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GRAHAM HOLDINGS CO filed this Form SD on 05/31/2017
Entire Document

5.3 Identify and Assess Risk in the Supply Chain

As described above, Forney and Joyce conduct a survey of all of their suppliers using the Template to obtain chain of custody declarations from their suppliers. The Template includes questions on the use and origin of Conflict Minerals in their components, supplier engagement with sub-tier suppliers and smelters and points of origin of the Conflict Minerals. To strengthen engagement with suppliers, they added a Conflict Minerals clause to their purchase orders in order to communicate the expectations and requirements regarding the sourcing and disclosure of Conflict Minerals.
5.4 Design and Implement a Strategy to Respond to Identified Risks

As discussed above, in most cases, suppliers were unable to specify smelters or refiners used for components supplied to Forney and Joyce because most are distributors that are still working to obtain information from their own suppliers. For those suppliers that provided names of smelters/refiners, the supplier’s reported validation status was confirmed by comparing it to the information contained on the Conflict Free Sourcing Initiative (the “CFSI”) website.

5.5 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

Neither Forney nor Joyce have a direct relationship with smelters or refiners, nor do they perform direct audits of such entities in their supply chain.

5.6 Report on Supply Chain Due Diligence

Our Form SD and this Conflict Minerals Report are both available on our website at GHCO will file a Form SD with the Securities and Exchange Commission on an annual basis, pursuant to Rule 13p-1 of the Act.
Results of Due Diligence Review-Facilities Used to Process the Necessary Conflict Minerals

As discussed above, Forney and Joyce solicited all of their suppliers to gather information by means of the Template regarding the sourcing of 3TG in the products supplied to them. A majority of the suppliers responded that they were still in the process of evaluating the source of 3TG in their own products. Based on the information provided by suppliers in the Templates, the smelters used to process necessary conflict minerals include those listed on the attached Schedule 1. With respect to those smelters that were identified by suppliers in their Template, the supplier’s reported validation status was confirmed by comparing it to the information contained on the CFSI website. Based on the information provided by suppliers and Forney’s and Joyce’s own due diligence efforts, we do not have sufficient information to