United States
Securities and Exchange Commission
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
GLOBAL BRASS AND COPPER HOLDINGS, INC.
(Exact name of registrant as specified in its charter)
| Delaware | 001-35938 | 06-1826563 | ||
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) |
475 N. Martingale Road Suite 1200 Schaumburg, IL | 60173 | |
| (Address of principal executive offices) | (Zip Code) |
Anne-Marie W. D’Angelo
General Counsel
(847)240-4700
(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:
| ☒ | Rule13p-1 under the Securities Exchange Act (17 CFR240.13p-1) for the reporting period from January 1 to December 31, 2018. |
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Global Brass and Copper Holdings, Inc. (the “Company”) is filed pursuant to Rule13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2018 to December 31, 2018. Rule13p-1 (the “Rule”) 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 (collectively, the “Conflict Minerals”).
The Company’s primary line of business is the production of copper and copper-based alloys and fabricated products made from copper and copper-based alloys. Some of the products fabricated or produced by the Company either (i) contain small amounts of tin as a component of the alloy or (ii) are plated with tin or gold for functional reasons. For certain of the Company’s products, tin is an alloy agent necessary to produce those products and achieve the particular properties required of those alloys. Both tin and gold are considered Conflict Minerals under the Rule.
The vast majority of tin used in the Company’s manufacturing operations is sourced through scrap. However, a small amount of tin used to manufacture alloys, and the tin and gold used in plating operations, are indirectly sourced from smelters by purchases through brokers or dealers.
As required by the Rule, the Company has conducted a good faith, reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals used in its products to determine whether any such Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country and/or whether any of the Conflict Minerals were from recycled or scrap sources. Where applicable, the Company has conducted additional due diligence regarding the sources of the Conflict Minerals.
The Company’s Conflict Minerals Report for the Reporting Period is filed as Exhibit 1.01 hereto and can be found on its website atwww.gbcholdings.com.
Item 1.02 Exhibit
The Company’s Conflict Minerals report for the year ended December 31, 2018 is filed as Exhibit 1.01 to this Form SD.
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report dated May 31, 2019 as required by Items 1.01 and 1.02 of this Form.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
| GLOBAL BRASS AND COPPER HOLDINGS, INC | ||
| By: | /s/ John J. Wasz | |
| John J. Wasz | ||
| Chief Executive Officer | ||
Date: May 31, 2019
