Specialized Disclosure Report (sd)
03 June 2014 - 5:17AM
Edgar (US Regulatory)
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
Sims Metal
Management Limited
(Exact name of registrant as specified in its charter)
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Victoria, Australia
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001-33983
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98-0490682
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(State or other jurisdiction
of incorporation or organization)
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(Commission
File Number)
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(IRS Employer
Identification No.)
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16 West 22
nd
Street, 10
th
Floor
New York, NY 10010
(Address of principal executive office) (Zip Code)
Frank M. Moratti, Company Secretary and General Counsel
(61 2) 8113 1600; Frank.Moratti@simsmm.com
Sir Joseph Banks Corporate Park, Suite 3, Level 2, 32-34 Lord Street
Botany, NSW 2019, Australia
(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:
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013.
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Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
Sims Metal Management
Limited (Sims or the Company) is one of the worlds largest metals and electronics recycling companies. Sims operates a geographically diverse metal recycling and electronics recycling business with a network of
processing facilities. For example, generally Sims purchases or otherwise receives end-of-life scrap metal and electronics materials, and sorts, handles or otherwise mechanically processes them to produce specification grade metal for sale to others
for use as raw material for steel mills, smelters, etc.
The Companys metal recycling operations source material from metal dealers, peddlers
(individuals that constitute our retail trade), auto wreckers, demolition firms and others who generate obsolete metal and from manufacturers who generate industrial metal. The Companys electronics recycling operations source material from
manufacturers of post-consumer electronic products, businesses and municipal organizations.
This Form SD disclosure is presented to comply with Rule
13p-1 under the Securities Exchange Act of 1934, as amended (Rule 13p-1). Pursuant to Rule 13p-1, to the extent that it engages in manufacture of products, the Company undertook to determine whether the products it manufactured or
contracted to manufacture during the year ended December 31, 2013 contained conflict minerals necessary to the functionality or production of such products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold,
wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (3TG).
The Company evaluated its products to
determine which of its products may contain 3TG. Based on this review, the Company determined that the post-industrial and post-consumer scrap that it processes and, along with certain recycled or scrap computer products that it refurbishes, that it
sells may contain 3TG. The Company conducted a reasonable country of origin inquiry based on a review of its business operations to determine whether any of the 3TG contained in its products came from recycled or scrap sources or if it did not,
whether the 3TG originated in the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (the Covered Countries). The Companys due
diligence process relied on its understanding that the Companys metals sources are limited to such recycled or scrap sources, except for a very limited group of products, for the refurbishment of which the Company may buy on very limited
occasions metal-containing components from retail outlets and/or the OEM manufacturing facilities which produced them. In light of the highly limited number of such purchases and the high improbability that such components could contain conflict
minerals entering the supply chain for the first time after January 31, 2013, the Company has reached the conclusion that it does not have 3TG from the Covered Countries in the products it sells for this reporting period. Going forward, the Company
anticipates revisiting the infrequent occasions in which it may purchase metal-containing components other than from recycled or scrap sources regarding the potential applicability of the conflict minerals rule relating to those potential purchases.
Based on this reasonable country of origin inquiry, the Company has in good faith concluded that any 3TG present in its products for the period covered by this report originated from recycled or scrap sources, except to the very limited extent noted
above.
In accordance with the requirements under Rule 13p-1, the above disclosure is also available on the Investors section of the
Companys website at www.simsmm.com.
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 undersigned, thereunto duly authorized.
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June 2, 2014
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SIMS METAL MANAGEMENT LIMITED
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/s/ Frank M. Moratti
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Frank M. Moratti
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Group Company Secretary and General Counsel
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