UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D. C. 20549
FORM SD
Specialized Disclosure Report
Preformed
Line Products Company
(Exact name of registrant as specified
in its charter)
| Ohio |
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0-31164 |
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34-0676895 |
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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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| 660 Beta Drive, Mayfield Village, Ohio |
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44143 |
| (Address of principal executive offices) |
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(Zip Code) |
Caroline S. Vaccariello (440) 461-5200
(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, 2014. |
SECTION 1 – CONFLICT MINERALS DISCLOSURE
Item 1.01. Conflict Minerals Disclosure and Report.
Registrant has filed herewith a Conflict
Minerals Report as Exhibit 1.01 hereto.
Conflict Minerals Disclosure
Registrant’s Conflict Minerals Report
is available on the following publicly available Internet website: www.preformed.com.
Item 1.02. Exhibit.
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Exhibit
No. |
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Description |
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| 1.01 |
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Conflict Minerals Report. |
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 duly authorized undersigned.
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| PREFORMED LINE PRODUCTS COMPANY |
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| By: |
/s/Caroline S. Vaccariello |
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Date: June 1, 2015 |
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Caroline S. Vaccariello, |
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General Counsel & Corporate Secretary |
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Exhibit 1.01
Preformed Line Products Co.
Conflict Minerals Report
For the Year ended December 31, 2014
This disclosure for the year ended December
31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes
certain reporting obligations on SEC registrants whose manufactured products contain specific conflict minerals originating from
the Democratic Republic of the Congo or an adjoining country (“Covered Countries”). For the purposes of this report,
the Rule defines Conflict Minerals as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited
to tin, tantalum, tungsten and gold.
This disclosure has been prepared by the
management of Preformed Line Products Company (“PLPC”, the “Company”, “we” or “us”).
The information includes the activities of all of the Company’s majority owned subsidiaries.
The Company is an international designer
and manufacturer of products and systems employed in the construction and maintenance of overhead and underground networks for
the energy, telecommunication, cable operators, information (data communication), and other similar industries. Its primary products
support, protect, connect, terminate secure cables and wires. It also provides solar hardware systems and mounting hardware for
a variety of solar power applications. The Company has 17 sales and manufacturing operations in 15 different countries.
The Company’s products include:
| • | Formed Wire and Related Hardware Products |
| • | Data Communication Cabinets |
Formed Wire Products and Related Hardware
Products are used in the energy, communications, cable and special industries (i.e., metal building, tower and antenna industries,
the agriculture and arborist industries, and marine systems industry) to support, protect, terminate and secure both power conductor
and communication cables and to control cable dynamics (e.g., vibration). Protective Closures, including splice cases, are used
to protect fixed line communication networks, such as copper cable or fiber optic cable, from moisture, environmental hazards and
other potential contaminants. Data Communication Cabinets are products used in high-speed data systems to hold and protect electronic
equipment. Plastic Products, including guy markers, tree guards, fiber optic cable markers and pedestal markers, are used in energy,
communications, cable television and special industries to identify power conductors, communication cables and guy wires. Other
Products include hardware assemblies, pole line hardware, cable vibration control devices, resale products, underground connectors,
solar hardware systems and urethane products. They are used by energy, renewable energy, communications, cable and special industries
for various applications and are defined as products that complement the Company’s core line offerings.
| 3. | Inquiry and Due Diligence Efforts |
The Company initially reviewed its product
line to determine which products, if any, require a Conflict Mineral that is necessary to the functionality or production of the
product. This inquiry resulted in a determination that the only products of the Company that may potentially require a Conflict
Mineral are products that have certain fastener components, which the Company does not manufacture. These fastener components require
tin, one of the designated Conflict Minerals. Based on the Company’s review of its products, these fasteners are only found
in certain of our communication and energy products described above. Therefore, for purposes of this report, only the sources of
the fastener components of those products were considered further.
The Company does not have any direct relationships
with any tin smelter or refinery in its supply chain. As a downstream purchaser of fastener components that contain tin, our due
diligence measures can provide only reasonable, not absolute, assurance regarding the presence, source and chain of custody of
Conflict Minerals. The Company’s due diligence processes are based on the necessity of seeking data from its direct suppliers
and those suppliers seeking similar information within their supply chains to identify the original sources of the applicable Conflict
Minerals.
The Company contacted every direct supplier
of fasteners and required that they certify to the existence of Conflict Minerals in their product, as well as the origin of such
Conflict Minerals. In addition, the Company had all of its international subsidiaries contact their respective direct suppliers
with the same inquiry. The Company also communicated with direct suppliers on responses to supply chain surveys that it identified
as containing incomplete or potentially inaccurate information to seek additional clarifying information. The Company has regularly
engaged and continues to engage with any direct supplier for which it has not received a final response.
The Company is committed to sourcing components
and materials from companies that share in the Company’s values of respecting human rights. To that end, the Company is in
the process of determining the necessity of a policy on Conflict Minerals, requiring that all suppliers supply materials to the
Company that are “DRC conflict free.” In addition, the Company has integrated requirements for DRC Conflict Free within
its standard terms and conditions of purchase. The Company requires all direct suppliers to provide an annual survey using the
Electronic Industry Citizenship Coalition and the Global eSustainability Initiative Conflict Minerals Reporting Template, with
their annual supplier package. Additionally, the Company’s Legal Counsel, along with the Purchasing Group managers and Internal
Audit, continue to establish and evaluate the Company’s approach to its ongoing obligation for compliance with the Conflict
Minerals reporting requirements.
| 4. | Results of Due Diligence |
The Company has received supply chain survey
responses from approximately 97% of its fastener suppliers, both domestically and internationally. No supplier of fasteners that
contain tin has indicated that the Conflict Mineral originated from the Covered Countries; however, some have noted that they are
still working to determine definitive sources. Based on these responses, the Company cannot be certain that its products do not
contain Conflict Minerals from the Covered Countries or identify the facilities used to process the necessary Conflict Minerals
in those products until all of the final responses are received.
Until complete responses have been received
from the Company’s fastener suppliers, the Company cannot determine the country of origin, the facilities used for processing
or the mine or location of origin or otherwise complete the Company’s Conflict Minerals due diligence with respect to the
products described above that contain tin.
The Company will continue to take the following
steps in order to improve the number and completeness of supplier responses and oversight of the Company’s supply chain:
| · | Requiring that all suppliers submit an annual certification of their
uses of Conflict Minerals using a template based on the one available from the Electronic Industry Citizenship Coalition and the
Global eSustainability Initiative; |
| · | Communicating with suppliers whose responses are incomplete or inadequate,
in order to educate them on the necessity for clear information and reinforcing the value the Company places on such information; |
| · | Incorporating contractual terms with requirements related to Conflict
Minerals and responsible sourcing in the Company’s contracts with suppliers; and |
| · | Evaluating participation in industry groups and other initiatives
relating to Conflict Minerals. |
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