United States
Securities and Exchange Commission
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
HOWMET AEROSPACE INC.
(Exact name of registrant as specified in its charter)
| Delaware | 1-3610 |
(State or other jurisdiction of incorporation) | (Commission file number) |
201 Isabella Street, Suite 200 Pittsburgh, Pennsylvania | 15212-5872 |
| (Address of principal executive offices) | (Zip code) |
Office of Investor Relations (412) 553-1950
Office of the Secretary (412) 553-1940
(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:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
| ¨ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended . |
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Overview
Unless the context indicates otherwise, the terms “Howmet,” “Company,” “we,” “its,” “us” and “our” refer to Howmet Aerospace Inc. and all current subsidiaries consolidated for the purposes of its financial statements that were in-scope for the 2023 compliance period. The “Conflict Minerals Rule” means, collectively, Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” 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.
See the Conflict Minerals Report filed as an exhibit to this report (the “Conflict Minerals Report”) for information regarding the applicability of the Conflict Minerals Rule to the Company generally.
Reasonable Country of Origin Inquiry Information
We conducted a “reasonable country of origin inquiry” (“RCOI”) within the meaning of the Conflict Minerals Rule to determine the origin of the necessary 3TG contained in our in-scope products. To the extent applicable, we utilized the same processes and procedures for our RCOI that we used for our due diligence described in the Conflict Minerals Report. We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (collectively, the “OECD Guidance”). For a discussion of our OECD Guidance framework and the due diligence measures that we performed in respect of 2023, see the Conflict Minerals Report filed as an exhibit to this Form SD.
Based on our RCOI, we determined that the necessary tin contained in certain of our in-scope products originated from smelters that we believe, based on publicly available information, sourced all of their ore from outside of the Democratic Republic of the Congo (the “DRC”) and its adjoining countries or from recycled or scrap sources. These products were selected titanium alloys, titanium mill products and titanium fabricated parts. None of these products contained 3TG from any other sources.
The foregoing information is available at the following Internet website: http://www.howmet.com. The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or our Conflict Minerals Report.
Conflict Minerals Report
As provided for in the Conflict Minerals Rule, a Conflict Minerals Report is provided as an exhibit to this Form SD and is available at the following Internet website: http://www.howmet.com.
Item 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 - Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 - Exhibits
Item 3.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report for the calendar year ended December 31, 2023
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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.
| Howmet Aerospace Inc. | |||
| (Registrant) | |||
| By: | /s/ Lola F. Lin | Date: May 29, 2024 | |
| Name: | Lola F. Lin | ||
| Title: | Executive Vice President, Chief Legal and Compliance Officer and Secretary | ||
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EXHIBIT INDEX
| Exhibit | Description | |
| 1.01 | Conflict Minerals Report for the calendar year ended December 31, 2023 |
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