UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

INTERLINK ELECTRONICS, INC.

(Exact name of registrant as specified in its charter)

Ryan J. Hoffman

Chief Financial Officer and Secretary

(805) 484-8855

(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 submitted, and provide the period to which the information in this Form applies:

Section 1 – Conflict Minerals Disclosure

A Conflict Minerals Report is attached as an exhibit to this Form SD and is available on our website, www.interlinkelectronics.com, as permitted by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD. The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or the Conflict Minerals Report.

The Conflict Minerals Report provided for in Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 – Resource Extraction Issuer Disclosure

Not applicable.

Section 3 – Exhibits

The following exhibit(s) are filed as part of this Form SD:

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.

Exhibit 1.01

INTERLINK ELECTRONICS, INC.

Conflict Minerals Report
For the Calendar Year Ended December 31, 2022

This Conflict Minerals Report (“Report”) of Interlink Electronics, Inc. has been prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period January 1, 2022 to December 31, 2022. As used in this Report and unless otherwise expressly stated or the context otherwise requires, all references to “Interlink,” “we,” “our,” “Company” and similar references are references to Interlink Electronics, Inc. and its consolidated subsidiaries.

The U.S. Securities and Exchange Commission (SEC) Final Conflict Minerals Rule  (SEC Final Rule)¹ requires a three-step compliance process: the first step is determining the applicability of the rule; the second step is conducting a “reasonable country of origin inquiry” (RCOI) to determine whether or not there is reason to believe that tin, tungsten, tantalum or gold (3TG), also referred to as conflict minerals, from the Democratic Republic of Congo or adjoining countries (collectively, the “Covered Countries”) are present in the company’s products or are from recycled or scrap sources; and if so, the third step is conducting due diligence to determine the source and origin of those conflict minerals based on the facilities (smelter or refiners, “SORs”) in which they were processed. Companies requiring due diligence must use a nationally or internationally recognized standard such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance ²) to meet the SEC regulatory requirements.

The first step in SEC Final Rule compliance is examining rule applicability to Interlinks activities. According to the Final Rule, there are four decision criteria: (1) whether the organization files reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act; (2) whether the organization manufactures or contracts to manufacture products; (3) whether conflict minerals are “necessary to the functionality” or “necessary to the production” of such products and (4) whether the necessary conflict minerals were outside the supply chain prior to January 31, 2013.³

Interlink engaged a third-party consulting firm, Source Intelligence (https://www.sourceintelligence.com/), to assist with the collection of information about the presence and sourcing of conflict minerals used in the products and components supplied to us. We provided a list of Tier 1 suppliers determined to be in-scope for regulatory purposes to Source Intelligence. Based on Interlink Electronics’ influence over the manufacturing process (i.e., meeting the manufacture or contract to manufacture definitions in Rule 13p-1) and potential use of 3TG these suppliers were engaged following the RCOI process described below.

¹ Securities and Exchange Commission, 17 CFR Parts 240 and 249b, http://www.sec.gov/rules/final/2012/34-67716.pdf.

² OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.

³ Conflict minerals are considered “outside the supply chain” if they were smelted or refined or were outside of a covered country prior to January 31, 2013.

Interlink designs, develops, manufactures, and sells a range of force-sensing and related technologies that incorporate our proprietary materials technology, firmware, and software into a portfolio of standard sensor-based products and custom sensor-system solutions. These include sensor components, sub-assemblies, modules, and products that support effective, efficient cursor control and novel three-dimensional user inputs. Our human machine interface technology platforms are deployed in a wide range of markets including consumer electronics, automotive, industrial, and medical. In December 2022, Interlink US acquired two leading companies in electrochemical gas-sensing technology for industry, community, health, and home, providing custom solutions, advanced sensors, innovative products, and services. KWJ Engineering and SPEC Sensors have 30 years’ experience in developing gas sensors and solutions. Their products have uses in fields such as carbon monoxide and ozone detection and air quality monitoring. The Conflict Minerals reporting rule permits a reporting company acquires another company that manufactures or contracts for the manufacture of products which potentially contain conflict minerals and that previously had not been required to file a Form SD report for those minerals, may delay the reporting on the acquired company’s products until the end of the first calendar year that begins no sooner than eight months after the closing date of the acquisition. As such this current report does not include the products of KWJ Engineering and SPEC Sensors. These will be included in the next reporting period.

We have adopted a Conflict Minerals Policy that states our commitment to ethical business conduct and the responsible sourcing of minerals throughout our global supply chain. The Conflict Minerals Policy is available on our website at www.interlinkelectronics.com under “About Us - Environment and Sustainability”

We determined that certain conflict minerals are necessary to the functionality of one or more of our products that we manufactured or had manufactured during the Reporting Period, and thus conducted a reasonable country of origin inquiry (RCOI) to determine whether any conflict minerals necessary to the functionality or production of such products originated in the Covered Countries or are from recycled or scrap sources. We established an internal team responsible for the reasonable country of origin inquiry, which included employees involved with material procurement.

We contract with numerous suppliers that contribute to the manufacture of our products, and are several levels removed from the smelters or refiners (“SORs”) that process the minerals used in our products and from the mines of origin for those minerals. Interlink does not purchase raw ore or unrefined conflict minerals, and we made no purchases in the Covered Countries. As a result, in conducting our RCOI, we necessarily relied upon our suppliers to provide conflict minerals sourcing information and identify those SORs that represent the sources of conflict minerals in our supply chain.

The RCOI began with an evaluation of our suppliers who provided materials, components or products that became part of products we manufactured or contracted to be manufactured in 2022 which contained or were likely to contain conflict minerals necessary to the production or functionality of those products.

A total of 37 Tier 1 suppliers were identified as in-scope for conflict mineral regulatory purposes and contacted as part of the RCOI process conducted by Source Intelligence. The response rate among these suppliers was 76%.

Of these responding suppliers, 36% indicated one or more of the regulated metals (3TG) as necessary to the functionality or production of the products they supply to Interlink Electronics. Based on Source Intelligence’s smelter/refiner database⁴, and as shown in the CMCP Data Summary, there was an indication of DRC sourcing for 48 out of 235 verified smelters/refiners.

Each of the Identified Suppliers was contacted by introductory email containing a registration and survey request link for an on-line data collection platform. The Identified Suppliers were asked to provide information about the presence and sourcing of conflict minerals used in the products and components supplied to Interlink, with the ultimate objective of identifying for any conflict minerals the SORs and the associated mine countries of origin. To collect this information, the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (CMRT), versions 6.22 or higher was used. If an Identified Supplier failed to respond to our request for information or provided an incomplete or insufficient response, we sent follow-up inquiries requesting a complete response. In addition, supplier responses were evaluated for plausibility, consistency and gaps, and Identified Suppliers were contacted if any of the following quality control issues were identified:

⁴ Source Intelligence maintains a smelter/refiner database to document which companies are known metal processors (i.e., verified), which companies are exclusive recyclers, mine country of origin information, and DRC conflict-free certification status. Source Intelligence collects SOR data submitted by suppliers via CMRTs and compares it against its existing database. Supplier responses listing entities that are not verified smelters/refiners are flagged and suppliers are asked for further clarification.

Of 28 responding suppliers, 36% indicated one or more of the regulated metals (3TG) as necessary to the functionality or production of the products they supply to Interlink Electronics. Based on Source Intelligence’s smelter/refiner database⁵, and as shown in the CMCP Data Summary, there was an indication of DRC sourcing for 48 out of 235 verified smelters/refiners. There were only 4 of these SOR’s that were sourcing from covered countries and were not certified.

Consequently, Interlink has concluded that certain of its products in calendar year 2022 contain conflict minerals that may have originated in the Covered Countries and were not from scrap or recycled sources.

For those supply chains with SORs that are known or thought to be sourcing conflict minerals in the Covered Countries, additional investigation is needed to determine the source and chain-of-custody of the conflict minerals. For this reason, and because only 76% of the Identified Suppliers responded to our RCOI request for information, we are unable to determine whether any conflict minerals in products that we manufactured or had manufactured in 2022 financed or benefited armed groups in a Covered Country. However, of the 48 SORs that have been identified 44 have been certified Conflict Free by Third Party audit.

⁵ The information in the smelter/refiner database begins with supplier-provided information (CMRT data); Source Intelligence then performs additional research (internet, industry and government associations) and outreach (email and telephone) directly with these companies to confirm the data provided via CMRTs. The Source Intelligence Smelter Verification and Outreach Process includes research in an attempt to verify types of metal processing performed (including exclusive recycling), mine countries of origin, conflict-free certification status, and due diligence measures being conducted for those entities who are not conflict-free certified.

In response to our RCOI, our responding suppliers identified 235 SORs in their CMRTs which may have processed conflict minerals contained in materials, components or products provided to us. A list of these SORs is set forth in Annex I. We cross-referenced these SORs against the list of facilities that have received a “conflict free” designation from the Conflict-Free Smelter Program (“CFSP”) and its cross-recognized programs (e.g. the Responsible Jewellery Council and the London Bullion Market Association), whose designations provide country of origin and additional due diligence information on the conflict minerals sourced by such facilities. Of these 235 identified SORs 48 SORs were identified as sourcing from Covered Countries, as of April 21^st, 2022. A list of these is set forth in Annex II:

Under the CFSP’s standards, “compliant” means a facility has been audited and found to be compliant with the relevant CFSP protocol, and “active” means a facility that is engaged in the program but has not yet been found to be compliant.

Each of the 44 SORs that we believe may source conflict minerals from the Covered Countries has received a “conflict free” designation from the CFSP.

Interlink believes that the Subject Minerals contained in our products originate from the countries listed in Annex III below, as well as from recycled and scrap sources.

Interlink intends to undertake the following additional steps to continue to mitigate any possible risk that the necessary conflict minerals in our products could benefit armed groups in the Covered Countries:

Annex I

SMELTERS AND REFINERS IN SUPPLY CHAIN

235 Smelters Or Refiners (SOR's) Reported In Interlinks Supply Chain For 2022

Annex II

SMELTERS AND REFINERS SOURCING FROM COVERED COUNTRIES

44 Smelters Or Refiners (SOR's) Reported In Interlinks Supply Chain Who Source Metals from Covered Countries but are Certified Conflict Minerals Free by Third Party Audit For the Year 2022

4 Smelters or Refiners (SOR's) Reported In Interlinks Supply Chain Who Source Metals from Covered Countries but are Not Certified Conflict Minerals Free by Third Party Audit For the Year 2022

Annex III

COUNTRIES FROM WHICH SUBJECT MINERALS SOURCED