UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
IEH Corporation
(Exact name of the registrant
as specified in its charter)
New York
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0-5278
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13-5549348
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(State or other jurisdiction of
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(Commission
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(IRS Employer
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incorporation or organization)
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File Number)
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Identification No.)
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140 58
th
Street, Suite 8E
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Brooklyn, New York
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11220
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(Address of principle executive offices)
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(Zip code)
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Robert Knoth
Chief Financial Officer
Tel.: (718) 492-4448
(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:
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x
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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, 2013.
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Section 1 – Conflict
Minerals Disclosure
Item 1.01 – Conflict
Minerals Disclosure and Report
Introduction
This Specialized Disclosure Report
on Form SD of IEH Corporation (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange
Act of 1934, as amended, for the reporting period January 1, 2013 to December 31, 2013.
Rule 13p-1 (the “Rule”)
was adopted by the Securities and Exchange Commission (“SEC”) pursuant to the Dodd-Frank Wall Street Reform and Consumer
Protection Act of 2010 (“Dodd-Frank Act”) and requires disclosure of certain information when a company manufactures
or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production
of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives,
which are limited to tantalum, tin and tungsten (the “Conflict Minerals”). The “Covered Countries” for
the purposes of Rule 13p-1 are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South
Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (the “Covered Countries”). As described below, the Company
manufactures products for which the Conflict Minerals (specifically gold) are necessary to the functionality or production of those
products. The Rule excludes from its requirements Conflict Minerals that, prior to January 31, 2013, were located “outside
of the supply chain”, as that phrase is defined in the Rule.
Pursuant to the Rule, for products
which contain necessary Conflict Minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed
to determine whether any of the necessary Conflict Minerals originated in any of the Covered Countries. If, based on such
inquiry, the registrant knows or has reason to believe that any of the necessary Conflict Minerals contained in its products originated
or may have originated in a Covered Country and knows or has reason to believe that those necessary Conflict Minerals may not be
solely from recycled or scrap sources, the registrant must conduct due diligence as a method to conclude if the necessary Conflict
Minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries.
Background
The Company designs, develops and manufactures printed
circuit connectors for high performance applications. Customers served include the government, military, aerospace, medical, automotive,
industrial test equipment and commercial electronics market.
In its manufacturing process, the Company utilizes chemical
salts which are sourced from a single supplier. These salts contain gold and other chemicals. The salts are dissolved by the Company
in water using an electroplating process which extracts the gold from the liquefied salts. The Company then uses the gold to gold-plate
key components of the Company’s end-products. While there are other suppliers who distribute similar salts the Company make
its purchases of these chemical salts exclusively from one domestic supplier which has been the supplier to the Company for several
years, including prior to and after January 31, 2013. The Company also uses tin to manufacture its products. The Company itself
does not purchase gold or any other Conflict Minerals. The Company does not purchase any Conflict Minerals, including gold or tin,
directly from mines, smelters or refiners. The Company must rely on its suppliers to provide information regarding the origin of
Conflict Minerals that are included in the materials purchased from such supplier to use in the manufacture of the Company’s
end-use products.
As described above and below
in this Form SD, the Company has conducted a good faith and reasonable country of origin inquiry regarding the Conflict Minerals
that are necessary to the functionality or production of its products which are required to be reported on for the calendar year
ended December 31, 2013. In accordance with the Rule, this inquiry is limited to Conflict Minerals contained in components of its
products that were not outside of the supply chain prior to January 31, 2013. This good faith reasonable country of origin inquiry
was reasonably designed to determine whether any of these Conflict Minerals originated in the Covered Countries and whether any
of the Conflict Minerals may be from recycled or scrap sources. The Company’s supply chain for materials that constitute
Conflict Minerals with respect to its end-use products is not complex although there are different levels of third parties in the
supply chain between the Company, as the manufacturer of the end-products and the original sources of the Conflict Minerals. As
stated above, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company’s single
supplier of chemical salts containing gold does not either and must rely on its suppliers. The Company must therefore rely on its
suppliers and such suppliers’ suppliers to provide information regarding the origin of Conflict Minerals that are included
in the Company’s end-use products.
Reasonable Country of Origin
Inquiry
In performing its reasonable
country of origin inquiry for 2013, the Company performed a comprehensive analysis of its product components, and the role played
by its suppliers which provides materials containing Conflict Minerals. For the purpose of this Form SD, the Company’s reasonable
country of origin did not encompass an inquiry of Conflict Minerals contained in its products that, prior to January 31, 2013,
were outside of the Company’s supply chain (as such term is defined in Form SD). The Company’s reasonable country of
origin inquiry was overseen by the Company’s Chief Financial Officer and other members of its senior management team.
In conducting the reasonable
country of origin inquiry, the Company engaged in outreach to principal points of contact at its direct suppliers and in certain
cases indirect suppliers were contacted by the Company’s direct suppliers. The Company’s principal approach in carrying
out this inquiry was to request that its suppliers complete and return the Conflict Mineral Reporting Template of the Electric
Industry Citizenship Coalition and the Global e-Sustainability Initiative (the “Conflict Mineral Reporting Template”)
and/or seeking confirmation that the supplier has adopted procedures designed to ensure that any Conflict Minerals sold to the
Company did not originate in the Covered Countries. The Conflict Mineral Reporting Template enabled the Company to obtain information
from its suppliers regarding such entities’ conflict-free policies, engagement with their suppliers, the smelters used by
such suppliers and the origin of Conflict Minerals included in their products, as well as their due diligence efforts. Where the
Company did not receive complete responses to the Conflict Mineral Reporting Template from a supplier, the Company received written
representations from such suppliers as to the country of origin of the Conflict Minerals in the materials or components procured
from such supplier or indirect supplier. As warranted, the Company engaged in follow-up inquiries with its suppliers based on the
information provided to it either in the form of a Conflict Mineral Reporting Template or other written representation.
Since (i) the Company’s
reasonable country of origin inquiry allowed it to determine that it had no reason to believe that any of the Conflict Minerals
necessary for the functionality or production of its end-use products which are required to be reported on for 2013 may have originated
in any Covered Country and (ii) the Company is not required to report on any Conflict Minerals which, prior to January 31, 2013,
were outside of the supply chain, the Company determined that it was not required to undertake additional due diligence procedures
in accordance with the Rule. The Company conducted its reasonable country of origin inquiry in good faith, and believes that such
inquiry was reasonable to allow it to make its determination as reported in this Form SD.
Conflict
Minerals Disclosure
Based on its reasonable country
of origin inquiry, the Company concluded that it has no reason to believe that the Conflict Minerals necessary for the functionality
or production of products which are required to be reported on for the calendar year ended December 31, 2013 may have originated
in the Covered Countries.
This Form SD is publicly available
at
www.iehcorp.com/about/investors/
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Item 1.02 – Exhibit
Not required.
Section 2 – Exhibits
Item 2.01— Exhibits
Not applicable.
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.
(Registrant)
/s/
Robert Knoth
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June 2, 2014
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By: Robert Knoth
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(Date)
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Title: Chief Financial Officer
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IEH (PK) (USOTC:IEHC)
Gráfica de Acción Histórica
De May 2024 a Jun 2024
IEH (PK) (USOTC:IEHC)
Gráfica de Acción Histórica
De Jun 2023 a Jun 2024