Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This report for the year ended December 31, 2023 has been prepared by management of Chicago Rivet & Machine Co. (the
Company, we, us, and our) to comply with Section 13(p) of the Securities Exchange Act of 1934, as amended, and Rule 13p-1 (the Rule) promulgated
thereunder. The Rule was adopted by the Securities and Exchange Commission (SEC) as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and imposes certain reporting obligations on SEC registrants whose
manufactured products contain so-called conflict minerals that are necessary to the functionality or production of those products. As used in this report, the term conflict minerals
includes columbite-tantalite, cassiterite, gold, wolframite, and their derivatives tantalum, tin and tungsten.
A copy of this report is
made available on our website at www.chicagorivet.com, under the heading Investor Relations. The website and the information accessible through it are not incorporated into this specialized disclosure report.
Company Overview
The Company operates in
two segments of the fastener industry: fasteners and assembly equipment. The fastener segment consists of the manufacture and sale of rivets, cold-formed fasteners and parts and screw machine products. The assembly equipment segment consists
primarily of the manufacture of automatic rivet setting machines, automatic assembly equipment and parts and tools for such machines.
For
the year ended December 31, 2023, we determined that the plating of certain products in the fastener segment contained tin and that our rivet setting machines include electronic components that also may contain conflict minerals. As required by
the Rule, we conducted a reasonable country of origin inquiry to determine whether those conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (collectively, Covered Countries).
Reasonable Country of Origin Inquiry
Because there are multiple tiers between us and the mines from which conflict minerals are sourced, we rely on the information provided by our
direct suppliers to determine the origin of the conflict minerals contained in the components and materials supplied to us, including the conflict minerals provided to our suppliers from sub-tier suppliers.
Accordingly, the methods we used to determine the origin of those conflict minerals included the following:
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Sending letters to our direct suppliers, explaining the Rule and referring the suppliers to online training
materials and instructions available on the Conflict Free Sourcing Initiatives website (www.conflictfreesourcing.org). |
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Soliciting survey responses from our direct suppliers, using the standard Conflict Minerals Reporting Template
designed by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI). This template has been widely adopted to assist companies in their due diligence processes
related to conflict minerals. The template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a companys supply chain. It includes questions regarding a companys
conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in suppliers products, as
well as supplier due diligence. |
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Reviewing responses that we received from our suppliers and following up on inconsistent, incomplete and vague
responses. |
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Sending reminders to suppliers who did not respond to our surveys, encouraging them to respond.
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