521 20140521143644 ACCESSION NUMBER: 0001173382-14-000015 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20131231 FILED AS OF DATE: 20140521 DATE AS OF CHANGE: 20140521 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CAE INC CENTRAL INDEX KEY: 0001173382 STANDARD INDUSTRIAL CLASSIFICATION: MISCELLANEOUS ELECTRICAL MACHINERY, EQUIPMENT & SUPPLIES [3690] IRS NUMBER: 000000000 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-31402 FILM NUMBER: 14860384 BUSINESS ADDRESS: STREET 1: 2025 LOGISTICS DRIVE CITY: MISSISSAUGA STATE: A6 ZIP: L5S 1Z9 BUSINESS PHONE: 514-341-6780 MAIL ADDRESS: STREET 1: 8585 COTE DE LIESSE, CP 1800 STREET 2: DEPT. 04 CITY: ST-LAURENT, QUEBEC STATE: A6 ZIP: H4L 4X4 SD 1 formsdmay20-14.htm FORM SD formsdmay20-14.htm - Generated by SEC Publisher for SEC Filing

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD
Specialized Disclosure Report

CAE INC.

Canada 1-31402 Not Applicable
(State of incorporation ) (Commission (IRS Employer
  File Number) Identification No. )

 

8585 Côte-de-Liesse, Saint-Laurent, Québec, Canada H3Z 2G4
(Address of principal executive offices) (Postal Code)

Hartland Paterson, telephone: (514) 734-5779
(Name and telephone number 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, 2013.


Section I          Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report, Exhibit

A copy of CAE INC.’s Conflict Minerals Report is filed as Exhibit 2.01 hereto and is publicly available at www.cae.com.

Item 1.02 Exhibit

CAE has filed, as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.

Section 2          Exhibit

Item 2.01 Exhibit

The following exhibit is filed as part of this report:

Exhibit 2.01 — Conflict Minerals Report as required by Item 1.01 and 1.02 of this Form.

2


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.

CAE INC.  
By: /s/ Hartland Paterson Date: May 20, 2014
Name: Hartland Paterson  
Title: General Counsel, Chief Compliance Officer and Secretary  
    3

 

 EX-1.01 2 exhibit201may20-144.htm EXHIBIT 2.01-CONFLICT MINERALS REPORT exhibit201may20-144.htm - Generated by SEC Publisher for SEC Filing

Exhibit 2.01

     Conflict Minerals Report of CAE Inc. in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934

This is the Conflict Minerals Report of CAE Inc. (“CAE”) for calendar year 2013 in accordance with Rule 13p-1 (“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. 3467716 for definitions to the terms used in this Report, unless otherwise defined herein.

In accordance with the rules, CAE undertook due diligence to determine the conflict minerals status of the necessary conflict minerals gold and tin used in components for manufacturing CAE’s products. In conducting its due diligence, CAE applied guidance from the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2011) (“OECD Framework”), an internationally recognized due diligence framework.

CAE has determined in good faith from its due diligence efforts that for calendar year 2013 conflict minerals used in components for manufacturing CAE’s products are “DRC conflict free” (terms as defined in the 1934 Act).

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 two years following November 13, 2012.

CAE’s due diligence measures were based on the Electronic Industry Citizenship Coalition and Global e-Sustainability (“EICC/GeSI”) initiative with the smelters and refiners of conflict minerals who provide those conflict minerals to our suppliers. As a company in the simulator manufacturing business, CAE does not engage in the actual mining of conflict minerals. CAE does not make purchases of raw ore or unrefined conflict minerals and makes no purchases in the Covered Countries.

CAE’s due diligence measures included:

  • Determining which conflict minerals are necessary to the functionality or production of a product manufactured or contracted to be manufactured by CAE worldwide.

  • Adopting a Conflict Mineral Policy and revised the CAE Procurement Terms and Conditions to flow down Conflict Minerals requirements to suppliers.

  • Conducting a “Reasonable Country of Origin Inquiries” (RCOI) for “in scope” suppliers to ensure traceability throughout our supply chain to establish the origin of Conflict Minerals using the EICC/GeSI Conflict Minerals Reporting Template.

  • Discontinuing business with any supplier determined as “uncommitted” to compliance.

As a result of the due diligence measures described above, CAE has no reason to believe that its necessary Conflict Minerals (tin & gold) may have originated in the Democratic Republic of the Congo or An Adjoining Country.