Siliconware Precision Industries Co., Ltd. is the first company to file a Form SD, with a filing in the early morning hours of April 24, 2014. A Conflict Minerals Report is filed as an exhibit to the Form SD. The company files under the “seminconductors and related devices” SIC code. According to the company, no independent private sector audit was required.
The company does, however, go on to claim that certain of its products are “conflict free.” Further, the due diligence elements of the Conflict Minerals Report are not separately set out and do not highlight the elements of the OECD Guidelines as the basis for the due diligence measures performed. There appears to be no description of the reasonable country of origin inquiry, either in the Form SD or in the Conflict Minerals Report.
The executive officer signing the form was “Vice President.”
There will be lots of commentary on the content of the filing, but that is better left for private conversations.