SEC Filing Html Data
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 205492015
FORM SD
Specialized Disclosure Report
CompX International Inc.
(Exact name of registrant as specified in its charter)
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Delaware
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1-13905
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57-0981653
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(State or other jurisdiction of incorporation)
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(Commission
File Number)
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(IRS Employer
Identification No.)
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5430 LBJ Freeway, Suite 1700, Dallas, Texas
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75240-2620
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(Address of principal executive offices)
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(Zip Code)
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Jane Grimm
Vice President and Secretary
CompX International Inc.
Three Lincoln Centre
5430 LBJ Freeway, Suite 1700
Dallas, Texas 75240-2620
(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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ý
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Rule 13p-1 under the Securities Exchange Act (17 CFR
240.13p-1) for the reporting period from January 1 to December 31, 2018
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Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
For the calendar year 2018, 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 2018. 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 2018. We sent a total of 476 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.
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Category of Description of the Certification Regarding the Vendor’s Provided Products
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Number of Vendors Responding by Category
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Percentage of Vendors Responding by Category
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Contained no amount of conflict minerals
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365
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76.7%
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Contained some amount of conflict mineral(s) but all such conflict mineral(s) came from recycled or scrap sources
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13
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2.7%
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Contained some amount (including de
minimis amounts) of one or more conflict mineral(s), but such conflict mineral(s) did not originate in the Democratic Republic of the Congo or an adjoining country
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97
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20.4%
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Contained some amount (including de
minimis amounts) of one or more conflict mineral(s), with such conflict mineral(s) originating or possibly originating in the
Democratic Republic of the Congo or an adjoining country
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1
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0.2%
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Total
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476
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100.0%
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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 0.017% of total purchases from all
of the registrant’s vendors in 2018.
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
http://compxinternational.gcs-web.com/conflict-minerals-disclosure
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.
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CompX International Inc.
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(Registrant)
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By: /s/ Jane Grimm
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Date: May 29, 2019
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Jane Grimm
Vice President and Secretary
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