Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
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 2021 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 2021 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
Each
Alcoa business segment 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 segment as new products that could come within the scope of the Conflict Minerals Rule are
developed. In addition, each business segment 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.
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 2021 reporting period. Alcoa requested that each in-scope supplier
complete the Conflict Minerals Reporting Template (CMRT) developed by the Responsible Minerals Initiative (RMI), 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 Mineral smelters identified by our suppliers in the completed CMRTs were reviewed against the Responsible Minerals Assurance Process (RMAP) conformant smelter list and other
publicly-available information to confirm that all such smelters were conformant with the RMAP assessment procedure managed by RMI. 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.
Having followed the
described procedures, we believe that we identified all Covered Products containing Conflict Minerals for the 2021 reporting period and that two suppliers are likely to have supplied Conflict Minerals to us in connection with our Covered Products.
The only Conflict Mineral included in our Covered Products during 2021 was tin.
In addition to reviewing completed CMRTs, Alcoas procedures include
reviewing supporting documentation, available conflict minerals policies, and other statements from suppliers, including for accuracy, completeness, and overall reasonableness to evaluate and determine whether Alcoa may reasonably rely on such
information. Further supplier engagement is performed as necessary to obtain additional or complete information or clarification. Alcoa believes it has received adequate 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.