UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
PHOTRONICS, INC.
(Exact name of registrant as specified in its charter)
15 Secor Road
Brookfield, CT 06804
(Address of principal executive offices, including zip code)
Richelle E. Burr
(203) 775-9000
(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:
Section 1 – Conflict Minerals Disclosure
Item 1.01 – Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
In order to comply with Rule 13p-1 (17 CFR 240.13p-1) under Section 13(p) of the Securities Exchange Act of 1934, as amended, Photronics, Inc. (the “Company”) submits this § 249b.400 Form SD, specialized disclosure report (“Form SD”). As defined
in Form SD, the term “conflict mineral” means columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, or any other mineral or its derivatives determined by the Secretary
of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (as defined in Form SD).
The Company has determined that tantalum is a conflict mineral which is necessary to the functionality or production of certain products manufactured by the Company.
The Company has conducted a good faith, reasonable country of origin inquiry with respect to the tantalum used in the Company’s products for the calendar year ended December 31, 2019, which such inquiry was reasonably designed to determine
whether any of the conflict minerals originated in the Democratic Republic of the Congo or any adjoining country (as defined in Form SD). Based on this country of origin inquiry, the Company has no reason to believe that any of the tantalum
necessary to the functionality or production of products manufactured by the Company in 2019 originated in the Democratic Republic of the Congo or any adjoining country (as defined in Form SD) unless they originated from recycled or scrap sources
(as defined in Form SD) or from sources which have been assessed and approved by independent, internationally recognized, and reputable third parties.
In order to make its determination with respect to the country of origin of its tantalum, the Company undertook the following inquiry:
This conflict minerals disclosure is available on the Company’s website at www.photronics.com.
Item 1.02 – Exhibit
Not applicable.
Item 2.01 – Exhibits
SIGNATURE
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.
Date: June 1, 2020