INRD Inrad Optics Inc (PK)

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

 

Specialized Disclosure Report

 

Inrad Optics, Inc.

(Exact name of the registrant as specified in its charter)

 

New Jersey	0-11668	22-2003247
(State or other jurisdiction of incorporation or organization)	(Commission File Number)	(IRS Employer Identification No.)

 

181 Legrand Avenue, Northvale, NJ	07647
(Address of principal executive offices)	(Zip code)

 

William J. Foote		[Phone]  201-767-1910
(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, 2014.

 

  

Section 1 – Conflict Minerals Disclosure

 

Item 1.01 Conflict Minerals Disclosure and Report

 

Introduction

 

Inrad Optics, Inc. and its subsidiaries (the “Company” or “Inrad Optics”), headquartered in Northvale, New Jersey, was incorporated in New Jersey in 1973. The Company develops, manufactures and markets products and services for use in photonics industry sectors via three distinct but complimentary product areas - "Crystals and Devices," "Custom Optics" and "Metal Optics." The Company is a vertically integrated manufacturer specializing in crystal-based optical components and devices, custom optical components from both glass and metal, and precision optical and opto-mechanical assemblies. Manufacturing capabilities include solution and high temperature crystal growth, extensive optical fabrication capabilities, including precision diamond turning and the ability to handle large substrates, optical coatings and provide in-process metrology.

 

Inrad Optics is committed to conflict free sourcing and complying with applicable laws affecting the Company’s industry. As such, the Company has worked to implement due diligence procedures in connection with the conflict minerals requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Company’s Conflict Minerals Statement is publically available on its Internet website at: http://www.inradoptics.com/facility-capabilities/quality-systems/quality-certifications

 

Reasonable Country of Origin Inquiry.

 

As conflict minerals (as defined in Item 1.01(d)(3) of Form SD, “Conflict Minerals”) are necessary to the functionality or production of a product manufactured by Inrad Optics, the Company has conducted in good faith a reasonable country of origin inquiry (“RCOI”) for calendar year 2014 to determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country (as defined in Item 1.01(d)(1) of Form SD, an “Adjoining Country”), or from recycled or scrap sources (as defined in Item 1.01(d)(6) of Form SD, “Recycled/Scrap Sources”).

 

Conflict Minerals Disclosure

 

Inrad Optics is concurrently filing the required Conflict Minerals Report, which is publically available on the Company’s Internet website at: http://www.inradoptics.com

 

Item 1.02 Exhibit

 

Inrad Optics, as an exhibit to this Form SD, is filing the Conflict Minerals Report required by Item 1.01 of Form SD.

 

Section 2 – Exhibits

 

Item 2.01 Exhibits

 

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD

 

 

SIGNATURES

 

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

 

Inrad Optics, Inc
(Registrant)
/s/ W.J. Foote		June 1, 2015
By William J. Foote, CFO, Secretary and Treasurer		Date

 

* * * * *

 

 

 

 

Exhibit 1.01

 

Inrad Optics, Inc.

Conflict Minerals Report

for the Reporting Period from January 1, 2014 to December 31, 2014

 

(1)

Introduction

 

Inrad Optics, Inc. and its subsidiaries (the “Company” or “Inrad Optics”), headquartered in Northvale, New Jersey, was incorporated in New Jersey in 1973. The Company develops, manufactures and markets products and services for use in photonics industry sectors via three distinct but complimentary product areas - "Crystals and Devices," "Custom Optics" and "Metal Optics." The Company is a vertically integrated manufacturer specializing in crystal-based optical components and devices, custom optical components from both glass and metal, and precision optical and opto-mechanical assemblies. Manufacturing capabilities include solution and high temperature crystal growth, extensive optical fabrication capabilities, including precision diamond turning and the ability to handle large substrates, optical coatings and provide in-process metrology.

 

Inrad Optics is committed to conflict free sourcing and complying with applicable laws affecting the Company’s industry. As such, the Company has worked to implement due diligence procedures in connection with the conflict minerals requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Company’s Conflict Minerals Statement is publically available on its Internet website at: http://www.inradoptics.com/facility-capabilities/quality-systems/quality-certifications

 

(2)

Reasonable Country of Origin Inquiry

 

As conflict minerals (as defined in Item 1.01(d)(3) of Form SD, “Conflict Minerals”) are necessary to the functionality or production of a product manufactured by Inrad Optics, the Company has conducted in good faith a reasonable country of origin inquiry (“RCOI”) for calendar year 2014 to determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country (as defined in Item 1.01(d)(1) of Form SD, an “Adjoining Country”), or from recycled or scrap sources (as defined in Item 1.01(d)(6) of Form SD, “Recycled/Scrap Sources”).

 

(3)

Due Diligence

 

"Inrad Optics,” "we," "our" and "us" are used interchangeably to refer to Inrad Optics, Inc. and its subsidiaries. The following is a description of the measures we took to exercise due diligence on the source and chain of custody of conflict minerals (as defined in Item 1.01(d)(3) of Form SD, “Conflict Minerals”) contained in our products manufactured during the 2014 calendar year.

 

As a first step, we determined that Conflict Minerals are contained in certain products manufactured by us, and that the Conflict Minerals are necessary to the functionality or production of certain products. Inrad Optics then conducted a supply chain survey of its applicable direct suppliers using the Electronic Industry Citizenship Coalition, Incorporated & Global e-Sustainability Initiative (“EICC/GeSI”) Conflict Minerals reporting template. We surveyed 15 direct suppliers identified as providing components that potentially contain Conflict Minerals during the 2014 calendar year and received responses from 13 or approximately 87%. These responses were summarized and evaluated and follow-up calls were made where additional clarification was required.

 

In furtherance of our supplier survey efforts, Inrad optics has worked to integrate into its supply chain management programs the Organization for Economic Co-operation and Development (“OECD”) five-step framework for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas. Our due diligence framework and compliance efforts are described below.

 

 

1.

Establish Strong Management Systems

 

In accordance with our due diligence framework and compliance efforts:

 

·

We have communicated to applicable suppliers our compliance efforts with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, pursuant to a compliance statement and other communications. We requested that our applicable suppliers provide a comprehensive Conflict Minerals declaration for all Conflict Minerals in the form of, or comparable to, the EICC/GeSI template.

·

We plan to communicate our compliance efforts to all new suppliers and provide annual compliance communications and RCOIs to applicable suppliers.

·

We have worked towards implementing internal compliance efforts, including internal reporting requirements, to support our supply chain due diligence process.

·

We are working towards implementing a process with new suppliers to screen their applicable components and identify where conflict minerals may exist.

·

We are currently designing and establishing a system of controls and supply chain transparency by employing due diligence tools created by EICC/GeSI, including supply chain surveys. As a downstream manufacturer, we rely on our suppliers to provide the origins of all Conflict Minerals, including smelter and mine locations, and transit routes. Based on our reasonable country of origin inquiry conducted in accordance with the EICC/GeSI template (“RCOI”), we could not determine smelter and mine locations, and transit routes, for all of our manufactured or contracted to manufacture products.

·

We plan to implement a risk mitigation response plan to address business relationships with suppliers that are DRC conflict undeterminable (as defined in Item 1.01(d)(5) of Form SD), which mitigation may include identifying an alternate supply. Our program will include adequate monitoring to adjust our strategies as sourcing data improves and new information is received.

 

2.

Identify and Assess Risks in Our Supply Chain

 

We identified risks at the product level by determining first whether the products contained Conflict Minerals necessary to the functionality or production of products that we manufacture.

 

We then identified the applicable supplier(s) relating to those products. As we progress, we expect that transparency in our supply chain will increase and that will allow for better risk assessment at more detailed levels of our supply chain. We intend to continue our communications with our suppliers regarding Conflict Minerals in order to endeavor to mitigate risks that the necessary Conflict Minerals identified in the products we manufacture could benefit armed groups in the Democratic Republic of the Congo or an adjoining country (as defined in Item 1.01(d)(1) of Form SD).

 

Based on assessed risks, our RCOI covered applicable suppliers.

 

3.

Design and Implement a Strategy to Respond to Identified Risks

 

We believe that our RCOI was reasonably designed and executed to determine the existence and source of Conflict Minerals in our supply chain, including recycled or scrap materials (as defined in Item 1.01(d)(6) of Form SD). We utilized the EICC/GeSI template for our RCOI, but also comparable forms of documentation accepted in the industry. We conducted our effort to send surveys in good faith and communicated directly with our suppliers throughout the process. We evaluated survey responses to identify: (i) the use and source of Conflict Minerals; and (ii) any warning signs indicating that Conflict Minerals may have come from the Democratic Republic of the Congo or an adjoining country. We made additional inquiries on a case-by-case basis to clarify or obtain more information as necessary. We tracked results of our supply chain diligence process and reported the results to our executive leadership team.

 

 

We do not have sufficient information, based on the survey responses received, to determine each of the specific facilities used to process Conflict Minerals or to identify specific countries of origin for the Conflict Minerals used in all of our products.

 

4.

Implement Targeted Independent Third-Party Due Diligence

 

We are in support of industry initiatives which encourage smelters and have targeted suppliers and/or facilities to participate in comparable due diligence validation activities.

 

5.

Report on Supply Chain Due Diligence

 

We have developed a company policy and will continue to communicate with our suppliers. Management’s conflict minerals compliance and due diligence efforts will be reported on an annual basis and will be available on the company website at http://www.inradoptics.com. Further, we have responded to customer requests for information regarding our Conflict Minerals determination when requested and will continue to do so.

 

Conclusion

 

Based on a “reasonable country of origin inquiry” (RCOI), we are unable to determine if the necessary conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (collectively, referred to as the “Covered Countries”) and financed or benefited armed groups in those countries or if those necessary conflict minerals were from recycled or scrap sources.

 

This report was not subjected to an independent private sector audit as allowed under Rule 13p-1.