Section 1 Conflict Minerals Disclosure
Item 1.01
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Conflict Minerals Disclosure and Report
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Overview
Alcoa Corporation (Alcoa or the
Company) is a global industry leader in bauxite, alumina, and aluminum products.
Unless the context indicates otherwise, the terms
Alcoa, Company, we, us and our refer to Alcoa Corporation and all subsidiaries consolidated for the purposes of its financial statements that were
in-scope
for the 2018 compliance period. The Conflict Minerals Rule means, collectively, Rule
13p-1
under the Securities Exchange Act of 1934, as amended
(the Exchange Act), and the Specialized Disclosure Report on Form SD pursuant to Rule
13p-1
promulgated under the Exchange Act. As used herein and consistent with the Conflict Minerals Rule,
Conflict Minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.
Conflict Minerals Disclosure
This Form SD is publicly
available on our website,
www.alcoa.com
, under the Investors section. The information contained on our website is not incorporated by reference into this Form SD and should not be considered part of this Form SD.
Alcoas processes and procedures described below were designed to determine whether the Conflict Minerals intentionally added and necessary to the
functionality or production of products we manufactured during 2018 originated in the Democratic Republic of the Congo or adjoining countries, as defined under the Conflicts Minerals Rule (collectively, the Covered Countries), or
otherwise originated from scrap or recycled materials.
Procedures and Reasonable Country of Origin Inquiry
For 2018, each Alcoa business unit conducted an assessment to determine whether its manufactured products contained any Conflict Minerals that were necessary
to the functionality or production of such products (any such manufactured products containing Conflict Minerals are referred to herein as Covered Products). This assessment involved an internal review of all materials that become part
of Covered Products and may include a review of product specifications, bills of material, supplier inquiries, product composition analyses, and other information about such Covered Products known to us. This assessment is also conducted by each
business unit as new products that could come within the scope of the Conflict Minerals Rule are developed. In addition, each business unit identified, for all Covered Products it manufactures, any purchased materials that include Conflict Minerals
used in the manufacture of such Covered Products, as well as the suppliers of such purchased materials, through a review of purchase records for such Covered Products.
Having followed the described procedures, we believe that we identified, for the 2018 reporting period, all Covered Products containing Conflict Minerals. The
only Conflict Mineral included in our Covered Products during 2018 was tin. We identified two suppliers likely to have supplied Conflict Minerals to us in connection with our Covered Products.
Following this assessment, Alcoa conducted a good faith reasonable country of origin inquiry (the RCOI) within the meaning of the Conflict
Minerals Rule to determine the origin of the Conflict Minerals contained in its Covered Products for the 2018 reporting period. Alcoa requested that each supplier of such Conflict Minerals complete the Conflict Minerals Reporting Template
(CMRT) developed by the Responsible Minerals Initiative (RMI) (formerly the Conflict-Free Sourcing Initiative), with a response at the Covered Product level to the extent possible, in order to identify the origin of the
Conflict Minerals in such products. Specific Conflict Minerals smelters identified by our suppliers in the completed CMRTs were reviewed against the Responsible Minerals Assurance Process (RMAP) conformant smelter and refiner lists and
other publicly-available information to confirm that all such smelters were conformant with the RMAP assessment procedure (managed by RMI, which formerly was known as the Conflict-Free Smelter Program). RMAP conformant smelters have undergone an
independent, third-party audit of their management systems and sourcing practices to validate compliance with protocols and current global standards to support responsible sourcing of raw materials.
Alcoa also reviewed any supporting documentation and other statements from suppliers. All completed CMRTs and other responses and documentation were reviewed
for accuracy, completeness, and overall reasonableness to evaluate and determine whether the suppliers provided information upon which Alcoa may reasonably rely. Further inquiry and engagement with suppliers were performed as necessary to obtain
additional or complete information or clarification. Alcoa received, from all
in-scope
suppliers for 2018, adequate responses and appropriate information relating to the countries of origin of the Conflict
Minerals relevant to its Covered Products as well as whether the Conflict Minerals were produced from scrap or recycled materials, thus enabling it to complete the RCOI process.
Conclusion
On the basis of the described internal review
and RCOI processes undertaken, Alcoa believes that, for 2018, the Conflict Minerals included in its Covered Products either (i) did not originate in the Covered Countries or (ii) were from scrap or recycled materials.