Specialized Disclosure Report (sd)
01 Giugno 2020 - 11:01PM
Edgar (US Regulatory)
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
RTW Retailwinds, Inc.
(Exact name of registrant as specified in
its charter)
Delaware
|
|
1-32315
|
|
33-1031445
|
(State or other jurisdiction of
incorporation or organization)
|
|
(Commission
File Number)
|
|
(I.R.S. Employer
Identification No.)
|
330 West 34th Street, 9th Floor,
New York, New York
|
|
10001
|
(Address of principal executive offices)
|
|
(Zip Code)
|
Sheamus Toal
(212-884-2000)
(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:
x
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
Conflict Minerals Disclosure
RTW Retailwinds, Inc. (together with its subsidiaries, the “Company”,
“we” or “our) is a specialty women's omni-channel and digitally enabled retailer with a powerful multi-brand
lifestyle platform providing curated fashion solutions that are versatile, on-trend, and stylish at a great value. The Company's
portfolio includes branded merchandise from New York & Company, Fashion to Figure, Happy x Nature, and collaborations with
Eva Mendes, Gabrielle Union and Kate Hudson. The Company's branded merchandise is sold exclusively at its retail locations and
online.
The Company purchases finished apparel and accessories products
both from importers and directly from manufacturers and is committed to ensuring that the products it sells are produced in a socially
responsible way, including in compliance with the requirements of Rule 13p-1 under the Securities Exchange Act of 1934, as
amended (the “Rule”).
In furtherance of this commitment, the Company adopted a Conflict
Minerals Policy to help ensure compliance with the purposes and requirements of the Rule regarding the presence of Conflict Minerals
sourced from the Democratic Republic of the Congo or an adjoining country (each a “Covered Country”) in the Company’s
supply chain. Conflict Minerals (also known as “3TG”) are defined as gold, cassiterite, columbite-tantalite, wolframite,
and their derivatives, which are limited to tin, tantalum, tungsten.
Pursuant to the Policy, the Company reviews its entire product
line on an annual basis to determine whether any of the products it manufactures or contracts for manufacture contain any 3TG which
is necessary to the product’s functionality or production (such minerals hereinafter referred to as “Necessary 3TG”).
After completing this review for calendar year 2019, we determined that small quantities of Necessary 3TG, namely gold and tin,
were contained in certain components of the Company’s products, specifically zippers, buttons and other trim items.
Based on this determination, the Company conducted in good faith
a reasonable country of origin inquiry (“RCOI”) about the source of the Necessary 3TG in the Company’s products
for the reporting period ended December 31, 2019 in accordance with the requirements of the Rule and the instructions to Form SD.
The RCOI was reasonably designed to determine whether any of the Necessary 3TG contained in our products originated in a Covered
Country or came from recycled or scrap sources.
To conduct the RCOI, we engaged and made inquiries of all of
our in-scope direct suppliers that produced apparel and accessory products for the Company in 2019 that we believed could contain
Necessary 3TG. We also directed these suppliers to make inquiries of their direct suppliers about the origin of the Necessary 3TG
in our products. We conducted our inquiry using the Conflict Minerals Reporting Template (“CMRT”) developed by
Responsible Minerals Initiative. As part of this process, we provided information and offered assistance to suppliers about
the specifics of the Rule and the information requested in the CMRT.
Survey
responses were received from 92 of the Company’s direct suppliers. The responding suppliers represent 94.4% of our unit volume
for calendar year 2019. Our response rate was lower than in previous years as a result of the COVID-19 pandemic. We reviewed
each completed response and followed up with our suppliers as necessary (via email, phone and through sourcing contacts) to gather
additional information for responses requiring further clarification. Based on the information provided by our suppliers,
we do not have reason to believe that the Necessary 3TG contained in any of the products manufactured by or for the Company in
2019 may have originated from the Covered Countries.
As required by the Rule, we report on our 3TG sourcing annually,
and this Form SD is publicly available on the Company’s website at http://www.nyandcompany.com/nyco/static/about/investor-relations/. The
website and the information accessible through it are not incorporated into this Form SD.
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.
|
|
RTW RETAILWINDS, INC.
|
|
|
|
|
By:
|
/s/ SHEAMUS TOAL
|
|
|
Sheamus Toal
|
|
|
Chief Executive Officer and Chief Financial Officer
|
Date: June 1, 2020
Grafico Azioni RTW Retailwinds (NYSE:RTW)
Storico
Da Mag 2024 a Giu 2024
Grafico Azioni RTW Retailwinds (NYSE:RTW)
Storico
Da Giu 2023 a Giu 2024