Specialized Disclosure Report (sd)
29 May 2020 - 10:01PM
Edgar (US Regulatory)
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Graham
Corporation
(Exact name of registrant as specified in its charter)
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Delaware
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1-8462
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16-1194720
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(State or other jurisdiction of
incorporation or organization)
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(Commission
File Number)
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(IRS Employer
Identification No.)
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20 Florence Avenue, Batavia, New York
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14020
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(Address of principal executive offices)
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(Zip Code)
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Jennifer Condame, Controller and Chief Accounting Officer: (585)
343-2216
(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
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Conflict Minerals Disclosure and Report
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Conflict Minerals Disclosure
Graham Corporation (we, us or our) has determined that from January 1, 2019 December 31, 2019,
certain Conflict Minerals (as defined by Item 1.01(d)(3) of Form SD) were necessary to the functionality and/or production of products that we manufactured or that we contracted to manufacture. Based on a reasonable country of origin inquiry, we
have no reason to believe that such Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country sharing an internationally recognized border with the Democratic Republic of the Congo (together, Covered
Countries).
We undertook our reasonable country of origin inquiry by sending a vendor questionnaire to each of our vendors that has
been active within the past year, including new vendors. The questionnaire solicited information regarding each such vendors use of Conflict Minerals, its due diligence procedures with respect to its supply chain and the country of origin of
any such Conflict Minerals. In some instances, we followed up with our vendors to obtain their responses. We also maintain a policy that we take vendor responses to the questionnaire into account when assessing continuing vendor relationships. We
also attach the questionnaire to all purchase orders.
None of the elicited responses implicated any of the Covered Countries as the
country of origin for any Conflict Minerals used by us in products that we manufactured or contracted to manufacture during the period covered by this specialized disclosure report. Based on our review of the responses, we have no reason to believe
that Conflict Minerals provided by our vendors may have originated in the Covered Countries.
This Conflict Minerals Disclosure is
available on our website at www.graham-mfg.com/corporate-governance.
Based on the results of our reasonable country of origin inquiry described in Item 1.01 above, we are not required to file a Conflict Minerals
Report.
Section 2 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.
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Graham Corporation
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(Registrant)
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By:
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/s/ Jeff Glajch
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May 29, 2020
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(Name)
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Jeff Glajch
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(Date)
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(Title)
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Vice President Finance & Administration and Chief Financial Officer
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