Governance
CMC is committed to working with partners who share our values and our goals of operating ethically and sustainably while maintaining the highest standards of quality and reliability. Our global supply chain and vendor base is made up of over 6,000 companies, including about 400 significant suppliers in the United States. We engage with key suppliers through formal surveys to gain a better understanding of our suppliers’ commitment to sustainability-related topics including diversity, human rights and environmental performance.
We follow outlined procedures for supplier selection and performance monitoring, under the direction of our chief supply chain officer and our purchasing and procurement teams, who receive regular training. In 2024, we implemented a supplier pre-qualification process for major capital projects in which we require the acceptance of our Supplier Code of Conduct in addition to other criteria for bid selection. New employees in North America, Europe, and the UK are required to enroll in our supply chain courses within six months of joining CMC and upon completion are certified as advanced procurement professionals or procurement professionals.
All suppliers are required to review and acknowledge compliance with our Supplier Code of Conduct, which outlines our expectations in areas including ethical business practices, health and safety, human rights and environmental stewardship.
We continually evaluate our supplier practices to set goals and benchmark performance.
Our vast global supplier base sometimes faces inherent risks of disruption, such as economic downturns or geopolitical crises. Several years ago, to help mitigate these risks, we began moving the supply chain closer to our local operations when possible.
With a focus on buying locally, we improve the resilience of our supply chain, reduce risks and minimize our environmental impact from factors such as transport-related GHG emissions.
Throughout these efforts, we’ve continued to increase our sustainability focus. This allows us to work with our suppliers to help improve human rights, worker conditions, ethical behavior and environmental compliance and performance.
At the same time, we acknowledge that supply chain risks persist from COVID-19, while the Ukraine war has added to supply chain insecurity in Europe . To that end, we performed a supplier risk assessment in 2023 to better understand the environmental, geopolitical and regulatory impacts across our operations.
Conflict Minerals
We do not purchase, use or process Conflict Minerals, which under U.S. law are tin, tantalum, tungsten and gold originating from the Democratic Republic of the Congo or an adjoining country (Covered Countries). As stated in our Conflict Minerals Policy, which is included in our Supplier Code of Conduct, we require suppliers to assist in compliance with laws and regulations governing Conflict Minerals by conducting reasonable country of origin inquiries and following internationally accepted due diligence guidelines. CMC complies with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, which requires the company to file an annual Conflict Minerals Report with the SEC. Our latest Conflict Minerals Report covering 2023, filed with the SEC on May 24, 2024, states that based on our due diligence, CMC has 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.
Local Suppliers
We seek to work with local suppliers in the regions where we operate when possible, and in 2024 approximately 67% of our U.S. suppliers were local. In the United States, we utilize a purchasing platform, which makes it easier for local and regional suppliers to do business with CMC. The platform enables our procurement teams to receive and acknowledge purchase orders and invoices within the same platform, which minimizes back-office functions for smaller suppliers.
The charter includes eight commitments that signatories and their supply chains need to address to show they are treating people responsibly, including human rights, wellbeing, equality, workplace culture and training.