Section 1 Conflict Minerals Disclosure
Item 1.01. Conflict Minerals Disclosure and Report
Introduction
This report is being filed by
Commercial Metals Company (together with its consolidated subsidiaries, CMC) for the calendar year ended December 31, 2022, in compliance with Rule 13p-1 (the
Rule) of the Securities Exchange Act of 1934, as amended.
The Rule was adopted by the Securities and Exchange Commission (the
SEC) to establish reporting and disclosure requirements in support of mandates under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
Company Overview
As of December 31, 2022,
CMC and its subsidiaries manufacture, recycle and fabricate steel and metal products, related materials and services through a network of facilities that includes seven electric arc furnace (EAF) mini mills, two EAF micro
mills, a rerolling mill, steel fabrication and processing plants, construction-related product warehouses and metal recycling facilities in the United States and Poland. As of December 31, 2022, CMCs core business is the manufacture and
sale of steel products. CMC operates steel mills in the United States and Poland. Through its Tensar operations, CMC is also a leading global provider of innovative ground and soil stabilization solutions selling into more than 80 national markets
through two major product lines: Tensar® geogrids and Geopier® foundation systems.
Conflict Minerals Disclosure
CMC conducted a
centrally coordinated product review to identify conflict minerals, as defined by the SEC, which exist in products manufactured and sold by CMC, and which are necessary to the functionality or production of those products. For the calendar year
ended December 31, 2022, CMC engaged procurement and product experts across all product lines and business units to conduct the review.
With regard
to products manufactured and sold by CMC, it is CMCs finding that any conflict minerals contained in such products originated solely from scrap metal sources and are unnecessary to the functionality or production of such products. Although
some residual amount of the derivatives of tin, tantalum or tungsten may be present in steel products manufactured and sold by CMC, such conflict minerals come from scrap metal sources. Further, such conflict minerals are not necessary to the
functionality or production of the steel products manufactured by CMC.
Reasonable Country of Origin Inquiry
CMC conducted a reasonable country of origin inquiry (RCOI) in good faith and in full consideration of the SECs guidance for
the calendar year ended December 31, 2022. Specifically, CMC identified the suppliers of any such raw materials and requested vendor certifications, in the form of the Conflict Minerals Reporting Template specifically designed to determine
whether conflict minerals originated in the Democratic Republic of the Congo or an adjoining country, as defined by the SEC, (collectively, the Covered Countries) or were obtained from recycled or scrap sources, as defined
by the SEC. This information was accumulated and summarized to determine whether further due diligence procedures were necessary, and to determine the applicable Form SD reporting requirements. Given the results, no further due diligence procedures
were required.