Specialized Disclosure Report (sd)
June 01 2015 - 3:57PM
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, 2014. |
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 28 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). The
smelters are Malaysia Smelting Corporation, Malaysia and PT Timah (Persero),
Tbk, Indonesia.
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: June 1, 2015
ALLIANCE FIBER OPTIC PRODUCTS, INC. |
|
|
By
|
/s/ Anita
K. Ho |
Name:
Anita K. Ho |
Title: Acting Chief
Financial Officer |
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