TAT Technologies : Conflict Minerals Report 2022

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form SD

SPECIALIZED DISCLOSURE REPORT

TAT TECHNOLOGIES LTD.

(Exact Name of Registrant as Specified in Charter)

Section 1 - Conflict Minerals Disclosure

TAT Technologies Ltd. (the "Company") evaluated its current product lines and determined that certain products it manufactures or contracts to manufacture contain Gold and Tin that are necessary to the functionality or production of its products. These minerals are considered within the scope of the relevant "Conflict Minerals" or "3TG" which are defined as Gold, Tantalum, Tungsten and Tin.

Based on a reasonable country of origin inquiry ("RCOI") performed, the Company cannot yet determine with complete certainty whether the necessary Conflict Minerals used in its products originate, or likely originate, entirely from recycled or scrap sources or if the Conflict Minerals originated or may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (collectively referred to as the "Covered Countries").

TAT has examined the existence of conflict minerals in the production processes of its products.

The assessment revealed that only 2 out of hundreds of suppliers TAT is working with are suspected of using them. The total spend for buying from those suppliers in 2022 was approximately 1.2% of the company's total purchasing, which is considered negligible.

Nevertheless, we are filing a Conflict Minerals Report. The Company carries out due diligence on its mineral supply chain according to the guidelines and framework established by the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related Supplements (the "OECD Due Diligence Guidance").

A copy of The Company's Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at: www.TAT-Technologies.com under "Investors", or at the following link: ttps://tat-technologies.com/wp-content/uploads/2023/05/TAT-Conflict-Minerals-Report-RY2022.pdf

The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.

Section 2 - Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

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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 undersigned, thereunto duly authorized.

TAT TECHNOLOGIES LTD.(Registrant)

By: /s/ Ehud Ben-Yair

Ehud Ben-Yair

Chief Financial Officer

Date: May 31, 2023

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Exhibit 1.01

TAT Technologies Ltd.

Conflict Minerals Report

For The Year Ended December 31, 2022

This report for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission ("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 ("Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain, or likely contain, Conflict Minerals that are necessary to the functionality or production of their products. Conflict Minerals are defined as tin, tantalum, tungsten, and gold ("3TG") for the purposes of this assessment. These requirements apply to registrants whatever the likely geographic origin of the Conflict Minerals and whether or not they fund, directly or indirectly, or benefit armed conflict in the affected regions as defined per the Rule, i.e. the Democratic Republic of the Congo ("DRC") and the adjoining countries ("Covered Countries"). As part of the company's desire to take responsibility for and concern themselves with human rights issues, we decided to review the company's supply chain according to the EU regulation's guidance as well, and within that have included conflict-affected or high-risk areas ("CAHRAs") when approaching suppliers for information.

If a registrant cannot establish with absolute certainty that the Conflict Minerals originated from sources other than the DRC and the Covered Countries, or if they are unable to determine the likely country of origin of those Conflict Minerals that are necessary to the production or functionality of their products, or if they cannot determine whether the necessary Conflict Minerals originate solely from recycled or scrap sources, the registrant must submit a Form SD that describes the Reasonable Country of Origin Inquiry ("RCOI") that was performed within the mineral supply chain. Furthermore, the registrant must also exercise due diligence on the Conflict Minerals' source and chain of custody and must annually submit a Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. TAT is a downstream company, in that the Company's direct suppliers purchase cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which presently are limited to tin, tantalum, tungsten, and gold (collectively "3TG") -related materials after processing by smelters or refiners ("SORs"). As a result, any information reported on smelters or refiners was gathered from information reported to us by our direct suppliers and we do not collect information on the source and chain of custody of the necessary Conflict Minerals directly from the smelters or refiners, or the facilities that process and mine 3TG.

1. Company Overview

This report has been prepared by the management of TAT Technologies Ltd. (herein referred to as "TAT" the "Company," "we," "us," or "our"). The information includes the activities of all relevant subsidiaries that are required to be consolidated.

TAT Technologies Ltd. is a leading provider of services and products to the commercial and military aerospace and ground defense industries. TAT operates under four segments: (i) OEM of heat transfer solutions and aviation accessories; (ii) MRO services for heat transfer components and OEM of heat transfer solutions; (iii) MRO services for aviation components; and (iv) overhaul and coating of jet engine components.

TAT's activities in the area of OEM of heat transfer solutions and aviation accessories through its Gedera facility primarily include the design, development and manufacture of (i) a broad range of heat transfer solutions, such as pre-coolers heat exchangers and oil/fuel hydraulic heat exchangers, used in mechanical and electronic systems on board commercial, military and business aircraft; (ii) environmental control and power electronics cooling systems installed on board aircraft and ground applications; and (iii) a variety of other mechanical aircraft accessories and systems such as pumps, valves, and turbine power units.

TAT's activities in the area of MRO and OEM of heat transfer solutions include the MRO of heat transfer components and to a lesser extent, the manufacturing of certain heat transfer solutions. TAT's Limco subsidiary operates an FAA-certified repair station, which provides heat transfer MRO services for airlines, air cargo carriers, maintenance service centers and the military.

TAT's activities in the area of MRO services for aviation components include the MRO of APUs, landing gears and other aircraft components. TAT's Piedmont subsidiary operates an FAA- certified repair station, which provides aircraft component MRO services for airlines, air cargo carriers, maintenance service centers and the military.

TAT's activities in the area of jet engine overhaul through its Turbochrome facility includes the overhaul and coating of jet engine components, including turbine vanes and blades, fan blades, variable inlet guide vanes and afterburner flaps.

2. Products Overview

TAT is principally engaged in the following activities:

• Design, development, manufacture and sale of a broad range of heat transfer equipment and solutions;
• Remanufacture, overhaul and repair of heat transfer equipment;
• Maintenance, repair and overhaul of auxiliary power units, landing gears and related components;
• Design, development and manufacture of aviation and flow control accessories including fuel components, secondary power systems, and various instrumentation and electronic assemblies; and
• Design, development and manufacture of environmental control and cooling systems.
• Overhaul and coating of jet engine components

The products developed, repaired, and maintained by TAT are primarily used for airborne systems on commercial and military aircrafts as well as for defense ground systems. The principal markets of TAT are in Israel, Europe and the United States.

Based on TAT's internal assessment that included a review of all company products in order to identify the products that may include the relevant minerals, the Company uses Gold and Tin out of the relevant 3TG minerals according to the specifications of the Rule in its OEM manufacturing processes and as such the relevant materials may be included in Heat Exchangers Cores and Air Conditioners manufactured by us. TAT's other activities have been excluded from the process since these activities involve repair and maintenance services, which are excluded from the Rule's requirements.

3. Reasonable Country of Origin Inquiry (RCOI)

Based on our product analysis, TAT has concluded in good faith that during the calendar year 2022, Gold and Tin, which are considered "Conflict Minerals" as per the Rule, can be found in our products that were manufactured or that were contracted to manufacture in 2022 and that are necessary to their production and/or functionality. Therefore, the products that we manufacture are subject to the reporting obligations of Rule 13p-1. A list of suppliers that TAT Technologies purchased from during calendar year 2022, was issued using TAT's IT systems by the purchasing department manager.

We have examined whether Turbochrome's activities should be considered in or outside the scope of the Conflict Minerals Rule. In order to do so we have heeded the advice of our legal advisors, stipulating that Turbochrome is not considered in scope as it predominately provides maintenance and repair services.

This decision was based on the following stated exclusions to Conflict Minerals Rule:

1. Not contracting to manufacture if the issuer tests, services, maintains, or repairs a product, (Final Rule p.22,60), even if in the course of such activity a part containing conflict minerals is introduced into the product.
2. If a company provides a service utilizing a product that contains conflict minerals, the service provider will not be subject to the rule. (SEC FAQ #7) (Shearman & Sterling p.5) For example, a cruise line is a service provider; a shipyard is a manufacturer.

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