Specialized Disclosure Report (sd)
May 19 2016 - 1:38PM
Edgar (US Regulatory)
UNITED
STATES
SECURITIES AND
EXCHANGE COMMISSION
Washington, D.C. 20549
FORM
SD
Specialized Disclosure
Report
QUANTUM
CORPORATION
(Exact name of
registrant as specified in its charter)
Delaware
(State or other jurisdiction of incorporation or
organization)
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1-3449
(Commission File Number)
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94-2665054
(I.R.S. Employer Identification No.)
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224 Airport
Parkway, Suite 300, San Jose, California
(Address of principal executive offices)
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95110
(Zip
Code)
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Garry Felker
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(949) 856-7897
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(Name and telephone number, including area
code, of the person to contact in connection with this
report.)
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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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☒
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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,
2015.
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Section 1 Conflict
Minerals Disclosure
Item 1.01 Conflict
Minerals Disclosure and Report
Quantum Corporation
(Quantum) has evaluated its current products and determined that certain
products we manufacture or contract to manufacture contain tin, tungsten,
tantalum and/or gold (3TG). Based on the outcome of our due diligence
procedures, we have filed a Conflict Minerals Report herewith.
Reasonable Country of
Origin Inquiry (RCOI)
Following our initial
determination that certain of our hardware products contain components that
contain 3TG minerals, Quantum conducted an RCOI to determine which components
contain 3TG minerals and whether such 3TG minerals originated in the Democratic
Republic of the Congo and adjoining countries (the Covered Countries). Our
RCOI was based on a survey of our direct suppliers of parts, components and
assemblies containing conflict minerals. We have identified over 200 direct
suppliers that supply components for our products that may contain 3TG minerals.
We requested that each of these 200 suppliers complete the EICC GeSI conflict
minerals reporting template. We do not have a direct relationship with any of
the smelters or refiners of the 3TG materials. Accordingly, we rely on our
suppliers to provide us with information about the source of conflict minerals
contained in the components supplied to us based on the EICC GeSI conflict
minerals reporting template. Our direct suppliers are similarly reliant upon
information provided by their suppliers. Many of the largest suppliers are also
SEC registrants and subject to Rule 13p-1.
Over 75% of our suppliers
responded. Based on those responses, Quantum determined that 3TG minerals
present in certain of its products may have originated in the Covered Countries
and were not from scrap or recycled sources. Therefore, in accordance with Rule
13p-1, Quantum proceeded to engage in due diligence regarding the sources and
chain of custody of its 3TG minerals and has completed a Conflict Minerals
Report, filed herewith.
Conflict Minerals
Disclosure
A copy of the Companys
Conflict Minerals Report is provided as Exhibit 1.02 hereto and is publicly
available Companys website at
http://www.quantum.com
, where
the document may be found by clicking About Us from the home page, selecting
Investor Relations and then clicking on Corporate Documents.
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
Item 2.01 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.
QUANTUM CORPORATION
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/s/ SHAWN
HALL
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Shawn Hall
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Senior Vice President and General
Counsel
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Date: May 19,
2016
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