MPX Marine Products Corp

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

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FORM SD

Specialized Disclosure Report

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MARINE PRODUCTS CORPORATION

(Exact name of registrant as specified in its charter)

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2801 Buford Highway NE, Suite 300, Atlanta, Georgia 30329

(Full mailing address of executive offices)

(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 the form is being filed, and provide the period to which this form is being filed:

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Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Specialized Disclosure Form (Form SD) of Marine Products Corporation and its subsidiaries (“Marine Products” or “the Company”) is filed pursuant to Rule 13p-1 (the “Rule”) of the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. Additional information is required where the Company has reason to believe that the minerals originated in the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (collectively, the “Covered Countries”). The specified minerals are gold, columbite-tantalite (coltan), cassiterite, and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”).

In accordance with the Rule, the Company evaluated its products and determined that during calendar year 2023 certain products it contracted to manufacture may have contained tin, tungsten, tantalum and/or gold (“3TG”). As required by the Rule, the Company conducted a good faith reasonable country of origin inquiry regarding the Conflict Minerals by sending a questionnaire adapted from the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative (“EICC/GeSI”) Conflict Minerals Reporting Template to all the direct suppliers of products that may contain Conflict Minerals. The EICC/GeSI Template is designed to confirm the use of Conflict Minerals in the covered products, to identify the source of the Conflict Minerals, and to determine whether any of the Conflict Minerals originated in the Covered Countries, or from recycled, or scrap sources.

Conflict Minerals Disclosure

The Company’s Conflict Minerals Report is filed as an exhibit herewith and is available on the Company’s website at www.marineproductscorp.com under the Governance section.

Item 1.02 Exhibit

Conflict Minerals Report required by Item 1.01 is filed as an exhibit to this Form SD.

Section 3 – Exhibits

Item 3.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.  

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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.

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EXHIBIT 1.01

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CONFLICT MINERALS REPORT

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This report has not been subject to an independent private sector audit.

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Marine Products Corporation (“Marine Products” or “the Company”) manufactures fiberglass motorized boats distributed and marketed through its independent dealer network. Marine Products’ product offerings include Chaparral sterndrive, outboard and Robalo outboard sport fishing boats.

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“Conflict Minerals” or “3TG” are gold, columbite-tantalite (coltan), cassiterite, wolframite or their derivatives, which are limited to tantalum, tin, and tungsten.  “Covered Countries” are the Democratic Republic of the Congo (DRC) and certain adjoining countries.

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Marine Products does not purchase raw ore or unrefined Conflict Minerals directly from mines, smelters or refiners and makes no direct purchases of any minerals in the Covered Countries. The Company’s supply chain with respect to the products that use Conflict Minerals is complex, with intermediaries and third parties in the supply chain between the manufacture of products and the original sources of Conflict Minerals. The Company must therefore rely on its suppliers to provide information on the origin of the 3TG contained in components and materials supplied, including sources of 3TG that are supplied to them from their suppliers (i.e., second-tier suppliers). The Company surveyed 100 percent of its direct suppliers of raw materials and components.  This risk-based approach is consistent in all material aspects with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold and for tin, tantalum and tungsten.

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Marine Products conducted a survey of the direct suppliers of all the products used in the manufacture of its boats. We used the Conflict Minerals Reporting Template (“CMRT”) published by the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative (“EICC/GeSI”) Conflict Free Sourcing Initiative (“CFSI”).  CMRT maintains a list of smelters that have received a conflict free designation from the CFSI.  All smelter information provided by the vendors is compared against the list maintained by CMRT.

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The Company received responses from 35 percent of the suppliers surveyed; 19 percent confirmed that 3TG is used in their products and the results are as follows:

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Some of the challenges that we encountered when we obtained the responses were as follows:

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The products that the Company contracts to have manufactured which contain Conflict Minerals are described below:

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