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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C.   20549

FORM SD

Specialized Disclosure Report

(Exact name of registrant as specified in its charter)

 

A. Andrew R. Louis

Vice President and Secretary

CompX International Inc.

Three Lincoln Centre

5430 LBJ Freeway, Suite 1700

Dallas, Texas  75240-2697

(972) 233-1700

(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:

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Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

For the calendar year 2014, 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 2014.  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 2014.  We sent a total of 482 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 check 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, the registrant contacted the vendor.  The vendor informed the registrant that it had used a third party to perform an analysis regarding the vendor's conflict minerals and their sources over all of the vendor's business units as a whole rather than the two items that the registrant purchased from the vendor in 2014.

As a result, the registrant does not have sufficient information to assess whether the two products it purchased from the vendor contained some amount of one or more conflict minerals originating or possibly originating in the Democratic Republic of the Congo or an adjoining country.  Additionally, in 2014 the total value of the registrant's purchases from this vendor was 0.003% of the total purchases from all of the registrant's vendors. The registrant stopped purchasing from this vendor in 2014.

With respect to the 23 responses regarding conflict minerals of undeterminable origin, the registrant's aggregate dollar amount purchased from the vendors in this category, was approximately 6.1% of the aggregate dollar amount of all of the registrant's purchases from its vendors in 2014, which vendors represented 482 vendor identification numbers in total.

This Conflicts Minerals Disclosure is also posted on our website at

http://phx.corporate-ir.net/External.File?item=UGFyZW50SUQ9Mjg5MTg1fENoaWxkSUQ9LTF8VHlwZT0z&t=1.

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.