Specialized Disclosure Report (sd)
23 Mai 2018 - 5:56PM
Edgar (US Regulatory)
UNITED
STATES
SECURITIES
AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM
SD
Specialized
Disclosure Report
WSI
Industries, Inc.
|
(Exact
name of registrant as specified in its charter)
|
Minnesota
|
|
000-00619
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41-0691607
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State
or other jurisdiction of incorporation or organization)
|
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(Commission
File
Number)
|
|
(IRS
Employer
Identification
No.)
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213
Chelsea Road
Monticello,
Minnesota
|
|
55362
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(Address
of principal executive offices)
|
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(Zip
Code)
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Paul
D. Sheely
(763)
295-9202
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(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, 2017
|
Section
1 – Conflict Minerals Disclosure
Item
1.01 Conflict Minerals Disclosure and Report
This
Form SD of WSI Industries, Inc. (the “Company”) is filed for the reporting period from January 1, 2017 to December
31, 2017 pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Rule”), and
in accordance with the Instructions to Form SD, as modified by the Updated Statement on the Effect of the Court of Appeals Decision
on the Conflict Minerals Rule issued by the SEC Division of Corporation Finance on April 7, 2017.
Conflict
Minerals Disclosure
About
WSI Industries’ Products
The
Company performs precision contract machining for customers in the aerospace/ avionics/ defense industries, automotive industry,
recreational powersports vehicles (ATV and motorcycle) markets, energy industry and bioscience industry. These components are
manufactured in accordance with customer specifications using materials both purchased by the Company as well as being supplied
by the customer.
In
accordance with Rule 13p-1, the Company reviewed its products and determined that conflict minerals were necessary to the functionality
or production certain products the Company manufactured or contracted to manufacture in the reporting period of January 1, 2017
to December 31, 2017 (the “covered products”). The Company relied upon determinations by its customers and suppliers
regarding whether the conflict minerals are necessary to the functionality or production of these products. These covered products
consist of certain engine components the Company manufactures for customers in its powersports business, which components contain
the conflict minerals of tungsten and tin.
Description
of Reasonable Country of Origin Inquiry
In
accordance with Rule 13p-1, the Company undertook a reasonable country of origin inquiry (“2017 RCOI”) to determine
whether the conflict minerals necessary to the functionality or production of the covered products were sourced from the Democratic
Republic of Congo or an adjoining country (the “Covered Countries”) or are from recycled or scrap sources.
The
2017 RCOI included the following steps:
●
|
The
Company identified the suppliers that provided the Company with the components, parts or other goods containing conflict minerals
included in the covered products, of which there were eight.
|
|
|
●
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The
Company solicited information from each of these suppliers regarding the country of origin of the conflict minerals within
the covered products using the Electronic Industry Citizenship Coalition-Global e-Sustainability Initiative (EICC-GeSI) Conflict
Minerals Common Reporting Template (the “Template”).
|
●
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The
Company reviewed the Template responses the Company received from the suppliers for completeness and consistency of answers.
Management followed-up with suppliers as needed to clarify responses.
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●
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The
Company’s senior management responsible for non-responsive suppliers personally contacted the suppliers in an attempt
to elicit responses.
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●
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The
suppliers’ responses to the Template and the Company’s contacts with the suppliers to develop conflict materials
related information were reported to senior management. Senior management also received updates on monitoring, tracking corrective
action and risk mitigation efforts.
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|
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●
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The
Company reviewed information generated in the course of the supply relationship to determine if there exist warning signs
or other circumstances indicating that conflict minerals originated or may have originated in the Covered Countries.
|
Results
of Reasonable Country of Origin Inquiry
The
2017 RCOI results are as follows:
●
|
Of
the eight suppliers, five suppliers reported through the Template that the components, parts or other goods that they supplied
for the covered products do not contain conflict minerals.
|
|
|
●
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Three
of the suppliers indicated through the Template that the components, parts or other goods that it supplied for the covered
products contain some or all of the conflict minerals. All three of the suppliers indicated through the Template that some
of the minerals did come from a Conflict Country, but also indicated that the smelters were compliant with the CFS program.
However, one supplier also indicated that for gold it was unknown as there was no publicly available, audit verified information
confirming that any gold refinery sources came from the covered countries.
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|
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●
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The
Company did not identify any warning signs or other circumstances indicating that, contrary to their responses through the
Template, conflict minerals in the covered products originated or may have originated in the Covered Countries.
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Website
Disclosure
A
copy of this Form SD is publicly available on the Company’s website at: http://www.wsiindustries.com/company/investor-relations.
Any
reference in this Form SD to the Company’s corporate website, and the contents thereof, is provided for convenience only;
such website and the contents thereof are not incorporated by reference into this Form SD nor deemed filed with the Securities
and Exchange Commission.
Item
1.02 Exhibit
Not
applicable.
Section
2 – Exhibits
Item
2.01 Exhibits
Not
applicable.
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.
WSI
INDUSTRIES, INC.
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/s/
Paul D. Sheely
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May
23, 2018
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By
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Paul
D. Sheely, Chief Financial Officer
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|
Date
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