Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Overview
Alcoa Corporation (Alcoa or the
Company) is a global industry leader in bauxite, alumina, and aluminum products.
Unless the context indicates otherwise, the terms
Alcoa, Company, we, us, and our refer to Alcoa Corporation and all 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
(the Exchange Act), and the Specialized Disclosure Report on Form SD pursuant to Rule 13p-1 promulgated under the Exchange Act. As used herein and consistent with the Conflict Minerals Rule,
Conflict Minerals 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.
Conflict Minerals Disclosure
This Form SD is publicly
available on our website, www.alcoa.com, under the Investors section. The information contained on our website is not incorporated by reference into this Form SD and should not be considered part of this Form SD.
Alcoas processes and procedures described below were designed to determine whether the Conflict Minerals intentionally added and necessary to the
functionality or production of products we manufactured during 2023 originated in the Democratic Republic of the Congo or adjoining countries, as defined under the Conflicts Minerals Rule (collectively, the Covered Countries), or
otherwise originated from scrap or recycled materials.
Procedures and Reasonable Country of Origin Inquiry
Each Alcoa business segment conducted an assessment to determine whether its manufactured products contained any Conflict Minerals that were necessary to the
functionality or production of such products (any such manufactured products containing Conflict Minerals are referred to herein as Covered Products). This assessment involved an internal review of all materials that become part of
Covered Products and may include a review of product specifications, bills of material, supplier inquiries, product composition analyses, and other information about such Covered Products known to us. This assessment is also conducted by each
business segment as new products that could come within the scope of the Conflict Minerals Rule are developed. In addition, each business segment identified, for all Covered Products it manufactures, any purchased materials that include Conflict
Minerals used in the manufacture of such Covered Products, as well as the suppliers of such purchased materials, through a review of purchase records for such Covered Products.
Following this assessment, Alcoa conducted a good faith reasonable country of origin inquiry (the RCOI) within the meaning of the Conflict
Minerals Rule to determine the origin of the Conflict Minerals contained in its Covered Products for the 2023 reporting period. Alcoa requested that each in-scope supplier complete the Conflict Minerals
Reporting Template (CMRT) developed by the Responsible Minerals Initiative (RMI), with a response at the Covered Product level to the extent possible, in order to identify the origin of the Conflict Minerals in such products.
Specific Conflict Mineral smelters identified by our suppliers in the completed CMRTs were reviewed against the Responsible Minerals Assurance Process (RMAP) conformant smelter list and other publicly-available information to confirm
that all such smelters were conformant with the RMAP assessment procedure managed by RMI. RMAP conformant smelters have undergone an independent, third-party audit of their management systems and sourcing practices to validate compliance with
protocols and current global standards to support responsible sourcing of raw materials.
Having followed the described procedures, we believe that we
identified all Covered Products containing Conflict Minerals for the 2023 reporting period and that one supplier is likely to have supplied Conflict Minerals to us in connection with our Covered Products. The only Conflict Mineral included in our
Covered Products during 2023 was tin.
In addition to reviewing completed CMRTs, Alcoas procedures include reviewing supporting documentation,
available conflict minerals policies, and other statements from suppliers, including for accuracy, completeness, and overall reasonableness to evaluate and determine whether Alcoa may reasonably rely on such information. Further supplier engagement
is performed as necessary to obtain additional or complete information or clarification.