Specialized Disclosure Report (sd)
June 01 2020 - 2:17PM
Edgar (US Regulatory)
UNITED STATES
SECURITIES AND
EXCHANGE COMMISSION
Washington,
D.C. 20549
FORM SD
Specialized
Disclosure Report
BIONIK LABORATORIES
CORP.
(Exact name
of registrant as specified in its charter)
Delaware
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000-54717
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27-1340346
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(State or other jurisdiction
of incorporation or organization)
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(Commission
File Number)
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(IRS Employer
Identification No.)
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483 Bay Street, N105
Toronto, Ontario
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M5G 2C9
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(Address of principal executive offices)
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(Zip Code)
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Eric Dusseux, Chief
Executive Officer
(416) 640-7887
(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:
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x
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Rule 13p-1 under the Securities
Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019.
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Section 1 –
Conflict Minerals Disclosure
Item 1.01
Conflict Minerals Disclosure and Report
Conflict Minerals
Disclosure
This Form SD of
Bionik Laboratories Corp. (the “Company”) for calendar year 2019 is being filed in accordance with Rule 13p-1
(“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended.
Rule 13p-1 requires
disclosure of certain information when a company manufactures or contracts to manufacture products for which minerals specified
in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite
(coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (the “Conflict
Minerals”). The “Covered Countries” for 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. Certain
of the Company’s operations manufacture, or contract to manufacture, products for which the Conflict Minerals are necessary
to the functionality or production of those products. The Company has conducted a good faith, reasonable country of origin inquiry
regarding the Conflict Minerals. This good faith, reasonable country of origin inquiry was designed to determine whether any of
the Conflict Minerals originated in the Covered Countries. Based on this reasonable country of origin inquiry, the Company is unable
to determine at this time whether Conflict Minerals necessary to the functionality or production of the Company’s products
manufactured in calendar year 2019 originated in the Covered Countries.
As part of the reasonable country of origin inquiry, the Company
identified several key suppliers and distributors for the reporting period from January 1, 2019 to December 31, 2019. As the majority
of the Company’s key suppliers are distributors, they are aware of many environmental and corporate social responsibility
issues, however their positions as a distributor relieve them from Conflict Minerals reporting obligations, since they do not manufacture
or contract to manufacture any products or components. As such, our distributors referred us to contact manufacturers directly
for due diligence information.
Based on distributors’ feedback, the Company performed
the following due diligence activities:
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Directly contacted the manufacturers and conducted a good-faith reasonable country of origin inquiry (“RCOI”) to
determine the origin of any Conflict Minerals contained in the Company’s products.
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Confirmed manufacturers’ conflict materials information through the Electronic Components Industry Association (ECIA).
ECIA develops a webpage per the following link that includes a list of companies that provide information on conflict materials.
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https://www.ecianow.org/industry-issues/conflict-materials/member-company-information/
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Based on the foregoing,
the Company is unable to definitively determine at this time whether Conflict Minerals necessary to the functionality or production
of the Company’s products manufactured in calendar year 2019 originated in the Covered Countries.
The Company has filed its conflicts mineral disclosure and report
on this Form SD, which is posted (and publicly available) on the Company’s website: www.bioniklabs.com (http://www.bioniklabs.com/investors/secfilings.htm).
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 undersigned thereto duly authorized.
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BIONIK LABORATORIES CORP.
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(Registrant)
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DATE: June 1, 2020
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By:
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/s/ Leslie Markow
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Leslie Markow
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Chief Financial Officer
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