Specialized Disclosure Report (sd)
18 Mai 2023 - 3:21PM
Edgar (US Regulatory)
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
RELIANCE STEEL & ALUMINUM CO.
(Exact name of registrant as specified in its charter)
Delaware |
001-13122 |
95-1142616 |
(State or other jurisdiction of
incorporation or organization) |
(Commission File Number) |
(I.R.S. Employer
Identification No.) |
16100 N. 71st Street, Suite 400
Scottsdale, Arizona 85254 |
(Address of principal executive offices) |
William A. Smith II
Senior Vice President, General Counsel and Corporate
Secretary
(480) 564-5700
(Name and telephone number, including area code,
of the person to contact in connection with 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 form applies:
| x | Rule
13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022. |
Section 1 – Conflict Minerals Disclosure
| Item 1.01 | Conflict Minerals Disclosure and Report |
Conflict Minerals Disclosure
This Form SD of Reliance Steel & Aluminum
Co. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 (the “1934
Act”) for the reporting period January 1, 2022 to December 31, 2022. 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 gold, columbite-tantalite (coltan), cassiterite and wolframite, including
their derivatives, which are limited to tantalum, tin and tungsten (the “conflict minerals”).
The Company is a leading diversified metal solutions
provider that acquires alloy, aluminum, brass, copper, carbon steel, stainless steel, titanium and specialty steel products from primary
metals producers and then processes these materials to meet customers’ specifications. Our primary processing services range from
cutting, leveling, or sawing to more complex processes such as machining or electropolishing. Through its network of approximately 315
locations in 40 U.S. states and in 12 foreign countries, the Company distributes a full line of over 100,000 metal products to more than
125,000 customers in a variety of industries. Conflict minerals are necessary to the functionality or production of certain products manufactured
by the Company or contracted by the Company to be manufactured.
Reasonable Country of Origin Inquiry
The Company has a policy to only purchase product
that is DRC conflict free. To confirm the DRC conflict free status of products provided by suppliers that the Company manufactured or
contracted to manufacture in 2022, the Company conducted in good faith a reasonable country of origin inquiry that was reasonably designed
to determine whether any of the conflict minerals contained in such products originated in the Democratic Republic of the Congo (DRC),
the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (collectively,
the “Covered Countries”), or are from recycled or scrap sources. The Company communicated individually to all of its suppliers
that as a prerequisite to supply products to the Company, including any of its subsidiaries, each supplier must certify that (i) the products
provided by the supplier to the Company do not contain conflict minerals; (ii) any conflict minerals contained in the products provided
by the supplier to the Company did not originate from any of the Covered Countries and the supplier has implemented procedures to identify
and monitor the origin of conflict minerals (other than those from recycled or scrap sources) contained in the products; (iii) conflict
minerals contained in the products supplied by the supplier to the Company are from recycled or scrap sources; and/or (iv) any conflict
minerals contained in the products supplied by the supplier to the Company were “outside the supply chain” prior to January
31, 2013.
The Company received certifications from all of
its significant suppliers. Each certification provided by a supplier was reviewed by an internal conflict minerals working group at the
corporate level and, if adequate to support reasonably a DRC conflict free status determination based on the criteria set forth in the
instructions to Form SD, the supplier was designated as an approved supplier to the Company. Supplier responses deemed insufficient to
support a determination that all of the products supplied to the Company by the supplier are DRC conflict free triggered follow-up discussions
with the supplier. In some instances such discussions resulted in a product level certification from the supplier of the DRC conflict
free status of certain specified products that the Company then approved for purchase from that supplier. In other instances, the Company
ceased purchases from suppliers who were unable to certify the DRC conflict free status of their products to the Company’s satisfaction.
Based on the reasonable country of origin
inquiry described above, the Company, except as noted below, has determined for the year ended December 31, 2022 that conflict
minerals that are necessary to the functionality or production of the Company’s products (i) did not originate in any of the
Covered Countries; (ii) did come from recycled or scrap sources; and/or (iii) were “outside the supply chain” prior to
January 31, 2013. A very small number of suppliers for a limited number of products responded that they did not have sufficient
information to make the certification described above. However, based on the responses received, the Company has no reason to
believe that any conflict minerals that are necessary to the functionality or production of such products may have originated in any
of the Covered Countries.
The Company’s internal audit team is engaged
in a periodic review of compliance with our policy and procedures related to the conflict minerals rule across our businesses.
This Conflict Minerals Disclosure is publicly available on the Company’s Internet website at https://investor.rsac.com/corporate-governance/corporate-governance-documents.
The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference
into this Form SD nor deemed filed with the U.S. Securities and Exchange Commission.
Please refer to Rule 13p-1, Form SD and the 1934
Act Release No. 34-67716 for definitions of the terms used above, unless otherwise defined herein.
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 duly authorized undersigned.
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RELIANCE STEEL & ALUMINUM CO. |
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Dated: May 18, 2023 |
By: |
/s/ William A. Smith II |
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William A. Smith II |
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Senior Vice President, General Counsel and Corporate Secretary |
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