UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
POSCO
(Exact name of registrant as specified in its charter)
| The Republic of Korea | 1-13368 | Not Applicable | ||
(State or other jurisdiction of incorporation) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||
POSCO Center, 440 Teheran-ro, Gangnam-gu Seoul, Korea | 06194 | |||
| (Address of principal executive offices) | (Zip Code) | |||
Han, Tony
POSCO Center, 440 Teheran-ro, Gangnam-gu,
Seoul, Korea 06194
+82-2-3457-1268
(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 and 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 |
Rule13p-1 under the Securities Exchange Act of 1934, as amended, generally provides that a company must file this specialized disclosure report if it manufactures or contracts to manufacture products for which one or more of the following minerals are necessary to the functionality or production of the company’s products: cassiterite; columbite-tantalite (coltan); and wolframite; their derivatives tantalum, tin and tungsten; and gold (collectively, “3TGs”). These are considered “conflict minerals” under Rule13p-1 regardless of their geographic origin and whether or not they fund armed conflict in the Democratic Republic of the Congo or its neighboring countries (the “covered countries”).
POSCO is a fully integrated steel producer incorporated in Korea. POSCO manufactures and sells a diversified line of steel products, including cold rolled and hot rolled products, stainless steel products, plates, wire rods and silicon steel sheets in the global market. All references to “we,” “us” or “our” shall mean POSCO and, unless the context otherwise require, its consolidated subsidiaries.
We determined that certain of our products (collectively, the “covered products”) contain some 3TGs that are necessary to the functionality or production of those products. We do not directly purchase 3TGs, nor do we have any direct relationship with any mines or smelters that process these minerals.
As specified under Rule13p-1, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) that we believe was reasonably designed to determine whether any of the necessary 3TGs contained in our products manufactured in 2018 originated in the covered countries or were from recycled or scrap sources. In conducting the RCOI, we required our direct suppliers of materials for covered products to complete certifications concerning their manufacturing practices and the materials they supply to us. We also conducted a supply-chain survey with those suppliers using the Responsible Minerals Initiative’s Conflict Minerals Reporting Template. All of our suppliers of materials for covered products manufactured in 2018 certified that none of the 3TGs contained in materials supplied to us were sourced from any covered countries.
As a result, we have no reason to believe that any of the 3TGs contained in the 2018 covered products originated in the covered countries or did not come from recycled or scrap sources. The information in this Form SD is also publicly available on our website athttp://www.posco.co.kr/homepage/docs/eng6/jsp/invest/archive/s91b6010060l.jsp.
| Item 1.02: | Exhibits |
Not applicable.
Section 2 – Exhibits
| Item 2.01: | Exhibits |
Not applicable.
SIGNATURE
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.
POSCO (Registrant) | ||||||
| By: | /s/ Seung Kyu, Lim | Date: May 30, 2019 | ||||
| Name: | Seung Kyu, Lim | |||||
| Title: | Executive Vice President | |||||
