UNITED
STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
__________________
Form SD
__________________
Specialized Disclosure Report
Allot Ltd.
(Exact
name of the registrant as specified in its charter)
Israel
(State or other
jurisdiction of incorporation)
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001-33129
(Commission
file number)
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22
Hanagar Street
Neve
Ne’eman Industrial Zone B
Hod-Hasharon 4501317
Israel
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(Address of principal
executive offices and zip code)
Rael
Kolevsohn
General
Counsel
Tel
+972-9-7619200
(Name and
telephone number, including area code, of the person to contact in
connection with this report)
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Check the appropriate box to
indicate the rule pursuant to which this form is being filed:
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☒
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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, 2021.
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☐
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Rule 13q-1 under the Securities
Exchange Act (17 CFR 240.13q-1) for the fiscal year ended
___________.
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SECTION 1 –
CONFLICT MINERALS DISCLOSURE
Item 1.01
Conflict Minerals Disclosure and Report
Introduction
This
Specialized Disclosure Form (“Form SD”) of Allot Ltd. (the
“Company,” “we,” or “us”) is filed pursuant to Rule 13p-1 (the
“Rule”) promulgated under the Securities Exchange Act of 1934, as
amended (the “Exchange Act”), for the reporting period from January
1 to December 31, 2021.
The Rule
requires disclosure of certain information when a company
manufactures or contracts to manufacture products (“Covered
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 (collectively, the “Conflict
Minerals”), that originated in the Democratic Republic of the Congo
(“DRC”) and certain adjoining countries (collectively with the DRC,
the “Covered Countries”).
For the
Covered Products, the registrant must conduct in good faith a
reasonable country of origin inquiry designed to determine whether
any of the Conflict Minerals originated in the Covered
Countries. If, based on such inquiry, a registrant knows or
has reason to believe that any of the Conflict Minerals contained
in its Covered Products originated or may have originated in a
Covered Country and that such Conflict Minerals are not or may not
be solely from recycled or scrap sources, the registrant must
conduct due diligence with respect to the source and chain of
custody of the Conflict Minerals to determine the origin of such
Conflict Minerals and whether they directly or indirectly financed
or benefited armed groups in the Covered Countries.
Conclusion Based on Reasonable Country of Origin Inquiry
In accordance
with the Rule, the Company has concluded in good faith that during
the year ended December 31, 2021:
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Certain of the
Company’s operations manufactured, or contracted to manufacture,
Covered Products for which the Conflict Minerals are necessary to
the functionality or production of those products.
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Based on the
Company’s good faith reasonable country of origin inquiry regarding
the Conflict Minerals, which was designed to determine whether any
of the Conflict Minerals contained in the Company’s Covered
Products originated in the Covered Countries and whether any of the
Conflict Minerals contained in the Covered Products are or may be
from recycled or scrap sources, the Company had reason to believe
that (i) the Conflict Minerals contained in its Covered Products
may have originated in the Covered Countries and (ii) such Conflict
Minerals may not be from recycled or scrap sources.
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On the basis
of these conclusions, the Company proceeded to exercise due
diligence with respect to the source and chain of custody of the
Conflict Minerals contained in its Covered Products. The Conflict
Minerals Report describing the Company’s due diligence efforts is
attached as Exhibit 1.01 to this Form SD for the reporting period
from January 1 to December 31, 2021. This Conflict Minerals
Report has not been subject to an independent private sector
audit.
Countries of
origin identified as a result of the Company’s reasonable country
of origin inquiry include, to the extent known, India, United Arab
Emirates, United States of America, Republic of Korea, Uganda,
Lithuania, Italy, Chile, Germany, Australia, Russian Federation,
Malaysia, Zambia, South Africa, Austria, Andorra, France,
Kazakhstan, Brazil, Belgium, Netherlands, Sudan, China (Mainland),
Taiwan, Zimbabwe, Poland, Thailand, Czech Republic, New Zealand,
Japan, Switzerland, Spain, Canada, Indonesia, Uzbekistan, Turkey,
Mexico, Singapore, Saudi Arabia, Kyrgyzstan, Sweden, Philippines,
Macedonia, Myanmar, Vietnam, Bolivia, Peru and
Estonia.
Conflict Minerals Disclosure
A copy of the
Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this
Form SD, and is publicly available on the Company’s website at
https://investors.allot.com/financial-information/sec-filings.
Unless otherwise stated in this Form SD and the Conflict Minerals
Report filed as Exhibit 1.01 hereto, any documents, third-party
materials or references to websites (including the Company’s) are
not incorporated by reference in, or considered to be a part of,
this Form SD and the attached Conflict Minerals Report.
Forward-Looking Statements
In addition to
historical facts, this Form SD and the attached Conflict Minerals
Report contain forward-looking statements within the meaning of
Section 27A of the U.S. Securities Act of 1933, as amended, Section
21E of the U.S. Securities Exchange Act of 1934, as amended, and
the safe harbor provisions of the U.S. Private Securities
Litigation Reform Act of 1995. We have based these forward-looking
statements on our current expectations and projections about future
events. Forward-looking statements include all statements that are
not historical facts and can be identified by terms such as
“anticipates,” “believes,” “could,” “seeks,” “estimates,”
“expects,” “intends,” “may,” “plans,” “potential,” “predicts,”
“projects,” “should,” “will,” “would” or similar expressions that
convey uncertainty of future events or outcomes and the negatives
of those terms. All forward-looking statements in this Form SD and
the attached Conflict Minerals Report reflect our current views
about future events, are based on assumptions and are subject to
risks and uncertainties that could cause our actual results to
differ materially from future results expressed or implied by the
forward-looking statements. Many of these factors are beyond our
ability to control or predict. Important factors that could cause
actual outcomes to differ materially from those contained in any
forward-looking statement include those described in the Company’s
reports, including its annual report on Form 20-F for the fiscal
year ended December 31, 2021, and other forms filed by the Company
with or furnished by the Company to the Securities and Exchange
Commission. You should not put undue reliance on any
forward-looking statements. Unless we are required to do so under
U.S. federal securities laws or other applicable laws, we do not
intend to update or revise any forward-looking statements.
Item 1.02
Exhibit
As specified
in Section 3, Item 3.01 of this Form SD, the Company is hereby
filing its Conflict Minerals Report as Exhibit 1.01 to this Form
SD.
SECTION 2 –
RESOURCE EXTRACTION ISSUER DISCLOSURE
Item 2.01
Resource Extraction Issuer Disclosure and Report
Not applicable.
SECTION 3 –
EXHIBITS
Item 3.01
Exhibits
The following exhibit is filed as
part of this report.
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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By:
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/s/ Rael Kolevsohn
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May 24, 2022
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Rael Kolevsohn,
General Counsel
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[Signature Page
to Form SD]