Form SD

Form SD is the SEC disclosure form under which SEC-registered companies file their annual conflict minerals disclosures. Required by Exchange Act Section 13(p) and Rule 13p-1 (implementing Dodd-Frank Section 1502), Form SD must be filed annually by May 31 for the prior calendar year. Form SD requires companies to disclose: whether conflict minerals are necessary to the functionality or production of their products, the results of their Reasonable Country of Origin Inquiry (RCOI), and — if applicable — a Conflict Minerals Report describing due diligence measures.

SEC Exchange Act Section 13(p); SEC Rule 13p-1; Form SD (adopted August 22, 2012); SEC Final Rule on Conflict Minerals.

Form SD is the primary public disclosure mechanism for U.S. conflict minerals compliance. It must be filed electronically via the SEC’s EDGAR system by May 31 each year. Companies must decide whether their products contain conflict minerals that are ‘necessary to functionality or production’ — if yes, an RCOI is required. If the RCOI cannot determine origin (or finds DRC/adjoining country origin), a Conflict Minerals Report must be attached. Form SD disclosures are publicly available and reviewed by investors, customers, and NGOs.

A Fortune 500 consumer electronics company files its annual Form SD on May 31. It attaches a Conflict Minerals Report describing its OECD-aligned due diligence, listing 234 smelters identified in its supply chain, the countries of origin identified, and progress in engaging non-conformant smelters. The disclosure is posted on the company’s investor relations webpage.