Unassociated Document
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
 
FORM SD
 

Specialized Disclosure Report

HOOKER FURNITURE CORPORATION
(Exact name of the registrant as specified in its charter)
 
Virginia
000-25349
54-0251350
(State or other jurisdiction of
incorporation or organization)
(Commission
File No.)
(I.R.S. Employer
Identification No.)
 
440 East Commonwealth Boulevard, Martinsville, VA
24112
(Address of principal executive offices)
(zip code)
 
Harrison S. Toms                                                                           (276) 656-3318
(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:

 ü
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013.

 
 
 

Section 1 - Conflict Minerals Disclosure
 
Item 1.01 Conflict Minerals Disclosure and Report
 
Conflict Minerals Disclosure
 
Hooker Furniture Corporation (including its subsidiaries, the “Company”) is filing this report on Form SD for the reporting period of January 1, 2013 to December 31, 2013 (the “Reporting Period”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”), and in accordance with the requirements of Item 1.01 of Form SD. Rule 13p-1 and Form SD require disclosure of information related to any product manufactured or contracted to be manufactured by the Company where “conflict minerals” are necessary to the functionality or production of those products.  “Conflict minerals” means columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten.
 
The Company has adopted a Policy on the Use of Conflict Minerals for its first tier suppliers of materials, products or components included in products sold to the Company (“Suppliers”), which requires Suppliers to:
 
·  
Conduct a reasonable country of origin inquiry of any materials, products or components sold to the Company under any supply agreement;
 
·  
Provide reasonable evidence to the Company certifying either that:
 
o  
no conflict minerals were used in the products sold to the Company, or
 
o  
conflict minerals are included or contained in such materials, products or components; and
 
·  
Upon written request, provide:
 
o  
a detailed description of the materials, products or components sold to the Company that contain conflict minerals; and
 
o  
a detailed explanation and relevant documentation supporting the specific due diligence methods and standards utilized by the supplier to determine the original market source and country of origin of such conflict minerals.
 
In addition, during 2013 the Company conducted an inquiry, which included a good faith reasonable country of origin inquiry, that was reasonably designed to determine whether:
 
·  
Any conflict mineral was necessary to the functionality or production of products manufactured, or contracted to be manufactured, by the Company during the Reporting Period (“necessary conflict minerals”); and
 
·  
Any necessary conflict mineral originated in the Democratic Republic of the Congo or any country that shares an internationally recognized border with the Democratic Republic of the Congo (the “Covered Countries”).
 
 
 
 
 
Based on this inquiry, which is described further below, the Company determined that, with limited exceptions, none of the Company’s products manufactured or contracted to be manufactured during the Reporting Period contained any necessary conflict mineral.  However, the Company determined that cassiterite (tin) and gold were necessary to the functionality or production of motors used in certain power recliners, loveseats and sofas contracted by the Company to be manufactured during the Reporting Period (the “Specified Products”).
 
A brief description of the Company’s inquiry, including its reasonable country of origin inquiry, is as follows:
 
·  
Beginning in late 2012, the Company’s Manager Product Integrity and Regulatory Compliance assembled a team to develop a program to implement and administer the Company’s Policy on the Use of Conflict Minerals. The team prepared a conflict minerals questionnaire to be completed by all of the Company’s Suppliers. The questionnaire and the Company’s Policy on the Use of Conflict Minerals were prepared in English and translated into four additional languages that are used by the vast majority of the Company’s Suppliers. The policy and questionnaire were sent to all of the Company’s Suppliers.
 
·  
The questionnaire asked Suppliers to certify in writing whether materials, products or components supplied to the Company included or contained necessary conflict minerals.
 
·  
If so, the Supplier was asked to:
 
o  
Provide a description of the material, product and/or product component and the conflict mineral(s) used;
 
o  
Certify whether the necessary conflict mineral(s) came from recycled material or scrap; or alternatively
 
o  
Certify the company and country of origin of any necessary conflict minerals.
 
·  
The Company received and reviewed responses from substantially all of its Suppliers.
 
·  
The Company received a response from one Supplier that indicated that necessary conflict minerals were included in the Specified Products. That Supplier certified that, based on its internal data and supplier audit practices, those conflict minerals did not originate in the Covered Countries.
 
Based on the Company’s reasonable country of origin inquiry described above, the Company determined that for the Specified Products:
 
1.  
The necessary conflict minerals did not originate in the Covered Countries; or
 
2.  
The Company had no reason to believe that any necessary conflict minerals originated in the Covered Countries.
 
This information is also publicly available on the Company’s website at: www.hookerfurniture.com/mineralsact.  Information on the Company’s website does not constitute a 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.
 
Date: June 2, 2014
HOOKER FURNITURE CORPORATION
 
By: /s/ Paul A Huckfeldt
Name: Paul A. Huckfeldt
Title: Senior Vice-President Finance and
Accounting, Chief Financial Officer