UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Conflict Minerals Disclosure
CPS TECHNOLOGIES CORP.
(Exact Name of Registrant as Specified in its Charter)
Delaware 0-16088 04-2832509
(State or other jurisdiction of incorporation) (Commission File Number) (IRS Employer Identification No.)
111 South Worcester Street, Norton, Massachusetts 02766
(Address of principal executive offices) (Zip Code)
Registrant 508-222-0614
'
s telephone number, including area code
(Former name or former address, if changed since last 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 from January 1 to December 31, 2023.
Section 1 - Conflict Minerals Disclosure
CPS Technologies Corp. conducted an analysis of our products related to SEC
defined "conflict minerals", which are tin, tantalum, tungsten, and gold (3TG)
and based on CPS's reasonable country of origin inquiry we have no reason to
believe that our necessary conflict minerals may have originated in the DRC or
adjoining countries.
Conflict Minerals Disclosure
A copy of The Company's Conflict Minerals Disclosure is provided in Item 1.01
hereto and will be publicly available at: www.cpstechnologysolutions.com.
Item 1.01 Conflict Minerals Disclosure
CPS Technologies Corp.
Conflict Minerals Disclosure
For The Year Ended December 31, 2023
This disclosure for CPS Technologies Corp. for the year ended December 31,
2023 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 (SEC) to implement reporting and disclosure requirements related to
conflict minerals as directed by the Dodd-Frank Wall Street Reform and
Consumer Protection Act of 2010 (Dodd-Frank Act). 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-tantalit
e, gold, wolframite, and their derivatives, which are limited to tin,
tantalum, tungsten, and gold (3TG) for the purposes of this assessment.
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Company Overview
This disclosure has been prepared by management of CPS Technologies Corp.,
(herein referred to as "CPS" the "Company," "we," "us," or "our"). Nearly all
manufacturing and testing is performed in our 38,000 square foot facility
located at 111 South Worcester Street. CPS is a small business that is ISO
9001:2015 certified and publicly traded (CPSH). CPS currently employs
approximately 88 employees.
Business/Product Overview
CPS Technologies Corp. (the "Company" or "CPS") provides advanced material
solutions to the electronics, power generation, automotive, and other
industries. The Company's products are generally used in high-power,
high-reliability applications. The Company's primary advanced material
solution is metal matrix composites (MMC's), a new class of materials which is
a combination of metal and ceramic. CPS also assembles housings and packages
for hybrid circuits. These housings and packages may include components made
of metal-matrix composites. Using its proprietary MMC technology, the Company
also produces light-weight armor, particularly for extreme environments and
heavy threat levels.
Supply Chain Due Diligence and Process And Management System
The 3TG components involved in our manufacturing process are primarily gold
plating, gold alloy solder and are focused with eight vendors. The Director of
Quality Assurance has responsibility to: monitor all 3TG materials in our
process, inform and educate our 3TG vendors of the Conflict Minerals
regulations, and to solicit information pertaining to the source of their 3TG
materials. This process is performed annually using Conflict Minerals
Reporting Template ("CMRT") which all vendors of 3TG materials submitted to
the Company annually, within the last 12 months.
Reasonable Country of Origin Inquiry (RCOI) and RCOI conclusion
:
We conducted an analysis of our products related to SEC defined "conflict
minerals", which are tin, tantalum, tungsten, and gold (3TG) and based on
CPS's reasonable country of origin inquiry we have no reason to believe that
our necessary conflict minerals may have originated in the DRC or adjoining
countries.
SIGNATURE
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 thereunto duly authorized.
CPS Technologies Corp.
(Registrant)
Date: May 23, 2024 /s/ Charles K. Griffith Jr
.
Charles K. Griffith Jr.
Chief Financial Officer