TRK Speedway Motorsports Inc

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

(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:

☑ 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

A copy of the Speedway Motorsports, Inc. Conflict Minerals Report provided as Exhibit 1.01 hereto is publicly available at: http://phx.corporate-ir.net/phoenix.zhtml?c=99758&p=irol-govhighlights.

Item 1.02 Exhibit

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 - Exhibits

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

SIGNATURES

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 duly authorized undersigned.

Exhibit 1.01

SPEEDWAY MOTORSPORTS, INC.

Conflict Minerals Report

For the Year Ended December 31, 2014

Overview

On August 22, 2012, the U.S. Securities and Exchange Commission (the “SEC”) adopted final rules to implement reporting and disclosure requirements concerning Conflict Minerals, as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The rules regarding Conflict Minerals were enacted to further the humanitarian goal of ending violent conflict and human rights abuses in the Democratic Republic of the Congo and surrounding countries (referred to as the “Covered Countries”), which have been partially financed by the exploitation and trade of Conflict Minerals. In this Conflict Minerals Report, references to the “Company”, “SMI”, “we”, “us”, and “our” refer to Speedway Motorsports, Inc. and its subsidiaries.

Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) requires manufacturers that file reports with the SEC to determine whether the products they manufacture or contract to manufacture contain Conflict Minerals that are “necessary to the functionality or production” of their products. Conflict Minerals currently include cassiterite, columbite/tantalite and wolframite (the most common derivatives of which are tin, tantalum and tungsten, respectively) as well as gold, regardless of where these minerals are mined, processed or sold. (The U.S. Secretary of State may designate other minerals in the future.)

In accordance with guidance from the SEC, our due diligence practices have not been subject to an independent private sector audit. We will obtain such an audit in the future if and when one may be required by SEC rules and guidance.

This Conflict Minerals Report for the year ended December 31, 2014 is presented to comply with Rule 13p-1 and guidance issued by the SEC.

Company and Supply Chain Description

We are a leading promoter, marketer and sponsor of motorsports activities in the United States. We own and operate eight racing facilities in four of the top-ten media markets in the United States through our subsidiaries: Atlanta Motor Speedway, Bristol Motor Speedway, Charlotte Motor Speedway, Kentucky Speedway, Las Vegas Motor Speedway, New Hampshire Motor Speedway, Sonoma Raceway, and Texas Motor Speedway. We also:

We have an extensive supply chain with several tiers of suppliers between us and smelters or refiners. We rely on our suppliers at the top tier of our supply chain, that is, those with whom we have direct business relationships, to provide information regarding the origin of the Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to them from lower tier suppliers.

Due Diligence Measures Performed

Pursuant to the Company’s Conflict Minerals policy, the Company developed a due diligence framework utilizing the Organisation for Economic Co-operation and Development (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related supplements. The OECD framework is the only due diligence framework recognized by the SEC to date. The due diligence measures performed for the reporting year ended December 31, 2014 are summarized below.

Establish Strong Company Management Systems.

We believe that the ultimate goal of Section 1502 of the Dodd-Frank Act is for all SEC filers to be able to certify that all Conflict Minerals from Covered Countries that are contained in products they manufacture or contract to manufacture have come from smelters and refiners identified as “conflict free” through the Conflict-Free Smelter program (details at www.conflictfreesourcing.org). The Company supports the humanitarian goal of ending violent conflict and human rights abuses and the Company requires that all of its global suppliers support and comply with this effort.

The Company’s Conflict Minerals Policy is located on our website at http://phx.corporate-ir.net/phoenix.zhtml?c=99758&p=irol-govhighlights

We retain conflict mineral documentation in accordance with our existing corporate retention policy and procedures.

Identify and Assess Risk in the Supply Chain.

We inspected the components used in the manufacturing of our products to identify Conflict Minerals risk in our supply chain. We then communicated the Company’s policy regarding Conflict Minerals to direct suppliers that may pose a risk and delivered the standardized Conflict Minerals Reporting Template developed by the Conflict-Free Sourcing Initiative to facilitate the transfer of information through the supply chain regarding mineral country of origin and smelters and refiners being utilized as well as whether the minerals come from a recycler or scrap supplier. The Company also requested that our direct suppliers make similar inquires of their suppliers through the various supply chain tiers down to the smelter/refinery level.

The returned survey responses were reviewed and recorded.

Design and Implement a Strategy to Respond to Identified Risks.

We implemented a supplier engagement and follow up process to respond to questions and follow up with suppliers as needed. This process was utilized in a variety of circumstances, including when suppliers were late in responding, provided incomplete, inconsistent or confusing information or when other issues were identified. The follow up process included telephone calls and written requests for information.

We communicate identified risks to management of the Company, as appropriate.

Reliance on Independent Third-Party Audit of Supply Chain Due Diligence at the Smelter/Refiner Level.

We do not have direct relationships with Conflict Minerals smelters and refiners, and do not expect to perform or direct audits of these entities within our supply chain. We intend to rely on the published results of audits conducted by the Conflict-Free Sourcing Initiative and other recognized certification programs in order to comply with OECD guidance to conduct independent third party audits.

Report on Supply Chain Due Diligence.

Our Form SD and Conflict Minerals Report is located on our web site at www.speedwaymotorsports.com. They also have been filed with the SEC and will continue to be filed annually to the extent required by SEC rules.

Due Diligence Results 

As a result of the due diligence procedures summarized above, the Company received a survey response rate from identified direct suppliers of over 60%. Some of our suppliers were unable to provide the names of smelters/refiners and country of origin information for minerals they purchased or the minerals used in the components that they purchased from their suppliers and used in the production of their components. We intend to continue to work with our suppliers in the future to obtain and validate the names of smelters/refiners and related countries of origin that supply Conflict Minerals to us for our products.

Based on the survey results and related due diligence, we have been unable to determine the origin of all of the Conflict Minerals in our products, if any, and have concluded, therefore, that our Legend Cars are “DRC conflict undeterminable”. We expect that our assessment of Conflict Minerals risk, and our efforts to mitigate such risks, will be an evolving process as more information is made available to our suppliers and to us about our supply chain. If, through our future due diligence efforts, we discover that Conflict Minerals that cannot be confirmed as “DRC conflict free” have made their way into our products, we intend to engage the supplier, or an alternative supplier, to pursue responsible conflict-free sourcing for all products supplied to the Company.

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