Specialized Disclosure Report (sd)
May 28 2020 - 11:56AM
Edgar (US Regulatory)
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
FORM SD
Specialized Disclosure Report
STEEL DYNAMICS, INC.
(Exact name of registrant as specified in
its charter)
Indiana
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0-21719
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35-1929476
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(State
or other jurisdiction of
incorporation)
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(Commission File Number)
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(IRS Employer
Identification No.)
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7575 West Jefferson Blvd, Fort Wayne, Indiana 46804
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(Address of principal executive offices) (Zip Code)
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Theresa E. Wagler 260-969-3500
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(Name and telephone number, including area code, of the person to contact in connection with this report.):
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Check the appropriate box below to indicate the rule pursuant
to which this form is being filed, and provide the period to which the information in this form applies:
x
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2019 to December 31,
2019.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Steel Dynamics, Inc.
(the “company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended
(the “Rule”), for the reporting period January 1, 2019 to December 31, 2019. 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 defined as cassiterite,
columbite-tantalite, wolfromite, gold and their derivatives, which are limited to tin, tantalum, tungsten and gold (the
“Conflict Minerals”). The “Covered Countries” for purposes of the Rule 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.
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1.
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Determination Disclosure, Company and Products Overview
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Steel Dynamics, Inc. is one of the largest
steel producers and metals recyclers in the United States based on current estimated steelmaking and coating capability and actual
metals recycling volumes, with one of the most diversified, high-margin steel product portfolios. Our primary sources of revenue
are from the manufacture and sale of steel products, the processing and sale of recycled ferrous and nonferrous metals, and the
fabrication and sale of steel joists and deck products. We have three reporting segments: steel operations, metals recycling operations,
and steel fabrication operations.
Our internal and supply chain assessment
yielded no Conflict Minerals contained on and/or within, and necessary to, the functionality of products we manufacture and sell.
Our metals recycling operations acquire and process post-industrial and post-consumer scrap or recycled metals that on occasion
may contain any of the Conflict Minerals.
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2.
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Reasonable Country of Origin Inquiry Results
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Due to the fact that our internal and supply
chain assessment yielded no Conflict Minerals contained on and/or within, and necessary to, the functionality of products we manufacture
and sell, the company was not required by the Rule to conduct a good faith reasonable country of origin inquiry regarding identified
Conflict Minerals. Conflict Minerals acquired and processed by our metals recycling operations are all from recycled or scrap sources,
and thus, as defined in Rule 13p-1, are considered Conflict Free.
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3.
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Reasonable Country of Origin Inquiry Process
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Although not required by the Rule, the
company voluntarily conducted a reasonable country of origin inquiry for calendar year 2019, which was completed in conjunction
with internal assessment teams at each of our subsidiaries and/or divisions. These internal assessment teams consisted of persons
in a position to know and understand the material inputs and processes utilized in the manufacture of our products, including the
location’s General Manager (or their equivalent), and as appropriate, personnel in purchasing, metallurgy, quality control,
engineering, and other areas. The internal assessment teams identified the raw materials that are introduced and/or contained in,
or on, our manufactured products that are necessary to the functionality or production of said products, and assessed if they may
contain Conflict Minerals. We identified the vendors of any such raw materials and requested vendor certifications, in the form
of the Conflict Minerals Reporting Template (CMRT) developed by the Conflict Free Sourcing Initiative (CFSI), an initiative of
the Electronic Industry Citizens Coalition (EICC) and Global e-Sustainability Initiative (GeSI), concerning the absence or possible
presence of Conflict Minerals in the products they supplied to us. If any Conflict Minerals were noted (of which none were), vendors
were requested to indicate whether such Conflict Minerals originated from a Covered Country, or from a recycler or scrap supplier.
All vendor certifications were thoroughly analyzed, including the absence or existence of Conflict Minerals, and if present (of
which none were), country of origin information, smelter information, and whether it came from recycled or scrap sources. This
subsidiary and/or division level information was accumulated and summarized to determine whether further due diligence procedures
were necessary, and to determine the applicable Form SD reporting requirements. No further due diligence procedures were required.
This information is publically available
at the company’s website: www.steeldynamics.com under the Investors section, SEC Filings.
Item 1.02 Exhibit
None
Section 2 – Exhibits
None
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 hereto duly authorized.
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STEEL DYNAMICS, INC.
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/s/Theresa
E. Wagler
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Date: May 28, 2020
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By:
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Theresa E. Wagler
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Title:
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Executive Vice President and
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Chief Financial Officer
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