Specialized Disclosure Report (sd)
May 28 2021 - 8:00AM
Edgar (US Regulatory)
UNITED
STATES
SECURITIES
AND EXCHANGE COMMISSION
Washington,
D.C. 20549
FORM
SD
Specialized
Disclosure Report
WIRELESS
TELECOM GROUP, INC.
(Exact
name of registrant as specified in its charter)
New
Jersey
|
|
001-11916
|
|
22-2582295
|
(State
or other jurisdiction
of incorporation)
|
|
(Commission
File
Number)
|
|
(IRS
Employer
Identification
No.)
|
25
Eastmans Road Parsippany, New Jersey 07054
(Address
of principal executive offices) (Zip Code)
Michael
J. Kandell
Chief
Financial Officer
(973)-386-9696
(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, 2020.
|
SECTION
1 – Conflict Mineral Disclosure
Item
1.01 Conflict Mineral Disclosure and Report
OVERVIEW
Wireless
Telecom Group, Inc., a New Jersey corporation, together with its subsidiaries (“we”, “us”, “our”
or the “Company”), specializes in the design and manufacture of advanced radio frequency (“RF”) and microwave
devices which enable the development, testing and deployment of wireless technology. The Company provides unique, highly customized
and configured solutions which drive innovation across a wide range of traditional and emerging wireless technologies.
Our
products include components, modules, instruments, systems and software used across the lifecycle of wireless connectivity and
communication development, deployment and testing. Our customers use these products in relation to commercial infrastructure development,
the expansion and upgrade of distributed antenna systems, deployment of small cell technology, use of medical devices and private
long-term evolution (“LTE”) and 5G networks. In addition, the Company’s products are used in the development
and testing of satellite communication systems, radar systems, semiconductor devices, automotive electronics and avionics.
The
purpose of this Form SD is to provide information pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities
Exchange Act of 1934, as amended (the “Act”). The Rule relates to the disclosure of certain information relating to
“conflict minerals,” which are defined in the rule as gold, columbite-tantalite (coltan), cassiterite and wolframite,
and their derivatives of tantalum, tin and tungsten (referred to in this Form SD as “3TG”).
The
products we manufacture contain multiple parts and materials from a wide array of direct and indirect suppliers from around the
world. There are typically multiple tiers of suppliers between the origin of the 3TG (mines and smelters) and our direct suppliers.
Because we are a downstream purchaser of raw materials and components, we must rely on our direct suppliers to work with their
upstream suppliers to obtain information about the origin of the 3TG contained in the products we manufacture or contract to manufacture.
WTT manufacturing processes consist primarily of using manufactured components and assemblies from our direct suppliers and integrating
them into system level solutions, instruments and components.
REASONABLE
COUNTRY OF ORIGIN INQUIRY
We
conducted an analysis of the products and components we assembled during the 2020 calendar year and concluded that certain 3TG
was necessary to the manufacture or functionality of those products and components. Accordingly, we conducted a reasonable country
of origin inquiry (“RCOI”) to determine if any of the 3TG originated from the Democratic Republic of the Congo (DRC)
or any adjoining countries (those and the DRC collectively referred to as “Covered Countries”) or if the 3TG was from
recycled or scrap sources.
WTT’s
RCOI process included conducting an inquiry using the RBA-GeSI Conflict Minerals Reporting Template (the “Template”)
developed by the Responsible Minerals Initiative (“RMI”). We provided the Template to all of our direct suppliers
and asked that they complete the template and return it to us for analysis. We conducted follow up with suppliers where information
was missing or responses were absent.
Based
on our RCOI, we concluded that we did not have sufficient reason to believe that all 3TG materials in our supply chain did not
originate in a Covered Country or were from recycled or scrap sources. Accordingly, the Company further pursued its supply chain
inquiry and conducted due diligence on that supply chain as required by the Rule. There was significant overlap between our reasonable
country of origin inquiry efforts and our due diligence efforts.
Consistent
with the statement of the staff of the Securities and Exchange Commission made public on April 7, 2017, WTT is not filing a conflict
minerals report with this Form SD.
This
Form SD is publicly available on our website at http://www.wirelesstelecomgroup.com/investor-relations under the heading
“Conflict Minerals Disclosure”.
Item
1.02 Exhibits
Not
Required
Section
2 –Exhibits
Item
2.01 Exhibits
None
SIGNATURES
Pursuant
to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed
on its behalf by the undersigned hereunto duly authorized.
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WIRELESS
TELECOM GROUP, INC.
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|
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Date:
May 28, 2021
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By:
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/s/
Michael J. Kandell
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Michael
J. Kandell
|
|
|
Chief
Financial Officer
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