BACKGROUND
This Specialized Disclosure Report on Form SD of Carpenter Technology Corporation (Carpenter) for the year ended December 31,
2021 is submitted 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). 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 (the Minerals). Please refer to the Rule and to SEC Release
No. 34-67716 for other definitions of terms used in this Report.
Carpenter develops,
manufactures and distributes cast/wrought and powder metal stainless steels and specialty alloys, including high temperature (iron-nickel-cobalt base), stainless, superior corrosion resistant, controlled expansion alloys, ultra high-strength and
implantable alloys, tool and die steels, and other specialty metals as well as titanium alloys. Carpenters products are used in many major markets, including aerospace and defense, energy, medical, transportation, and industrial and consumer.
Certain Carpenter products may contain the Minerals tungsten, tantalum and/or tin. Carpenter purchases these Minerals from suppliers as
raw materials or as scrap. As a result of this, Carpenter has performed a Reasonable Country of Origin Inquiry to determine whether any of its Minerals may have originated in the Democratic Republic of the Congo or one of the covered countries under
the Rule.
Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, Carpenter hereby submits this
Specialized Disclosure Report on Form SD for calendar year 2021.
Description of Reasonable Country of Origin Inquiry
The following briefly describes the process Carpenter followed in order to conduct a Reasonable Country of Origin Inquiry.
Carpenter carefully reviewed the Conflict Mineral Rule to determine which Business Units either manufactured or contracted to manufacture
products which were subject to the Rule. Carpenter then surveyed all of its Business Units that were subject to the Rule to determine if any materials necessary to the functionality or production of our products contained the Minerals. Carpenter was
aware that none of its products contained gold, so the focus was on tantalum, tungsten and tin. Some of Carpenters manufactured products did contain materials purchased as raw materials or as scrap containing tantalum, tungsten and tin.
Carpenter identified all of its suppliers from whom it purchased materials containing the Minerals from January 1, 2021 to
December 31, 2021. After excluding purchases deriving from a scrap source in accordance with the Rule, Carpenter sent a survey to each supplier. The supplier surveys were sent in the form of the Conflict Minerals Reporting Template (the
template), a standardized reporting template developed by the Responsible Minerals Initiative. The template was developed to facilitate the transfer of information through the supply chain regarding mineral country of origin and identify
smelters and refiners which processed the necessary conflict minerals contained in products. Carpenter received responses from each supplier identified and reviewed the responses to determine where the Minerals were smelted.