Specialized Disclosure Report (sd)
21 May 2020 - 5:45AM
Edgar (US Regulatory)
UNITED
STATES
SECURITIES
AND EXCHANGE COMMISSION
Washington,
D.C. 20549
FORM
SD
Specialized
Disclosure Report
RBC
Bearings Incorporated
(Exact
name of registrant as specified in its charter)
Delaware
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333-124824
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95-4372080
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(State
or other jurisdiction
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(Commission
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(IRS
Employer
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of
incorporation or organization)
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File
Number)
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Identification
No.)
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One
Tribology Center
Oxford, CT
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06478
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(Address
of principal executive offices)
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(Zip
Code)
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Joseph
Salamunovich, (203) 267-7001
(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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Rule 13p-1 under the Securities Exchange Act
(17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.
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Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
RBC Bearings Incorporated (the “Company”) determined
that certain conflict minerals, namely tin, tantalum and tungsten, are necessary to the functionality or production of certain
products manufactured, or contracted to be manufactured, by the Company and are required to be reported in the 2019 calendar year
covered by this specialized disclosure report. The Company conducted in good faith a reasonable country of origin inquiry regarding
those conflict minerals that was reasonably designed to determine whether any of the conflict minerals originated in the Democratic
Republic of the Congo or included adjoining countries, or are from recycled or scrap sources.
Conflict Minerals Disclosure
Based on a reasonable country of origin inquiry, the Company
has no reason to believe that such necessary conflict minerals may have originated in the Democratic Republic of the Congo or an
included adjoining country.
The Company’s reasonable
country of origin inquiry was based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected
and High-Risk Areas. The Company made inquiry to all necessary purchasing and product engineering personnel at all its divisions
and subsidiaries worldwide to review material content data forms, product and component engineering specifications, bills of materials,
product part codes, material certifications received and published industry material specifications to determine the metal composition
of products and product components that were being manufactured or contracted to be manufactured by the Company as well identification
of vendor information.
It was determined that the Company does not utilize gold in
any of the products it manufactured or contracted to be manufactured. Raw materials and components
containing tin, tantalum and tungsten were identified and all of the Company’s divisions and subsidiaries were asked to provide
vendor information for purchases of such raw materials or components containing these metals and utilized in products manufactured
or contracted to be manufactured by the Company.
The Company has an enterprise license
to utilize an industry accepted standard system that is tailored to track the requests sent out to vendors and follow up on requests
that were not answered in a timely manner. These requests asked the Company’s vendors to complete the Responsible Minerals
Initiative (“RMI”), (formerly the Conflict-Free Sourcing Initiative) reporting template, a standardized reporting template
developed by the RMI, an initiative of the Responsible Business Alliance and the Global e-Sustainability Initiative, which facilitates
the transfer of relevant and necessary information through the supply chain regarding mineral country of origin and smelters and
refiners being utilized.
Requests were sent to vendors supplying
the Company’s divisions and subsidiaries with raw materials or components containing tin, tantalum and tungsten. The Company
relied upon the answers provided by vendors on the RMI reporting template to determine the country of origin of the tin, tantalum
and tungsten mineral and country of origin of smelters and refiners being utilized with respect to such raw materials or components.
Based on a review and assessment of
the responses received from these vendors, the Company has no reason to believe that its necessary conflict minerals may have originated
in the Democratic Republic of the Congo or an included adjoining country.
This Conflict Minerals Disclosure is available on the “Investor
Relations” section of the Company’s website at http://www.rbcbearings.com.
Item 1.02 Exhibits – Not Applicable
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.
RBC Bearings Incorporated
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By:
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/s/Joseph
Salamunovich
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Date: May 20, 2020
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Name:
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Joseph Salamunovich
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Title:
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Vice President, General Counsel & Secretary
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2
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