UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

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FORM SD

Specialized Disclosure Report

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Surmodics, Inc.

(Exact name of registrant as specified in its charter)

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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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Section 1 – Conflict Minerals Disclosure

Item 1.01 and 1.02 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

A copy of the Surmodics, Inc. Conflict Minerals Report for the year ended December 31, 2020 is provided as Exhibit 1.01 hereto and is publicly available at www.surmodics.com in the Corporate Governance subsection of the Investors section of the website, under the heading “Governance Overview.”

Item 1.02 Exhibit

The Conflict Minerals Report is attached as Exhibit 1.01.

Section 2 – Exhibits

Item 2.01.  Exhibit

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

 

 

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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.

 

 

 

 

 

EXHIBIT 1.01

 

Conflict Minerals Report of Surmodics, Inc.

 

This Conflict Minerals Report of Surmodics, Inc. (the “Company”, “we” or “our”) for the period from January 1, 2020 to December 31, 2020, has been prepared pursuant to Rule 13p-1 and Form SD (together, the “Rule”) promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended.  The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which Conflict Minerals are necessary to the functionality or production of those products.  “Conflict Minerals” are defined in the Rule as gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten.

Company Background

The Company provides surface modification technologies for intravascular medical devices and chemical components for in vitro diagnostic immunoassay tests and microarrays.  As a provider of technologies and products to the medical device and diagnostic industries, the Company does not engage in the actual mining of conflict minerals, does not purchase raw ore or unrefined conflict minerals from any source, and does not directly purchase any product, mineral or any other materials from any source in any of the Covered Countries, as defined in the Rule.

Conflict Minerals Due Diligence

To comply with the Rule, the Company undertook an evaluation of the products it manufactures to determine whether any Conflict Mineral is necessary to the functionality or production of the product.  This evaluation included a review of product development information, bills of material, product specifications, design documents and information in our resource management systems.  Technical and supply chain personnel from our research and development, manufacturing and operations functions participated in the evaluation.

As a result of the evaluation, the Company determined that certain of its in vitro diagnostics products are made using a chemical compound (the “Chemical Compound”) derived from tin, which is considered necessary to the functionality or production of such products.  In the period covered by this Conflict Minerals Report, the Company estimates that it used approximately 100 grams of the Chemical Compound, with a purchase price of approximately $40.00.

In accordance with the Rule, the Company conducted, in good faith, due diligence on the source and chain of custody of the Conflict Minerals in the Chemical Compound.  The Company maintains two vendors as sources for the Chemical Compound.  The Company’s due diligence consisted of sending each vendor a Conflict Minerals Reporting Template (CMRT) (Revision 6.01; May 19, 2020) (the “Template”), developed by the Responsible Minerals Initiative.  The Company considers the Template to be a reasonable country of origin inquiry.  

Results of Conflict Minerals Due Diligence

Based on the responses of the vendors to the Template, the Company has no reason to believe that the Chemical Compound may have originated in a Covered Country, as defined in the Rule, except as follows:

 

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The response of one of the vendors of the Chemical Compound noted in its response to the Template that the source of the Conflict Mineral in the Chemical Compound it supplies is unknown and stated, “Uncertainty remains because our supplier does not report information on any one tin product but rather states that ‘Smelters that have confirmed, at a company level, sourcing from the Covered Countries have been identified in our supplier responses.  However, we have not yet confirmed with certainty which of these smelters are in our supply chain and, and, (sic) further, we do not have any information at this time indicating that we are supporting armed conflict in the Covered Countries.’”

Based on the volume of our use of the Chemical Compound, and the vendor’s disclosure, we believe that there is no more than a remote risk that any Conflict Minerals contained in the Chemical Compound that we may have purchases from the vendor benefited armed groups (as defined in the Rule). Therefore, no mitigation is needed related to such risk.