GENC Gencor Industries Inc

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

GENCOR INDUSTRIES, INC.

(Exact name of Registrant as specified in its charter)

Eric E. Mellen

(407) 290-6000

(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:

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

A copy of Gencor Industries, Inc.’s Conflict Minerals Report for the period from January 1 to December 31, 2023 is filed as Exhibit 1.01 and is incorporated herein by reference.

Item 1.02 Exhibit

The Company has prepared a Conflict Minerals Report, which is attached to this specialized disclosure report on Form SD as Exhibit 1.01.

Section 2 – Exhibits

Item 2.01 Exhibits

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

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 hereunto duly authorized.

Date: May 30, 2024

Exhibit 1.01

Gencor Industries, Inc.

Conflict Minerals Report

This report for the year ended December 31, 2023 has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for Gencor Industries, Inc. (“we”, the “Company” or “Gencor”). 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”). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (“Conflict Minerals” or “3TG”).

In accordance with the Rule, we conducted a Reasonable Country of Origin Inquiry (“RCOI”) to determine if any of our products contain Conflict Minerals originating from the Democratic Republic of the Congo (“DRC”) or an adjoining country (“Covered Countries”).

Company and Product Overview

Gencor designs, manufactures, and sells equipment used primarily for the production of asphalt in highway construction. The Company’s principal products include asphalt pavers, asphalt plants, combustion systems, and fluid heat transfer systems. The Company believes that its technical and design capabilities and environmentally friendly process technology have enabled it to become a leading manufacturer of asphalt pavers and plants.

Conflict Minerals Policy

Gencor is committed to work closely with its supply chain to ensure we comply with the requirements set forth in Section 1502 of the Dodd-Frank Act. Gencor does not knowingly source any products containing Conflict Minerals. We do not directly source 3TG from mines, smelters or refiners. The Company relies on its suppliers to provide accurate and reliable information about 3TG in the supply chain. We expect our suppliers to have policies in place and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing 3TG are from countries other than the DRC or Covered Countries. We are several steps removed in the supply chain from mines, smelters or refiners, limiting our influence over their sourcing. However, we seek to ensure that our sourcing practices are consistent with the expectations provided in our Conflict Minerals Policy.

Due Diligence Efforts

We have relationships with a network of suppliers. The Company’s supply chain is complex and there are multiple tiers between the mines where Conflict Minerals are extracted and our suppliers. In accordance with the Rule we undertook a country of origin inquiry to determine the source of any Conflict Minerals.

The principal raw material used in manufacturing our products is carbon steel. The products that we manufacture do not typically contain 3TG.

We conducted a RCOI regarding the Conflict Minerals. This inquiry was reasonably designed and performed in good faith to determine whether any of such Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may have been from recycled or scrap sources.

The Company is not aware that it has direct relationships with Conflict Minerals smelters, refiners or distributors and therefore did not perform or direct audits of such entities. However, the Company encourages audits to be conducted by its suppliers and supports third party audits. As a result of this reasonable due diligence and country of origin inquiry, the Company has determined to the best of its knowledge that none of its products for the period covered by this report contained any “conflicts minerals” originating from the Democratic Republic of the Congo or an adjoining country.

Future Actions

We continue to communicate with our suppliers to obtain information about our supply chain, vet all new suppliers for their ability to comply with the RCOI criteria of the Rule conform with the framework in The Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold, tin, tantalum and tungsten, and encourage suppliers to increase the participation rate of smelters and refiners in the Conflict-Free Smelter Program. We expect to continue our risk mitigation efforts, monitor evolving best practices and implement those we believe will help us address the ongoing issue of Conflict Minerals in the global supply chain.