Specialized Disclosure Report (sd)
November 21 2014 - 1:40PM
Edgar (US Regulatory)
UNITED
STATES
SECURITIES AND EXCHANGE
COMMISSION
Washington, D.C. 20549
____________
FORM SD
SPECIALIZED DISCLOSURE
REPORT
ALLIANCE FIBER OPTIC
PRODUCTS, INC.
(Exact name of
registrant as specified in its charter)
Delaware |
0-31857 |
77-0554122 |
(State or other
jurisdiction |
(Commission |
(IRS
Employer |
of
incorporation) |
File Number) |
Identification
No.) |
|
|
|
|
275 Gibraltar
Drive, Sunnyvale, California |
94089 |
|
(Address of principal
executive offices) |
(Zip
Code) |
Registrants telephone number,
including area code: (408) 736-6900
Check the appropriate box below to
indicate the rule pursuant to which this form is being filed, and provide the
period to which the information in this form applies:
x |
Rule 13p-1 under the Securities
Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013.
|
Section 1. Conflict Minerals
Disclosure
Item 1.01. Conflict Minerals
Disclosure and Report
(a) Alliance Fiber Optic Products, Inc. (the Company) undertook a
review of its products to determine whether one or more Conflict Minerals, as
defined in paragraph (d)(3) of Item 1.01, is necessary to the functionality or
production of products manufactured by the Company. The Company determined that
tin, a Conflict Mineral, is necessary to the functionality or production of
certain of its products.
(b) Conflict Minerals
Disclosure
Following its determination that tin
is necessary to the functionality or production of one or more of its products,
the Company conducted a reasonable country of origin inquiry (RCOI) by
circulating a supply-chain survey to all direct suppliers in which the nature of
the component supplied, or the location of the supplier, indicated that those
components might contain Conflict Minerals. The Company relies on its direct
suppliers to provide information on the origin of the Conflict Minerals
contained in components and materials supplied to it, including sources of
Conflict Minerals that are supplied to the Companys direct suppliers from lower
tier suppliers. The Company surveyed 27 such direct suppliers using the template
developed by the Electronic Industry Citizenship Coalition (EICC) and The
Global e-Sustainability Initiative (GeSI), known as the CFSI Reporting
Template.
The Company received responses from all of the suppliers
surveyed, although not all suppliers provided information sufficient to identify
the source of the tin used in their products or materials. The Company reviewed
the responses against criteria developed to determine which required further
engagement with suppliers. These criteria included untimely or incomplete
responses as well as inconsistencies within the data reported in the survey. The
Company then made follow-up inquiries of suppliers in order to obtain additional
or clarifying information.
Finally, the Company compared the
smelters and refiners identified by its direct suppliers via the supply-chain
survey against the list of smelter facilities that have received a "conflict
free" designation (such as through the EICC/GeSI Conflict Free Smelter
Initiative (CFSI) program's lists for tantalum, tin, tungsten and gold).
Based on the results of its RCOI and
related due diligence, the Company was able to determine the origin of all of
the tin in its products and to concluded that none of the tin originated in the
Democratic Republic of Congo or an adjoining country (the Covered Countries).
The Company has developed and
maintains internal procedures that are intended to provide a process in order to
generate and maintain the information needed to comply with the Companys
obligations with respect to compliance applicable Conflict Minerals rules,
including the Dodd-Frank Wall Street
Reform and Consumer Protection Act of 2010, as codified in Section 13(p) of the
Securities Exchange Act of 1934.
In addition, the Company has adopted a Conflict Minerals policy to
demonstrate its commitment to working with its global supply chain to ensure
compliance with the conflict minerals rules. The policy is available on the
Companys website.
The information contained in this
Form SD is also available on the Companys website at www.afop.com. The information on the Companys website shall
not be deemed to be incorporated by reference into this Form SD.
Item 1.02. Exhibit.
Not applicable.
Section 2. Exhibits.
None.
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
undersigned hereunto duly authorized.
Dated: November 21, 2014
ALLIANCE FIBER
OPTIC PRODUCTS, |
INC. |
|
|
|
By |
|
/s/ Anita K. Ho |
Name: |
Anita K.
Ho |
Title: |
Acting Chief
Financial Officer |
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