Section 1 Conflict Minerals Disclosure
Item 1.01. Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This report is being
filed by Commercial Metals Company (together with its consolidated subsidiaries, CMC) for the calendar year ended December 31, 2020, 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.
CMC manufactures, recycles and markets steel and metal products, related materials and services through a network of facilities that includes seven electric
arc furnace (EAF) mini mills, a rerolling mill, steel fabrication and processing plants, construction-related product warehouses, and metal recycling facilities in the United States and Poland. CMCs core business is
the manufacture and sale of steel products. CMC operates steel mills in the United States and Poland.
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, 2020, 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, 2020. 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.
Reasonable Country of Origin Inquiry Conclusion
CMC has evaluated the results of the RCOI in good faith and in full consideration of the SECs guidance, and finds no reason to believe that any conflict
minerals 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.