HomeMy WebLinkAboutConflict Minerals - Elgiloy Specialty MetalsTHE COMBINED METALS COMPANY LLC
Doc. Code: CMC/ESM-C-EHS-P-0203 Doc Ref: SAFETY/EHS Rev. 1 Date: 05/2024
Conflict Minerals | Extended Minerals Disclosure
Introduction
Combined Metals Company, LLC (CMC) and its family of operating companies: Elgiloy Specialty Metals
(ESM), Gibbs Interwire (GIW), and Combined Service Centers (CSC) supplies a combination of precision
cold-rolling up to a meter wide, wire drawing, and a network of service centers supplying stainless steel,
specialty metals, and carbon steel in slit coil, wire, sheet, blanks, and polishing to a variety of industries.
The CMC companies provide a diverse selection of high-performance alloys for strip, slit coil, sheet,
blanks, and wire, including hundreds of grades of stainless steels, nickel alloys, cobalt alloys, titanium
alloys, and carbon steel. The metal compositions supplied are well-known materials as specified by
ASTM International, the American Iron and Steel Institute (AISI) and the United States Military (MIL-
specs). Products are accompanied by a mill test certificate which gives element concentrations within
the product and the results of any required physical or metallurgical tests as specified on the material
specification. Providing such information has become standardized throughout the metals industry and
until recently has been sufficient to satisfy our clients' needs.
Conflict Minerals Disclosure
The CMC family of companies shares the concerns of Congress and the international business
community regarding the use of profits derived from the mining of certain minerals in the Democratic
Republic of Congo (“DRC”) and adjoining countries. In July 2010, the United States Congress passed
legislation as part of “Dodd-Frank” mandating supply chain due diligence and public disclosure related to
the sourcing of these Conflict Minerals (Tin, Tantalum, Tungsten, Gold). In the SEC rule, “DRC conflict-
free” is defined as minerals that were extracted and did not directly or indirectly benefit armed groups
in the covered countries. CMC is committed to legal and ethical compliance in all its business practices
and will comply with this legislation, along with all related implementing regulations issued by the SEC or
other agencies. CMC is not the mill, smelter, or refiner of the material and, therefore, is a downstream
supplier. We utilize the Conflict Minerals Reporting Template (CMRT) from Responsible Material
Initiative (RMI) to facilitate the transfer of information through the supply chain regarding mineral
country of origin and the smelters and refiners being utilized. We request that our material suppliers
complete and return the RMI CMRT, including updates with each revision to the regulation. Then we
update our CMRT to current revision, which is available upon request.
Extended Minerals Disclosure
The Extended Minerals Disclosure is currently voluntary and there are no regulatory compliance
requirements in place for cobalt and mica. CMC will continue to provide due diligence with our
suppliers to verify a conflict-free supply chain.
Jeff Simons
President
Combined Metals Company LLC