Conflict Minerals Disclosure
Quanex Building Products Corporation (“Quanex” or “the Company”) has manufactured or contracted to manufacture certain products for which “conflict minerals” (as defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act) are necessary to the functionality or production. Consequently, Quanex conducted, in good faith, a reasonable country of origin inquiry that was reasonably designed to determine whether any of those conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”), or whether any of those conflict minerals came from a scrap or recycled source.
Quanex conducted a multi-step reasonable country of origin inquiry. First, the Company required each of its suppliers to complete and sign a certification identifying whether the products, materials or components the supplier sells or supplies to Quanex contain conflict minerals. For those suppliers that indicated that their products, materials or components contain conflict minerals, the Company then required them to complete a supply chain questionnaire using the Conflict Minerals Reporting Template promulgated by the Electronic Industry Citizenship Coalition and Global e-Sustainability initiative. In that questionnaire, suppliers were prompted to disclose information such as the name of the smelter used to process their conflict minerals. The Company then thoroughly reviewed the questionnaire responses provided by suppliers to determine whether any conflict minerals may have originated in a Covered Country. The Company found that none of the suppliers’ responses indicated that the conflict minerals originated in a Covered Country. Additionally, none of the suppliers’ responses indicated that the conflict minerals were processed by a smelter in a Covered Country. Finally, none of the suppliers provided information indicating that the conflict minerals may have originated in a Covered Country. Based on this information, the Company has determined that it does not have reason to believe that any of its necessary conflict minerals may have originated in a Covered Country.