UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
CommercialMetals Company
(Exact name of registrant as specified in its charter)
Delaware 1-4304 75-0725338
(State or other jurisdiction (Commission (IRS Employer
of incorporation or organization) File Number) Identification No.)
6565 N. MacArthur Blvd. 75039
Irving, Texas
(Address of principal executive offices) (Zip Code)
Jody K. Absher
Senior Vice President, Chief Legal Officer and Corporate
Secretary
(214)
689-4300
(Name and telephone number, including area code, of the person to contact in
connectionwith this report.)
Check the appropriate box to indicate the rule pursuant to which this form is
being filed, and provide the period to which the information in this
formapplies:
Rule
13p-1
under the Securities Exchange Act (17 CFR
240.13p-1)
for the reporting period from January 1 to December 31, 2023.
Rule
13q-1
under the Securities Exchange Act (17 CFR
240.13q-1)
for the fiscal year ended
.
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Section 1 - Conflict Minerals Disclosure
Item 1.01. Conflict Minerals Disclosure and Report
Introduction
This report is being filed byCommercial Metals Company (together with its
consolidated subsidiaries, "
CMC
") for the calendar year ended December 31, 2023, in compliance with Rule
13p-1
(the"
Rule
") of the Securities Exchange Act of 1934, as amended.
The Rule was adopted by the United States (the"
U.S.
") 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 andConsumer Protection
Act of 2010.
Company Overview
As of December 31, 2023, CMC manufactures, recycles and fabricates steel and
metal products, related materials and services through a network offacilities
that includes seven electric arc furnace ("
EAF
") mini mills, three EAF micro mills, a rerolling mill, steel fabrication and
processing plants, construction-related product warehouses and metal recycling
facilitiesin the U.S. and Poland. As of December 31, 2023, CMC's core business
is the manufacture and sale of steel products. CMC operates steel mills in the
U.S. and Poland. Through its Tensar operations, CMC is also a leading global
provider ofinnovative ground and soil stabilization solutions selling into
more than 80 national markets through two major product lines: Tensar
(R)
geogrids and Geopier
(R)
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
byCMC, and which are necessary to the functionality or production of those
products. For the calendar year ended December 31, 2023, 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 CMC's finding that
any conflict minerals contained in such products originated solelyfrom
recycled or scrap 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, suchconflict minerals come from recycled or scrap 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 areasonable country of origin inquiry ("
RCOI
") in good faith and in full consideration of the SEC's guidance for the
calendar year ended December 31, 2023. Specifically, CMC identified the
suppliers of any such rawmaterials 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, asdefined 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 diligenceprocedures were necessary, and to determine the applicable Form
SD reporting requirements. Given the results, no further due diligence
procedures were required.
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Reasonable Country of Origin Inquiry Conclusion
CMC has evaluated the results of the RCOI in good faith and in full
consideration of the SEC's guidance, and finds no reason to believe that any
conflictminerals present in steel products manufactured and sold by CMC are
necessary to the functionality or production of those products or originated
in the Covered Countries.
Other Information
The information in this Form SD isalso publicly available on the "Investors"
section, "Filings and Annual Reports" subsection, of CMC's website at
www.cmc.com
. This link is provided for convenience only. The content of CMC's website
does notconstitute a part of this Form SD.
Item 1.02. Exhibit
Not required.
Section
2 -Exhibits
Item 2.01. Exhibits
None.
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SIGNATURES
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
dulyauthorized undersigned.
COMMERCIAL METALS COMPANY
May 24, 2024 By: /s/ Jody K. Absher
Name: Jody K. Absher
Title: Senior Vice President, Chief Legal Officer and Corporate Secretary