CSP : Specialized Disclosure Report

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

CSP Inc.

(Exact name of registrant as specified in its charter)

Massachusetts	0-10843	04-2441294
(State or other jurisdiction of incorporation	(IRS Employer Identification
or organization)	(Commission File Number)	No.)
175 Cabot St, Suite 210, Lowell MA	01854
(Address of principal executive offices)	(Zip Code)

Gary W. Levine, Chief Financial Officer [phone]

(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 this form applies:

• Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31,
  2021.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Form SD of CSP Inc. (the "Company") is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2021 to December 31, 2021.

Item 1.02 Exhibit

As specified in Section 2, Item 2.01 of this Form SD, the Company is filing its Conflict Minerals Report as Exhibit 1.01 to this report. A copy of the Company's Conflict Minerals Report is available at http://investorrelations.cspi.com/investor-

relations/corporate-governance/cspi-conflict-minerals-policy/default.aspx.

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report.

Exhibit No.

Description

1.01Conflict Minerals Report of CSP, Inc.

SIGNATURE

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.

	CSP INC.
Date: May 27, 2022	By: /s/ Gary W. Levine
		Gary W. Levine
		Chief Financial Officer

Exhibit 1.01

CSP Inc.

Conflict Minerals Report

For the reporting period January 1, 2021 to December 31, 2021

This Conflict Minerals Report (the "Report") of CSP Inc. (the "Company") has been prepared pursuant to Rule 13p-1 and Form SD (the "Rule") promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2021 to December 31, 2021.

In August 2012, the U.S. Securities and Exchange Commission ("SEC") issued rules implementing the "conflict minerals" disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "SEC Conflict Minerals Reporting Rule" or the "Rule"). If an SEC registrant manufactures (or contracts to have manufactured) products containing columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten (collectively, "3TG" or "Conflict Minerals"), and the 3TG is necessary to such products' functionality or production, the Rule requires that registrant to undertake a reasonable country of origin inquiry. If, as a result of the reasonable country of origin inquiry, the company knows or has reason to believe that any 3TG originated in the Democratic Republic of Congo or an adjoining country as defined in the Rule (the "Covered Countries"), and are not from recycled or scrap sources, the registrant must exercise due diligence on the source and chain of custody of such minerals. Specifically, registrants must determine whether: (a) any 3TG is necessary to the functionality or production of a product manufactured or contracted to be manufactured originated in the Covered Countries; and (b) the minerals directly or indirectly finance or benefit armed groups in the Covered Countries.

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Section 1 - Description of the Company's Products Covered by this Report

This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2021.

These products, which are referred to in this Report collectively as the "Covered Products," consist of substantially all of the products that are manufactured or contracted to be manufactured by the Company within its High Performance Products segment.

Section 2 - Reasonable Country of Origin Inquiry

The Company has conducted a reasonable country of origin inquiry regarding the Conflict Minerals that were necessary to the functionality or production of the Covered Products. This reasonable country of origin inquiry was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals came from recycled or scrap sources.

In conducting the reasonable country of origin inquiry, the Company utilized the conflict minerals reporting template developed by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) Extractives Working Group (the "EICC/GeSI Reporting Template").

The Company's supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Conflict Minerals that are included in the Covered Products. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore has taken steps to identify the applicable smelters and refiners of Conflict Minerals in the Company's supply chain.

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