美国
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
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表格SD.
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LUNA INNOVATIONS INCORPORATED
(Exact name of registrant as specified in its charter)
_____________________________________
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Delaware
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000-52008
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54-1560050
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（州或其他管辖权
Incorporation or Organization)
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（佣金文件号）
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(I.R.S. Employer
Identification Number)
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301 First Street SW, Suite 200
Roanoke，VA 24011
(Address of Principal Executive Offices)
Eugene J. Nestro
Chief Financial Officer
(540) 769-8400
(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 the form applies:
ý
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
A copy of the Conflict Minerals Report of Luna Innovations Incorporated (“we”) is attached as Exhibit 1.01 and is available at
//www.lmz-yz.com
，在投资者关系下。
我们采用了一个冲突矿物质政策，可在
http:// www.www.lmz-yz.com
，在投资者关系下。This policy is not incorporated herein by reference.
Item 1.02 Exhibit
We have filed, as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.
Section 2 – Exhibits
第2.01项展品
The following exhibit is filed as part of this report:
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展览
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描述
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1.01
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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.
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Luna Innovations Inc.orporated
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日期：
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May 29, 2020
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By:
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/ s / Eugene J.蜘蛛店
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Eugene J. Nestro
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Chief Financial Officer
（主要财务和会计官）
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Conflict Minerals Report of Luna Innovations Incorporated
按照规则13 p - 1下的证券Exchange Act of 1934
截至2019年12月31日止年度
介绍
This Conflict Minerals Report of Luna Innovations Incorporated (“LUNA”, "we") for the calendar year ended December 31, 2019 has been prepared in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “1934 Act”). Rule 13p-1 was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). Rule 13p-1 imposes certain reporting obligations on SEC registrants who manufacture or contract to manufacture products containing conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten and gold (“3TG”) for the purposes of this assessment. The “Covered Countries” for the purposes of Rule 13p-1 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.
If a registrant has reason to believe that any of the conflict minerals necessary to the functionality or production of its products may have originated in the Covered Countries, or if it is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
Company Overview
月亮是一个先进的光学技术的领导者,providing high performance fiber optic test, measurement and control products for the telecommunications industry and distributed fiber optic sensing products for industries utilizing composite and other advanced materials, such as the automotive, aerospace, energy and infrastructure industries. Our distributed fiber optic sensing products help designers and manufacturers more efficiently develop new and innovative products by providing valuable information such as highly detailed stress, strain and temperature measurements of a new design or manufacturing process. In addition, our distributed fiber optic sensing products are used to monitor the structural integrity or operational health of critical assets, including large civil structures such as bridges. Our communications test and control products accelerate the development of advanced fiber optic components and networks by providing fast and highly accurate characterization of components and networks. In addition, we provide applied research services, typically under research programs funded by the U.S. government, in areas of sensing and instrumentation, advanced materials, optical technologies and health sciences. Our business model is designed to accelerate the process of bringing new and innovative products to market.
截至2019年12月31日的年度，我们将组织成两个主要业务部分，产品和许可分部和技术开发部门。bob软件苹果怎么下载产品和许bob软件苹果怎么下载可段开发，制造和销售分布式光纤传感产品和通信测试和控制产品。我们继续开发和商业化我们的光纤技术，用于传感航空航天，汽车，能源和基础设施的应用，以及电信和数据通信行业的测试和测量应用。bobapp综合体育下载bobapp综合体育下载该段中的主要产品线和开发服务包括光学分布式感应询问器，光学矢量分析仪，光学反射反射表，Hyperion和太赫兹传感系统。为了制造这些产品，我们与200多家第三方合bob软件苹果怎么下载同制造商合同制造组件，然后我们将其组装成我们成品。
The Technology Development segment performs applied research principally in the areas of sensing and instrumentation, advanced materials, and health sciences.
The scope of this Conflict Minerals Report excludes the products of General Photonics Corporation (“GP”), which we acquired on March 1, 2019. In accordance with Rule 13p-1, we are delaying reporting on GP’s products until the Form SD to
be filed in 2021, which is following the end of the first reporting calendar year that begins no sooner than eight months after the effective date of the acquisition of GP.
Our Policy
We strive to conduct our activities in a manner that reflects our mission and Code of Business Conduct and Ethics, which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace and complying with applicable law. We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing for materials for our products. As part of this commitment, we have adopted a policy relating to conflict minerals which is posted on our website at //www.lmz-yz.com, under Investor Relations. This policy provides that we support the goals and objectives of Section 1502 of the Dodd Frank Act that requires public companies to determine the sourcing of conflict minerals used in their products and that we expect our suppliers to support our efforts to comply with the Dodd Frank Act and to proactively identify and make every effort to eliminate the use of any conflict minerals in our supply chain.
Due Diligence
根据第13P-1的规则，我们进行了尽职调查，以确定我们与第三方制造合同的产品组成的必要冲突矿物质。bob软件苹果怎么下载在进行我们的尽职调查时，我们为受冲突影响和高风险地区（经合组织2011年），国际公认的适当调查框架的负责任供应链的经合组织适当调查指导。
作为光学元件和光纤测试和测量行业的公司，我们从冲突矿物的实际采矿中取出了几个水平。bobapp综合体育下载我们不购买原料矿石或未精制的冲突矿物，也不是我们在涵盖的国家购买任何购买。我们对我们产品中使用的3TG来源进行了一个诚信合理的原产地询问。bob软件苹果怎么下载这种善意合理的原产地询问旨在确定任何3TG是否起源于所带来的国家，以及3TG中的任何一个是否可以来自回收或废料来源。作为此过程的一部分，我们使用负责任的商业联盟（“RBA”）冲突矿物调查模板进行了调查。开发了该模板，以促进关于为公司供应链提供材料的冶炼厂的信息的披露和沟通。它包括有关供应商的无冲突政策，与其直接供应商进行接触的问题，以及供应商及其供应商使用的冶炼厂的上市。该模板还包含有关其产品中包含的冲突矿物原产地的问题，以及尽职调查。bob软件苹果怎么下载
我们的尽职调查措施包括：
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Conducting a supply-chain survey with direct suppliers of materials that contain conflict minerals using the RBA Conflict Minerals Reporting Template to identify the smelters and refiners.
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Tracking responses and reviewing responses to assess their reliability.
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Reviewing statements regarding use of conflict minerals on vendors’ websites.
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Following up with suppliers who failed to return responses or who returned incomplete or inconsistent responses in order to gain additional information and received revised responses, as necessary. As of May 29, 2020, we had received responses and/or reviewed policies online from approximately 70% of the surveyed suppliers.
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将供应链调查中确定的冶炼厂和炼油厂进行比较，这些冶炼厂调查列表被诸如负责矿物保障过程（“RMAP”）的计划被确定为“自由的自由”（“RMAP”）进行3TG。
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Conclusions
Although certain of the suppliers who responded to the survey were able to identify the smelters and refiners and conclude that the 3TG in the components that they manufacture for us originated in countries other than the Covered Countries or conflict free programs, many of the suppliers who responded to the survey were unable to specify the smelters or refiners used for components supplied to us. Based on the information received in the due diligence process, we do not have sufficient information to determine whether the necessary conflict minerals originated in the Covered Countries and, if so, whether the necessary conflict minerals were from recycle or scrap sources, were DRC conflict free or have not been found to be DRC conflict free. To date, our process has not yielded any affirmative data indicating that any of the 3TG necessary for the functionality or production of our products originated in any of the Covered Countries.
Efforts to Mitigate Risk
在下一个合规期，我们打算实施措施，以改善从我们尽职调查收集的信息，以进一步减轻我们必要的冲突矿物不受武装团体受益的风险。这些步骤包括：
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Ongoing conduct of supply-chain surveys with direct suppliers of materials containing conflict minerals using the RBA Conflict Minerals Reporting Template to identify the smelters and refiners.
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Ensure comparison of the smelters and refiners identified in the supply-chain survey against the current list of smelters for tantalum, tin, tungsten and gold.
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增加供应商的响应率，目标是从80％以上的供应商收到回复。
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Work with suppliers and request their participation in a program such as the RMAP program to obtain a “conflict free” designation.
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