UNITED
STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 205492015
FORM SD
Specialized Disclosure Report
(Exact name
of registrant as specified in its charter)
Jane
Grimm
Vice
President and Secretary
CompX International Inc.
Three
Lincoln Centre
5430 LBJ
Freeway, Suite 1700
Dallas,
Texas 75240-2620
(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
For the
calendar year 2022, we assessed whether any conflict minerals, as
defined in Item 1.01(d)(3) of Form SD, were necessary to the
functionality or production of a product we manufactured or
contracted to be manufactured. We determined that certain
conflict minerals were necessary to the functionality of products
we manufactured.
Accordingly, we conducted in good faith a reasonable country of
origin inquiry regarding the conflict minerals in our products for
the calendar year 2022. We designed our inquiry to determine
whether such 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, or were from recycled or scrap sources, as
defined in Item 1.01(d)(6) of Form SD. We sent a
certification letter to each of our vendors who were approved
vendors during 2022. We sent a total of 467 of such
certification letters (one to each vendor with a unique vendor
identification number within our computer systems). An
approved vendor may have more than one vendor identification number
because, among other things, the vendor may have multiple locations
and each location has a separate vendor identification
number. The certification letter required each recipient to
support one response and, if necessary, we followed-up with the
vendor in order to ensure we received a response. A summary
of the responses regarding each such vendor’s product is as
follows.
With
respect to the one response regarding conflict minerals originating
or possibly originating in the Democratic Republic of the Congo or
an adjoining company, we contacted the vendor. This vendor
provides products from the electronic component industry with
extensive product lines. We purchase relatively few item SKUs
compared to total vendor offerings. The vendor informed us
that they have made efforts to ensure conflict free sourcing,
expect suppliers to source responsibly, or are in various stages of
compliance. This vendor does not directly provide product
specific reports as to the sourcing of their conflict
minerals. These conditions create a level of uncertainty
related to the term “possibly originating” as it relates to the
specific products the registrant purchases from this vendor.
As a result (and even though we were able to satisfy ourselves, by
further researching the manufacturers sourced by this vendor, that
certain specific products sourced from this vendor did not fall
into the fourth category above), the registrant does not have
sufficient information to assess whether all of the products it
purchased from this vendor did not contain some amount of one or
more conflict minerals originating or possibly originating in the
Democratic Republic of the Congo or an adjoining country. The
total value of the registrant’s purchases from this vendor (not
including purchases from the vendors of products that we were able
to remove from the fourth category by further researching
manufacturers) represents an aggregate of 0.013% of total purchases
from all of the registrant’s vendors in 2022.
As used
above, “conformant sources” means sources conformant to the
assessment protocols for conflict-free sourcing of the Responsible
Minerals Initiative (RMI) or industry equivalent program.
Based on
the registrant’s good faith, reasonable country of origin inquiry,
the registrant does not know or have reason to believe that the
conflict minerals in the registrant’s products have originated from
the Democratic Republic of the Congo or an adjoining country.
This
Conflicts Minerals Disclosure is also posted on our website
at
https://compxinternational.com/governance/#conflict
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 undersigned hereunto duly authorized.