SD 1 lmat20210525_sd.htm FORM SD lmat20210525_sd.htm






Washington, D.C. 20549



Form SD







LeMaitre Vascular, Inc.

(Exact name of registrant as specified in its charter)








(State or other jurisdiction of

incorporation or organization)


(Commission File Number)


(IRS Employer Identification No.)




63 Second Avenue, Burlington, MA




(Address of Principal Executive Offices)


(Zip Code)





Trent G. Kamke



(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:


☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.





Section 1 - Conflict Minerals Disclosure


Item 1.01 Conflict Minerals Disclosure and Report


LeMaitre Vascular, Inc. (the “Company” or “we”) conducted an evaluation of its product lines and determined that certain products manufactured, or contracted to be manufactured, by it contain conflict minerals, which are defined by paragraph (d)(3) of Item 1.01 of Form SD as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten.


Conflict Minerals Disclosure


This report for the year ended December 31, 2020 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”).


Products Overview


The Company develops, manufactures, processes and markets medical devices and implants for the treatment of peripheral vascular disease. We evaluated our product lines for the presence of conflict minerals and determined that a limited number contain conflict minerals necessary to the functionality or production of the product as described further below.


Reasonable Country of Origin Inquiry (RCOI)


We conducted an analysis of our products subject to the Rule and found that “conflict minerals,” as defined by the SEC, can be found in isolated components of our radiopaque tape, certain of our catheters and our powered phlebectomy devices (the “Products”).


We identified and contacted the three suppliers that provide the materials used in the isolated components of our radiopaque tape, catheters and the supplier of our powered phlebectomy devices. The suppliers demonstrated familiarity with the requirements of the Rule and indicated that they conducted due diligence into their supply chains. We requested that the suppliers provide to us representations or reports regarding the source of the conflict minerals or components containing conflict minerals supplied to us by them.


RCOI Results


One supplier confirmed that no conflict minerals originated from the Democratic Republic of the Congo (“DRC”) or an adjoining country. One supplier indicated that they do not purchase conflict minerals from the DRC or an adjoining country, nor do they purchase conflict minerals from suppliers who source in that region unless those suppliers have been certified by an authorized governing body as “conflict free.” The final supplier indicated that it maintains a policy to ensure that the sourcing of conflict minerals in its supply chain does not directly or indirectly contribute to armed conflict, unethical business practices or human rights abuses in conflict-affected and high-risk areas such as the DRC and to support local economies in such areas responsibly, by allowing the use of verified conflict-free conflict minerals in such areas in its supply chains. In furtherance of such policy, such supplier will not do business with any suppliers to them that 1) benefit from, contribute to, assist with, or facilitate the commission by any party of any forms of torture, cruel, inhumane or degrading treatment; other gross human rights violations and abuses such as widespread sexual violence; or war crimes or other violations of international humanitarian law, crimes against humanity or genocide; or 2) provide direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals, nor those who provide direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain. We have relied on our suppliers’ responses to provide us with information about the conflict minerals contained in the components or Products supplied to us and we did not identify any warning signs or have a basis to believe their responses were untrue.


A copy of the disclosure contained in this Form SD is publicly available at: under the heading entitled “Conflict Minerals Disclosure.”


Item 1.02 Exhibit




Section 2 Exhibits


Item 2.01 Exhibits








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.


LeMaitre Vascular, Inc.




By /s/ Trent G. Kamke_____________

Name: Trent G. Kamke

Title: Senior Vice President, Operations


Date: May 28, 2021