Conflict Minerals Statement


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Please be assured that George Risk Industries, Inc (GRI) understands the gravity of the subject of Conflict Minerals and its importance to you, our customer. We are committed to the pursuit of responsible procurement practices and have no intention, direct or indirect, of abetting the human rights violations identified in the Democratic Republic of Congo (DRC) and adjoining countries.

GRI intends to be compliant with Section 1502 of the Dodd-Frank Act and other regulations concerning the sourcing of the raw materials (currently defined as Tin, Tantalum, Tungsten, and Gold; also referred to as “3TG” minerals) from conflict areas. To the best of our knowledge at this time, the components supplied to our customers have been designed and manufactured with source material from environmentally and socially responsible suppliers being in compliance with the Electronics Industry Code of Conduct.

At this time a number of our suppliers have been unable to provide detailed information relating to the use of conflict minerals in the production of the electronic components that we use in our products. The Original Component Manufacturer (OCM) is currently the only source of detailed information regarding the substances, including any conflict minerals that are used in the manufacturing of their products. We are working with the OCM’s to make sure we are compliant. Many have already responded that they are “Conflict Mineral Free”, many are still checking with their suppliers, and a few have answered “Unknown” at this time. We are expecting them to become compliant soon.

We understand this is an important concern worldwide, although formal guidelines may vary between countries. The electronics industry has been proactive via the Electronic Industry Citizenship Coalition (EICC), and we will continue to follow EICC’s actions and recommendations as they apply to this issue. We also will continue to work with our suppliers to use DRC conflict free minerals.

Conflict Minerals Disclosure for George Risk Industries, Inc.

802 S. Elm St., Kimball, NE 69145

Scott McMurray



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 period from January 1, 2023, to December 31, 2023.

o Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ________.


Section 1 – Conflict Minerals Disclosure


Item 1.01 Conflict Minerals Disclosure and Report

This Form SD of George Risk Industries, Inc. is filed in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period from January 1, 2023 to December 31, 2023.

The Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD and is publicly available on the Company’s website at

The content of any website referred to in this Form SD, including Exhibit 1.01, is included for general information purposes only and is not incorporated by reference into this Form SD or the attached Conflict Minerals Report.


Item 1.02 Exhibit

The Company’s Conflict Minerals Report for the reporting period from January 1, 2023, to December 31, 2023, is filed as Exhibit 1.01 (see below) to this Form SD.


Section 2 – Exhibits Item 2.01 Exhibits


Exhibit 1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.




Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.




Date: May 10, 2024 By: Scott McMurray

Director of Sales & Marketing




Conflict Minerals Report

as required by Items 1.01 and 1.02 of Form SD


This Conflict Minerals Report of George Risk Industries, Inc. (GRI) has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023.

It is required to disclose certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the law are necessary to the functionality or production of those products. The specified minerals, referred to as 3TG, are gold, columbite-tantalite (coltan), cassiterite, and wolframite, including their derivatives, which are limited to tantalum, tin, and tungsten.

The “Covered Countries” for this report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola.

George Risk Industries, Inc. fully supports the objectives of the Act. We do not directly source materials from the Democratic Republic of the Congo (DRC) or adjoining countries (“Covered Countries”). Our suppliers have indicated they do not source materials from the DRC or Covered Countries. George Risk Industries, Inc. will take proper steps to switch to conflict-free materials if at any point we become aware of non-conflict-free materials within our supply chain.

Company and Products Overview

GRI is an electronics manufacturer. Our focus is on the security and proximity switch markets. Primarily, GRI sells to security and fire distributors, but we also provide switches for OEM use.

The products that GRI produces include security alarm switches, proximity switches, pool alarms, temperature and humidity sensors, custom computer keyboards, push-button switches, tools for wire handling, and other electronic products. Most of the GRI product line has products for which 3TG is necessary for the functionality or production of the product.


Supply Chain

GRI’s supply chain is complex. There are many 3rd parties between GRI and the source of the 3TG. GRI does not purchase 3TG directly from mines, smelters, or refiners. Many of our electronic parts are purchased through distribution. As a result, GRI must rely on the information provided by suppliers for the information relating to 3TG. GRI has taken steps to identify the smelters and refiners of 3TG in our supply chain.

GRI has adopted a statement relating to Conflict Minerals. The statement communicates that GRI intends to be free of Conflict Minerals in its supply chain and expects GRI suppliers to treat their supply chain in the same way.


Reasonable Country of Origin Inquiry (“RCOI”)

To determine whether any 3TG was necessary to the function or production of GRI products in 2023 and originated in the Conflict Region, the Company retained APA Engineering Conflict Minerals Due Diligence Service (“APA”), a third-party service provider, to assist us in reviewing our supply chain and identifying risks.

The Company obtained all contact details for direct suppliers and provided this information to APA for uploading into the AutoGen – CM, a software-as-a-service platform provided by APA that enables users to complete and track supplier communications and allows suppliers to upload completed conflict mineral reporting templates for validation, assessment, and management (“AutoGen – CM”).

To collect data on the sources of materials procured by the supply chain, the Company used the Conflict Minerals Reporting Template (“CMRT”) version 6.31 or higher to survey all suppliers. Follow-up questions were submitted to suppliers through early 2024 to better understand whether the materials they supply to us contain 3TG and, if so, to better trace the origin of those materials.

During the supplier survey, the Company contacted suppliers via the AutoGen – CM. The AutoGen – CM also provides functionality that meets the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on tantalum, tin, tungsten and gold (the “OECD Guidance”) process expectations by evaluating the quality of each supplier response and assigning a score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

Via the AutoGen – CM and the APA team, the Company requested that suppliers complete a CMRT. APA also provided suppliers with training and education to guide them on best practices and the use of the CMRT. APA monitored and tracked all communications in the AutoGen – CM for future reporting and transparency. The Company directly contacted suppliers that were unresponsive to APA’s communications during the diligence process and requested these suppliers to complete the CMRT and submit it to APA.

The Company’s program included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which help to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of in-scope suppliers. The results of this data validation contribute to the program’s assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

All submitted forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback on their CMRT submission, training courses, and direct engagement help through APA’s Conflict Minerals team. Because some suppliers may remain unresponsive to feedback, the Company tracks program gaps to account for future improvement opportunities.