UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
GLOBUS MEDICAL, INC.
(Exact name of registrant as specified in charter)
DELAWARE | 001-35621 | 04-3744954 | ||
(State or other jurisdiction of incorporation) | (Commission File Number) | (IRS Employer Identification No.) | ||
2560 GENERAL ARMISTEAD AVENUE, AUDUBON, PA 19403
(Address of principal executive offices) (Zip Code)
DANIEL T. SCAVILLA
Executive Vice President, Chief Financial Officer
(610) 930-1800
(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:
x | Rule 13p-1 under Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018. |
Section 1 - Conflict Mineral Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
For purposes of this Form SD, “Conflict Minerals” means columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives tantalum, tin and tungsten. In 2018, Globus Medical sold certain medical devices that contained Conflict Minerals. In accordance with the rules promulgated pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, pursuant to which the Securities and Exchange Commission adopted Form SD, we conducted a reasonable country of origin inquiry with respect to those Conflict Minerals that were contained in the medical devices that we sold in 2018 and were not outside of the supply chain prior to January 31, 2013. Third party suppliers primarily manufactured those medical devices for us. During 2018, we also manufactured a significant portion of our implant products at our facility in Eagleville, Pennsylvania. As part of our inquiry, we asked all third party suppliers of our medical devices containing Conflict Minerals to identify the source of those Conflict Minerals. We also performed the same inquiry of our raw materials vendors for our in-house manufactured products containing Conflict Minerals. This information included the name of the smelters that processed the Conflict Minerals that were not outside of the supply chain prior to January 31, 2013. Our inquiries noted that each of these smelters is on the Responsible Minerals Assurance Process Conformant Smelters and Refiners list maintained by the Responsible Minerals Initiative.
Conclusion
Based on our reasonable country of origin inquiry, we have no reason to believe that any Conflict Minerals contained in medical devices manufactured for us or by us in 2018 originated in the Democratic Republic of the Congo or an adjoining country.
This Conflict Minerals Disclosure is also available on our website at http://www.globusmedical.com/investors/conflict-minerals-disclosure/.
Item 1.02 Exhibit
Not required.
Section 2 - Exhibits
Item 2.01 Exhibits
None.
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.
GLOBUS MEDICAL, INC. | ||
(Registrant) | ||
Dated: | May 30, 2019 | /s/ DANIEL T. SCAVILLA |
Daniel T. Scavilla | ||
Executive Vice President, | ||
Chief Financial Officer | ||
Chief Commercial Officer | ||
(Principal Financial Officer) | ||