UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
The L.S. Starrett Co.
(Exact Name of Registrant as Specified in Charter)
|
Massachusetts |
1-367 |
04-1866480 |
|
(State or Other Jurisdiction of Incorporation) |
(Commission File Number) |
(IRS Employer Identification Number) |
|
121 Crescent Street, Athol, Massachusetts |
01331 |
|
(Address of Principal Executive Offices) |
(Zip Code) |
|
Stephen Walsh |
(978) 249-3551 |
|
(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 reporting period from January 1 to December 31, 2014.
Item 1.01 - Conflict Minerals Disclosure and Report
The L.S. Starrett Co. (the “Company”) evaluated its current product lines and determined that certain products, manufactured or contracted to manufacture, contain tin, tungsten, tantalum and/or gold (3TG). As a result the Company has filed a Conflict Minerals Report.
Item 1.02 - Exhibit
A copy of the Company's Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at http://www.starrett.com/.
Item 2.01 - Exhibits
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.
The L.S. Starrett Co.
(Registrant)
By: /s/ Francis J. O’Brien
Treasurer and Chief Financial Officer May 29, 2015
EXHIBIT INDEX
Exhibit 1.01 - Conflict Minerals Report.
Exhibit 1.01
Conflict Minerals Report of the L.S. Starrett Company
in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934
This is the Conflict Minerals Report of the L.S. Starrett Company (The “Company”) for calendar year 2014 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. 34-67716 for definitions to the terms used in this Report, unless otherwise defined herein.
The Company offers for sale precision measuring tools, metrology equipment, granite-based engineered solutions, saw blades and jobsite and shop tools. In accordance with SEC rules, the Company undertook due diligence to determine if any conflict minerals (tantalum, tin, tungsten and gold) were used in its manufacturing operations. Included in our review were purchased raw materials, components used in assemblies and finished product intended for resale. 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.
The Company’s manufacturing business is several levels removed from the actual mining of conflict minerals. The Company does not make purchases of raw ore or unrefined conflict minerals and makes no purchases in the Covered Countries.
The Company’s due diligence measures included:
A policy statement indicating the Company will comply with conflict minerals regulations as set forth by SEC regulations and the Dodd Frank Wall Street Reform Act
Designation of the Senior Vice President Operations as the person responsible for the due diligence process and SEC reporting
Nominated one person at each manufacturing location (Engineering Manager or General Manager) to be the leader of CM compliance program.
A review of raw materials, purchased components, and finished product intended for resale at each of its worldwide manufacturing locations.
Conducted a supply-chain survey with suppliers to determine if they used any of the conflict minerals and their sources of those minerals. This was done by letter and electronic communication. Each manufacturing location has a file to maintain a record of all related documentation
Follow-up with those suppliers who were not responsive or were source indeterminable
Instituted a CM verification process for any new suppliers
As of May 29, 2015, the Company sent supply chain surveys to 1207 suppliers. 1031 (85.4%) have affirmed they do not use any conflict minerals. 137 (11.3%) suppliers have not responded to date. 31(2.5%) responded they are not certain. 8 suppliers responded they are not conflict free. The company is working with those suppliers who are not conflict free or not certain by giving them time to research alternative sources and become compliant. In a few cases, we have made changes eliminating the need to purchase components which may use conflict minerals.
In the next compliance period, The Company intends to follow the above steps and will review its due diligence process to identify more effective means to obtain complete and accurate information about the supply chain to further mitigate the risk that its use of any conflict minerals do not benefit armed groups.