Document

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
 
SPECIALIZED DISCLOSURE REPORT
 
Griffon Corporation
(Exact name of the registrant as specified in its charter)
 
Delaware
 
1-06620
 
11-1893410
(State or other jurisdiction of
 
(Commission
 
(IRS Employer
incorporation or organization)
 
File Number)
 
Identification No.)
 
712 Fifth Avenue, 18th Floor, New York, New York
 
10019
(Address of principal executive offices)
 
(Zip code)
 
Brian G. Harris
Senior Vice President and
Chief Financial Officer
(Principal Financial Officer)
(212) 957-5000
 
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:
 
S
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.

 




 
Section 1 - Conflict Minerals Disclosure

 
Item 1.01 Conflict Minerals Disclosure and Report
 
Conflict Minerals Disclosure
 
Attached hereto and incorporated herein by reference as Exhibit 1.01 is the Griffon Corporation 2015 Conflict Minerals Report. Included within the Conflict Minerals Report are disclosures of:
 
 
(a)
Our Reasonable Country of Origin Inquiry (“RCOI”) of necessary Conflict Minerals (as defined under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”)), conducted in good faith, to determine whether any Conflict Minerals in our supply chain originated in the Democratic Republic of the Congo or an adjoining country (as defined in the Act as “DRC”), or are from recycled or scrap sources;

 
(b)
Our determination and results of our RCOI;
 
 
(c)
Our due diligence measures performed in accordance with the Organization for Economic Development and Cooperation (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas; and
 
 
(d)
The results of our OECD due diligence.
 
This Form SD and our 2015 Conflict Minerals Report can be found on our website at www.griffon.com. Both Form SD and the 2015 Conflict Minerals Report will be maintained on our website for a 12 month period.
 
Item 1.02 Exhibit
 
Griffon Corporation’s 2015 Conflict Minerals Report is attached hereto as Exhibit 1.01 and incorporated herein by reference.
 
Section 2 - Exhibits
 
Item 2.01 Exhibits
 
The following exhibit is filed as part of this report.
 
Exhibit 1.01: 2015 Conflict Minerals Report of Griffon Corporation

 




 
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.
 
 
Griffon Corporation
 
Date: May 31, 2016
 
 
 
 
By:
/s/ Brian G. Harris
 
 
Brian G. Harris
 
 
Senior Vice President and
 
 
Chief Financial Officer