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SD
GRAHAM HOLDINGS CO filed this Form SD on 05/31/2017
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We do not typically source conflict minerals directly from mines, smelters or refiners and therefore, in most cases, we are several levels removed from them.  As a result, we rely on the cooperation of our suppliers in the implementation of this policy and in enabling us to meet our compliance obligations.
 
 
4.
Reasonable Country of Origin Inquiry (“RCOI”)

4.1 Requests for Information and Survey Responses

Forney and Joyce conducted reasonable country of origin inquiries that were reasonably designed to determine whether any 3TG necessary to the functionality or production of any of their products originated in the Covered Countries or are from recycled or scrap sources. Forney and Joyce undertook an investigation of their suppliers of the generic components to determine the sources of the minerals incorporated into those components. Forney identified nine suppliers of the generic components contained in its products and Joyce identified four suppliers of generic components contained in its products. All of these suppliers were sent a survey designed to identify the source of the minerals. The survey sent was the Electronic Industry Citizen Coalition “Conflict Mineral Reporting Template” developed by the Electronic Industry Citizen Coalition and the Global e-Sustainability Initiative the “Template”). The Template is designed to collect sourcing information on the Conflict Minerals used in Forney’s and Joyce’s products. The Template includes questions related to, among other items, the use of 3TG in the supplier’s products, the supplier’s due diligence efforts, the source and chain of custody of any 3TG in the supplier’s products, whether the 3TG included in the supplier’s products came from recycled or scrap sources, and whether the supplier has a policy on conflict-free sourcing. Forney and Joyce also sought country of origin information directly by reviewing the policies and statements on the manufacturers’ websites addressing Conflict Minerals. Most of Forney’s and Joyce’s suppliers are distributors rather than manufacturers of components supplied to them, and most of such suppliers were unable to provide smelter information because they were still engaged in their own efforts to obtain information from their suppliers. Forney received responses from two suppliers that stated they do not knowingly purchase raw materials from conflict regions. Forney made a secondary attempt to conduct more due diligence by re-engaging with all the distributors for clarification on their respective findings. Joyce received a response from one supplier that included the names of eleven smelters that have been identified as certified Conflict-Free. Nevertheless, while neither Forney nor Joyce has determined that any of the Conflict Minerals in their generic components originated in the Covered Countries, they are unable to conclude with certainty that none of the Conflict Minerals contained in such generic components originated in the Covered Countries.

4.2 RCOI Conclusion

Based on our reasonable country of origin inquiry, we are unable to conclude that we have no reason to believe that none of the Conflict Minerals that are necessary to the functionality or production of our products originated in the Covered Countries and unable to conclude that they have not come from