UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549




FORM SD


Specialized Disclosure Report

Commission File Number 1-7573


PARKER DRILLING COMPANY
(Exact name of registrant as specified in its charter)



Delaware
73-0618660
(State or other jurisdiction of
incorporation or organization)
(I.R.S. Employer
Identification No.)
 
 
5 Greenway Plaza, Suite 100
Houston, Texas
77046
(Address of principal executive offices)
(Zip code)

Jon-Al Duplantier (281) 406-2000

(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 1to December 31, 2014.



Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure

Disclosure Requirement

This Disclosure for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities and Exchange Act of 1932 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC reporting companies whose manufactured products contain “Conflict Minerals” which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold. If a company can establish that its necessary Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) or from recycled or scrap sources, or if the company has no reason to believe that its necessary Conflict Minerals may have originated in the Covered Countries or reasonably believes that its necessary Conflict Minerals did come from recycled or scrap sources, it must disclose that determination, submitting a Form SD that includes a description of the Reasonable Country of Origin Inquiry it undertook in making its determination and the results of that inquiry.

The Company

This Disclosure has been prepared by management of Parker Drilling Company (the “Company”). Unless otherwise indicated, the terms “Company,” “Parker,” “we,” “us” and “our” refer to Parker Drilling Company, together with its subsidiaries. The information in this Disclosure includes the activities of all subsidiaries that are required to be consolidated.

The Company is an international provider of contract drilling and drilling-related services and rental tools. The Company currently operates in 23 countries. We own and operate drilling rigs and drilling-related equipment and also perform drilling-related services, referred to as Operations & Maintenance (“O&M”) work, for customer-owned drilling rigs on a contracted basis. We have extensive experience and expertise in drilling geologically difficult wells and in managing the logistical and technological challenges of operating in remote, harsh and ecologically sensitive areas. Our rental tools business supplies premium equipment to operators on land and offshore in the U.S. and select international markets. We have significant knowledge of the equipment needs of our customers and the logistical and product quality requirements of an effective rental tools supplier. We believe we are industry leaders in quality, health, safety and environmental practices.

Our business is currently comprised of three operating segments: (1) Rental Tools, (2) U.S. (Lower 48) Drilling, and (3) International and Alaska Drilling.




Reasonable Country of Origin Inquiry

We conducted an analysis of our business and determined that, even though we do not operate a specific manufacturing segment, we do, on occasion and as part of the services offered to our customers, manufacture products for sale and for the use of our customers. As part of our analysis, all manufactured products were assessed in order to identify Conflict Minerals scope and risk. Our analysis did not identify any Conflict Mineral or Conflict Mineral derivative other than tungsten that is contained as a necessary element to the functionality or production of any product manufactured for sale by the Company.

Based on this, the Company identified products for which tungsten was used as a necessary element to their functionality or production. Identified products containing tungsten as a necessary element to their functionality or production are:

Stabilizers; and
Whipstocks.

After performing this analysis, we conducted a reasonable country of origin inquiry (“RCOI”) to determine whether any of the tungsten used in our products originated in the Democratic Republic of the Congo or an adjoining country or whether such tungsten came from recycled or scrap sources. Because of the limited scope of the Company’s product manufacturing, we surveyed and received responses from each of the Company’s identified tungsten suppliers and identified their sources of tungsten as being either from scrap or recycled sources or from sources other than the Covered Countries. Each identified supplier also represented that the tungsten it provided to the Company was from scrap or recycled sources or from sources other than the Covered Countries. No such supplier provided any reason for the Company to believe that its Conflict Minerals originated in the Covered Countries.

Accordingly, based on the RCOI, the Company does not know or have reason to believe that Conflict Minerals necessary to the functionality or production of its products may have originated in the Covered Countries.

As a downstream purchaser of conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.

In accordance with the Rule, this Disclosure is available on the Company’s website at www.parkerdrilling.com.



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 undersigned thereunto duly authorized.

PARKER DRILLING COMPANY

Date: May 28, 2015    By: /s/ Jon-Al Duplantier
Jon-Al Duplantier
Senior Vice President, Chief
Administrative Officer and
General Counsel