CMC 2025 Sustainability Report

Governance

Strengthening Our Supply Chain

  1. Governance
  2. Strengthening Our Supply Chain

Responsible Supply Chain

  • 2-6 Activities, value chain and other business relationships

CMC strives to work with partners and suppliers who share our values and support our goals of operating with the highest standards of ethics, quality and sustainability. Our commitment to managing a responsible global supply chain includes taking a proactive approach to risk assessment and due diligence for our vendor base of over 6,100 companies, including about 450 significant suppliers in the U.S.

We conduct formal surveys with key suppliers to gain a better understanding of our suppliers’ commitment to sustainability-related topics including diversity, human rights and environmental performance. In 2025, the supplier survey was enhanced to better align with CMC’s sustainability priorities such as health and safety, labor relations, and sustainability transparency and reporting. The number of suppliers who received the survey also increased by 24%, reflecting our commitment to supply chain awareness and due diligence.

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. For suppliers on major capital projects, we utilize a platform compliant with ISO 27001:2013, which ensures secure and efficient information exchange and full audit trail capabilities.

Our procedures for supplier selection and performance monitoring, which are directed by our chief procurement officer and our purchasing and procurement teams, include the use of third party supplier risk monitoring software. This software platform was expanded in 2025 to include over 1,300 due diligence reports. The platform includes the ability to send questionnaires regarding sustainability topics including health and safety, environmental and social risks. To further enhance oversight, CMC is rolling out a supplier desk audit process that we will discuss more in the future.

New employees joining our purchasing and procurement teams in North America, Europe and the UK are required to enroll in our supply chain courses within six months of employment to obtain certification as advanced procurement professionals. CMC provides access to training for our purchasing and procurement teams through the Institute for Supply Management. Further employee engagement is conducted through monthly newsletters on important supply chain topics.

In 2025, CMC began an independent assessment of the maturity of its procurement program. The results of this assessment will be used to update relevant policies and procedures in the coming years.

We continually evaluate our supplier practices to set goals and benchmark performance.

Improving Resilience

  • 2-23 Policy commitments
  • 2-24 Embedding policy commitments
  • 2-25 Processes to remediate negative impacts
  • 2-30 Collective bargaining agreements

Our purchasing and procurement teams regularly analyze and assess potential risks that may cause disruption to our supply chain, including economic downturns or geopolitical crises. To help mitigate these risks, we implement initiatives such as selecting suppliers closer to our local operations when possible. The selection of local suppliers also reduces the environmental impact of factors such as transport-related GHG emissions.

We assess the supply chain risks of our commodity suppliers, including risks they may face from current or upcoming regulatory changes, through a formalized program including onsite visits and virtual data gathering. The results of these assessments are used to strengthen resilience by developing 5- and 10-year strategies for procurement of certain commodities such as electrodes and alloys.

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Conflict Minerals

CMC does 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). Our Conflict Minerals Policy, which is included in our Supplier Code of Conduct, requires suppliers to assist in compliance with laws and regulations governing Conflict Minerals by conducting a reasonable country of origin inquiry (RCOI) 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, filed with the SEC on May 23, 2025, states that based on the results of the RCOI conducted in 2024, 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

CMC aims to work with suppliers local to the regions where we operate. In the U.S., where we utilize a purchasing platform that makes it easier for local and regional suppliers to do business with CMC, approximately 84% of our suppliers were local in 2025, defined as suppliers also located in the U.S. The platform minimizes back-office functions for smaller suppliers by enabling our procurement teams to receive and acknowledge purchase orders and invoices within the same platform.

People Matter Charter

Our Tensar Division is a signatory of the People Matter Charter, which is a UK-based charter developed by the Supply Chain Sustainability School.

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.