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UNITED
STATES
SECURITIES
AND EXCHANGE COMMISSION
Washington,
D.C. 20549
FORM SD
Specialized Disclosure Report
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OMB
APPROVAL
OMB Number: 3235-0697
Expires: May
31, 2016
Estimated average
burden hours per response....480.61
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GAMING PARTNERS INTERNATIONAL CORPORATION
NEVADA
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0-23588
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88-0310433
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(State or other jurisdiction
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(Commission File #)
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(IRS Employer ID No)
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Of incorporation or organization)
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3945 W CHEYENNE, SUITE 208, NORTH LAS VEGAS, NV
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89032
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(Address of principal executive offices)
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(Zip Code)
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Alain Thieffry, Chief Financial Officer, and Chairperson of the Board, 702-598-2402
(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,
2015
.
Section 1 - Conflict Minerals Disclosure
Item 1.01
Conflict Minerals Disclosure and Report
(b)
Conflict Minerals Disclosure
This Form SD has been
prepared by GAMING PARTNERS INTERNATIONAL CORPORATION (herein referred to as “GPIC” the “Company,” “we,”
“us,” or “our”). The information includes the activities of all majority-owned subsidiaries that are required
to be consolidated. GPIC is a manufacturer and distributor of gaming products which are supplied to the casino industry. Our products
principally consist of gaming products (i.e. casino currency, playing cards, table layouts, dice, table accessories, and RFID technology)
which are supplied to the casino industry.
In 2013, the Company
developed policies and procedures to determine whether any of the products manufactured or contracted to be manufactured by GPIC
included parts, components or products which contained “Conflict Minerals” (columbite-tantalite (coltan), cassiterite,
gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten) necessary to the product’s generally
expected functions, use, purpose or production. The policies and procedures were developed in accordance with the OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals for Conflict-Affected and High-Risk Areas, including Supplements on Tin, Tantalum
and Tungsten, and the Gold Supplement (Second Edition 2012) (the “Guidance”) for supply chain diligence relating to
Conflict Minerals. GPIC conducts an annual evaluation to assess the applicability to the Company of Rule 13p-1 under the Securities
Exchange Act of 1934, as amended (the “Rule”) relating to the source and chain of custody of necessary Conflict Minerals
in its products originating from mines, refiners or smelters in the Democratic Republic of Congo and adjoining countries (the “Covered
Countries”) that, directly or indirectly, contribute to or finance militant groups in the region.
We have integrated
requirements related to the responsible sourcing of minerals with our Conflict Minerals Policy. Our suppliers are expected to
provide the sourcing information to us in accordance with our Conflict Minerals Policy, which is publicly available on our website
at
www.gpigaming.com
. The content of our website as referred to in this Form SD is included
for general information only and is not incorporated by reference into this Form SD.
For the reporting period
ended December 31, 2015, GPIC determined that the Company manufactured or contracted to manufacture certain of its products. These
products and related components and parts were then reviewed to determine whether they contained or were likely to contain any
Conflict Minerals. Based on these reviews, products containing Conflict Minerals necessary to its generally expected function,
use, purpose or production were identified, together with the supplier or suppliers of the relevant products, components or parts.
GPIC determined that the Company’s casino currency products contained a necessary Conflict Mineral, tungsten.
In accordance with the
requirements of the Rule, and the instructions to Form SD, GPIC undertook a reasonable country of origin inquiry (RCOI”)
of relevant suppliers of the components of its casino currency products in the Company’s supply chain for the reporting period
ended December 31, 2015.
As a company that purchases
raw materials for the production of gaming products, GPIC is several levels removed from the actual mining and smelting process
of Conflict Minerals. GPIC does not make direct purchases of raw ore or unrefined Conflict Minerals and makes no direct purchases
in the Covered Countries. Thus, in order to survey the Company’s supply chain, we rely upon our suppliers to provide information
on the origin of the materials supplied to us, including the materials that are supplied through their sub-tier suppliers.
The Company utilized
information and templates (the “CMRT”) obtained from the Electronic Industry Citizenship Coalition and Global e-Sustainability
(“EICC/GeSI”) Initiative relating to Conflict Minerals, including the Conflict Free Smelter Program (“CFSI”),
to conduct its inquiry. The CMRT was distributed to all identified suppliers of the Company’s casino currency products, components
or parts containing or likely to contain necessary tungsten to (i) confirm the presence of the minerals in such products, components
or parts, (ii) determine the country of origin of the tungsten used therein, (iii) determine whether such tungsten was sourced
from recycled or scrap materials, and (iv) confirm whether such products, components or part were otherwise outside of the supply
chain as of January 31, 2013, as set forth in the instructions to Form SD. The CMRT requested information on Conflict Minerals
supplied to the Company during calendar year 2015 and contained representations and certifications as to the source and origin
of the necessary tungsten in the casino currency products. The Company followed-up with suppliers through personal and written
communications, as necessary, resulting in a 100% response rate. Suppliers were asked to certify that materials sold to GPIC either
(i) do not originate from the Covered Countries, or (ii) are sourced from smelters or refiners validated as compliant to Conflict-Free
Sourcing (CFS) protocol using the CFSI Compliant Smelter and Refiner Lists. Each of the Company’s suppliers provided a certification
that the tungsten supplied by it did not originate in the Covered Countries, or otherwise came from scrap or recycled sources.
Based upon our review
of such certifications received from and other communications with our suppliers, GPIC considers that it is reasonable to rely
upon the representations and certifications obtained therefrom. Subject to and in reliance upon such certifications, GPIC has no
reason to believe that any of the necessary tungsten in its casino currency products originated in the Covered Countries or did
not otherwise come from recycled or scrap sources.
In accordance with our
Conflict Minerals Policy and our related procedures, our working group is continuing to monitor our supply chain and has sought
the cooperation and assistance of its suppliers in ensuring that the Conflict Minerals used in the Company’s products continue
to be sourced reliably and responsibly.
GPIC’s success
in making determinations about the potential presence of Conflict Minerals in its products depends upon various factors including,
but not limited to, (i) the respective due diligence efforts of our direct suppliers and their supply chain, together with their
willingness to provide the requested information, representations and certifications to the Company, and (ii) the ability of our
suppliers and other entities involved in our supply chain to make determinations consistent with nationally or internationally
recognized standards, including the OECD Guidance. Our inability to obtain reliable information from any level of our supply chain
could have a material impact on our future ability to report on the presence of Conflict Minerals with any degree of certainty.
There can be no assurance that our suppliers will continue to cooperate with its information inquiries and requests for certifications
or provide reliable and timely documentation or other evidence we require to enable us Company to make a reasonable determination
with respect to further RCOIs.
Item 1.02
Exhibits
None.
SECTION 2. EXHIBITS
Item 2.01
Exhibits
None.
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.
/s/ Alain Thieffry
Name/Title: Alain
Thieffry, Chief Financial Officer, and Chairperson
of the Board Date: May 27, 2016
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