Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Builders FirstSource, Inc., a Delaware
corporation formed in 1998, is a leading supplier of building materials, manufactured components and construction services to professional contractors,
and consumers. In this specialized
disclosure report, references to the company, we, our, ours or us refer to Builders FirstSource, Inc. and its consolidated subsidiaries.
(the Rule) promulgated under the Securities Exchange Act of 1934, as amended, requires public
disclosure of certain information when a company manufactures or contracts to manufacture products that include cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum or tungsten (collectively,
the Conflict Minerals), that are necessary to the functionality or production of such products. For purposes of the Rule, the Covered Countries are the Democratic Republic of the Congo or any of its adjoining countries,
which, for the period covered by this report, are the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Conflict Minerals Disclosure
During 2018, we undertook a
comprehensive review of the products that we manufacture or contract to have manufactured. This review included an analysis of all of the components utilized in these products to determine (i) which products may contain Conflict Minerals and
(ii) the identification of all suppliers from whom we source components that may contain Conflict Minerals. Our senior manufacturing personnel and internal legal counsel were involved with this analysis and approved the scope of the analysis as
well as the reasonable country of origin inquiry described below. Based upon this internal review, we determined that certain components utilized in our manufacturing processes or incorporated into our manufactured or contracted to manufacture
products likely contained Conflict Minerals that were necessary to the functionality or production of such products.
As a result of this comprehensive
product review, we initiated a good faith reasonable country of origin inquiry as required by the Rule. Our inquiry was designed to determine whether any of the Conflict Minerals that were necessary to the functionality or production of our
manufactured or contracted to manufacture products during the 2018 calendar year originated in any of the Covered Countries and whether any of the Conflict Minerals were from recycled or scrap sources. We adopted the Conflict Minerals reporting
template established by the Conflict-Free Sourcing Initiative and sent this template to all suppliers that we identified as potentially supplying us with Conflict Minerals for our manufactured or contracted to manufacture products. All of these
suppliers were asked to complete the Conflict Minerals reporting template established by the Conflict-Free Sourcing Initiative and to disclose whether Conflict Minerals were present in the products we purchased from them and, if so, the country of
origin of the Conflict Minerals.
We received responses from suppliers that accounted for substantially all of the total components we purchased in 2018
that we determined likely contained Conflict Minerals that were necessary to the functionality or production of products we manufacture or contract to manufacture. We also followed up with those suppliers that failed to timely complete the reporting
template or that provided incomplete or inconsistent responses.