Conflict Minerals Disclosure
Click here to access the Form SD most recently filed by Reliance Steel & Aluminum Co., the text of which appears below.
This Form SD of Reliance Steel & Aluminum Co. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 (the “1934 Act”) for the reporting period January 1, 2018 to December 31, 2018. Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule 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 Company is a metals service center company that acquires carbon steel, aluminum, stainless and alloy steel and other metal products from primary metals producers and then processes these materials to meet customer specifications using techniques such as blanking, leveling (or cutting-to-length), sawing, shape cutting, shearing and slitting, among others. Through its network of metals service centers, the Company distributes a full line of more than 100,000 metal products to more than 125,000 customers in a broad range of industries. Certain of these products contain conflict minerals necessary to the functionality or production of products manufactured by the Company or contracted by the Company to be manufactured.
Reasonable Country of Origin Inquiry
The Company has a policy to only purchase product that is DRC conflict free. To confirm the DRC conflict free status of products provided by suppliers that the Company manufactured or contracted to manufacture in 2018, the Company conducted in good faith a reasonable country of origin inquiry that was reasonably designed to determine whether any of the conflict minerals contained in such products originated in the Democratic Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (collectively, the “Covered Countries”), or are from recycled or scrap sources. The Company communicated individually to all of its suppliers that as a prerequisite to supply products to the Company, including any of its subsidiaries, each supplier must certify that (i) the products provided by the supplier to the Company do not contain conflict minerals; (ii) the products provided by the supplier to the Company that contain any conflict minerals did not originate from any of the Covered Countries and the supplier has implemented procedures to identify and monitor the origin of products (other than those from recycled or scrap sources) that contain conflict minerals; (iii) the products supplied by supplier to the Company that contain any conflict minerals are from recycled or scrap sources; and/or (iv) the products supplied by supplier to the Company that contain any conflict minerals were “outside the supply chain” prior to January 31, 2013.
The Company received certifications from all of its significant suppliers. Each certification provided by a supplier was reviewed by an internal conflict minerals working group at the corporate level and, if adequate to support reasonably a DRC conflict free status determination based on the criteria set forth in the 1934 Act Release No. 34-67716, the supplier was designated as an approved supplier to the Company. Supplier responses deemed insufficient to support a determination that all of the products supplied to the Company by the supplier are DRC conflict free triggered follow-up discussions with the supplier. In some instances such discussions resulted in a product level certification from the supplier of the DRC conflict free status of certain specified products that the Company then approved for purchase from that supplier. In other instances, the Company ceased purchases from suppliers who were unable to certify the DRC conflict free status of their products to the Company’s satisfaction.
Based on the reasonable country of origin inquiry described above, the Company, except as noted below, has determined for the year ended December 31, 2018 that conflict minerals that are necessary to the functionality or production of the Company’s products (i) did not originate in any of the Covered Countries; (ii) did come from recycled or scrap sources; and/or (iii) were “outside the supply chain” prior to January 31, 2013. A very small number of suppliers for a limited number of products responded that they did not have sufficient information to make the certification described above. However, based on the responses received, the Company has no reason to believe that any conflict minerals that are necessary to the functionality or production of such products may have originated in any of the Covered Countries.
The Company’s internal audit team is engaged in a periodic review of compliance with our policy and procedures related to the conflict minerals rule across our businesses.
This Conflict Minerals Disclosure is publicly available on the Company’s Internet website at www.rsac.com. The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD nor deemed filed with the U.S. Securities and Exchange Commission.
Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions of the terms used above, unless otherwise defined herein.