UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Skyline Medical Inc.
(Exact name of registrant as specified in its charter)
Commission File Number: 001-36790
| Delaware | 33-1007393 | |
| (State or other jurisdiction of | (I.R.S. Employer | |
| incorporation or organization) | Identification No.) | |
| 2915 Commers Drive, Suite 900 | Eagan, Minnesota 55121 | |
| (Address of principal executive offices) | (Zip Code) |
Bob Myers 651-389-4800
(Registrant’s 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:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.
Section 1 – Conflict Minerals Disclosure
Skyline Medical Inc. (“Skyline”, “we”, “our” or the “Company”) has evaluated its current product lines and determined that certain products we manufacture contain tin, tungsten, tantalum and/or gold (3TG), which are defined as “conflict minerals” by the United States Securities and Exchange Commission that are necessary to the functionality or production of our products. Accordingly, we are filing this disclosure along with a Conflict Minerals Report to disclose the measures we have taken to determine the origin of the conflict minerals used in our products.
Item 1.01 Conflict Minerals Disclosure
We undertook due diligence measures, including surveying our direct suppliers to try to determine the sources of these minerals, which we purchase through a complex supply chain.
We currently still have 31% of our suppliers who are not able to identify the mineral sources’ originating country. Therefore, we cannot exclude the possibility that some of these conflict minerals may have originated in the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources.
Item 1.02 Exhibit
A copy of the Company’s Conflict Minerals Report for the reporting period from January 1, 2016 to December 31, 2016 is provided as Exhibit 1.01 hereto and is publicly available at: www.skylinemedical.com under News and Media. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Section 2 - Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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.
Skyline Medical Inc.
| By: /s/ Bob Myers | Date: May 31, 2017 | |
| Name: Bob Myers | ||
| Title: Chief Financial Officer |
Exhibit 1.01
Skyline Medical Inc.
Conflict Minerals Report
For the Reporting Period from January 1, 2016 to December 31, 2016
This report, for the reporting period from January 1, 2016 to December 31, 2016, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement the reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”). These reporting requirements apply to registrants whatever the geographic origin of the conflict miners and whether or not the minerals fund armed conflict.
We conducted an analysis of our products and found that 3TG can be found in our waste fluid disposal system and are necessary to the functionality or production of this product. Therefore, we are subject to the reporting obligations of Rule 13p-1.
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.
We had previously undertaken a Reasonable Country of Origin Inquiry (“RCOI”) survey of 15 suppliers who provide us with those components likely to contain 3TG. Of the 13 responses received, which were provided in a variety of formats, including the template developed by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI), indicated: (a) the components did not contain 3TG minerals, (b) that the minerals supplied did not originate in a Covered Country, or (c) that the origin of the minerals that they supplied to us could not be determined at this time.
Due to the breadth and complexity of our products and supply chain, it will take time for many of our suppliers to verify the origin of all of the minerals, and they may not succeed in determining the origin of all or any such minerals.
Despite having conducted a good faith RCOI, we do not currently have sufficient information from our suppliers or other sources to determine the country of origin of all the conflict minerals used in our products or identify the facilities used to process those conflict minerals. Therefore, we cannot exclude the possibility that some of these conflict minerals may have originated in a Covered Country and are not from recycled or scrap sources.
Using our supply chain due diligence processes and continuing our outreach efforts, in combination with leveraging industry standard programs, we hope to further develop transparency into our supply chain.
We have not obtained an independent private sector audit to accompany this Report, as permitted by Form SD, which provides a temporary accommodation to such requirement for smaller reporting companies for the first four calendar years following November 13, 2012.
We recognize that we have ongoing obligations under the reporting requirements of Rule 13p-1 and have adopted a Conflict Minerals Policy. We will continue to request assistance from our direct suppliers to support our reporting obligations and best practices for RCOIs and related due diligence, and, compare the list of smelters identified through our RCOI to the lists of smelters that have been designated as “conflict free.” Out full intent is to continue this practice on an ongoing basis.