UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form SD

SPECIALIZED DISCLOSURE REPORT

A. O. Smith Corporation

(Exact name of registrant as specified in its charter)

Delaware

1-475

39-0619790

(State or other jurisdiction

(Commission

(I.R.S. Employer

of incorporation)

File No.)

Identification Number)

11270 West Park Place, Milwaukee, Wisconsin

53224-9508

(Address of principal executive offices)

(Zip Code)

John J. Kita

Executive Vice President and Chief Financial Officer

(414) 359-4000

(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:

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.

Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibits

Conflict Minerals Disclosure

A. O. Smith Corporation is providing a Conflict Minerals Report as Exhibit 1.01 hereto, and it is publicly available under "Additional Resources" at http://www.aosmith.com/About/Governance/.

Section 2 - Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

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 duly authorized undersigned.

A. O. SMITH CORPORATION

By /s/ John J. Kita

April 23, 2019

John J. Kita

(Date)

Executive Vice President and Chief

Financial Officer

Exhibit 1.01

A. O. Smith Corporation

Conflict Minerals Report

for the Year Ended December 31, 2018

This Report has been prepared by A. O. Smith Corporation ("A. O. Smith," "we," "us" or "our") to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"), which was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to certain minerals. The Rule imposes reporting obligations on SEC registrants (a "Covered Company" or "Covered Companies") who manufacture products containing certain minerals, including tin, tantalum, tungsten, and gold ("3TG" or "conflict minerals"). These reporting requirements apply to Covered Companies regardless of the geographic origin of the 3TG and regardless of whether or not sales of 3TG fund armed groups in the Democratic Republic of the Congo or an adjoining country (the "DRC" or "Covered Countries").

This Rule requires a Covered Company to conduct a "Reasonable Country of Origin Inquiry" that is designed to determine whether any of the 3TG in its products either originated in Covered Countries or were from recycled or scrap sources and, under certain circumstances, whether due diligence is required on the source and chain of custody of the 3TG. Pursuant to the Rule, if, based upon a reasonable country of origin inquiry, a Covered Company has reason to believe that any of the 3TG in its supply chain may have originated in one of the Covered Countries, or if a Covered Company is unable to determine the country of origin of 3TG, then it must file a Conflict Minerals Report with the SEC describing the due diligence measures it has undertaken or will undertake regarding the source and chain of custody of the 3TG. Due to our limited ability to determine the origin and chain of custody of 3TG necessary to the functionality or production of our products as described herein, we are filing this Conflict Minerals Report.

1.COMPANY OVERVIEW

A. O. Smith is a manufacturer of residential and commercial water heaters and boilers, as well as water treatment products for residential and light commercial applications, with manufacturing operations in the U.S., Canada, China, India, Mexico, the Netherlands and Turkey.

Our compliance process covered the supply chain for all of our operations. Specifically, we conducted an analysis of each of our products to identify those containing 3TG. This included reviewing our products' bill of materials and consulting with procurement and engineering personnel. We believe there are, at a minimum, miniscule amounts of 3TG in virtually all of our products, which is necessary for product functionality.

Our Conflict Minerals Policy

We have adopted a statement on conflict minerals, which is publicly available on our website at http://www.aosmith.com. Click on "Investors," then "Governance" and "Conflict Minerals Statement" in the column on the lower portion of the webpage.

Our Supply Chain

The products we manufacture are complex, typically containing hundreds of parts from suppliers worldwide. We reviewed our supplier list for all manufacturing locations and eliminated service providers, equipment vendors, other non-manufacturing suppliers, as well as vendors with whom we spent less than $5,000 in 2018 and redundant listings for our multiple plants. Based on that criteria, we identified approximately 1200 direct suppliers of materials and components worldwide in 2018. There are multiple tiers between our suppliers and the 3TG smelter for a particular component, which makes it difficult for us to ascertain the ultimate source of 3TG in the products we manufacture. We must rely on our direct suppliers to work with their upstream suppliers to provide accurate information on the origin of the 3TG contained in the components and materials we purchase.

We surveyed all direct suppliers identified through this process. For consistency, we sent the same letter, translated as appropriate, to all identified suppliers globally, requesting that they provide us information regarding 3TG and smelters using the current template developed by the Electronic Industry Citizenship Coalition ("EICC") and the Global e-Sustainability Initiative ("GeSI"), known as the Conflict Minerals Reporting Template (the "CMRT"). The EICC and GeSI are widely regarded as industry leaders in conflict minerals reporting. They jointly developed the CMRT to facilitate disclosure and communication of sourcing information regarding smelters and refiners that provide material to a manufacturer's supply chain by providing a consistent framework for survey responses. The CMRT was updated in 2018 to provide more detailed information, and includes questions regarding a direct supplier's conflict-free policy, its due diligence process, information about its supply chain such as the names and locations of smelters and refiners, as well as the origin of 3TG used by those facilities. The CMRT also has foreign language capability for many of our worldwide locations.

Efforts to Determine Mine or Location of Origin

We have determined that requesting our suppliers to complete the CMRT and making follow-up inquiries represents our reasonable best opportunity to determine the countries and, in some cases, mines or locations of origin of 3TG in our supply chain. We reached this conclusion, in part, because of the EICC-GeSIConflict-Free Smelter Program which operates in conjunction with the CMRT. This program is one of the industry leaders in the efforts to certify conflict-free smelters and provides a list of such smelters for manufacturers' use. To ensure that we have access to the most up to date smelter information for the last several years, A. O. Smith has been a longstanding member of the Responsible Minerals Initiative ("RMI"), formerly known as the Conflict Free Smelter Initiative, which was created to develop tools and processes to improve conflict minerals due diligence. As outlined in the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance"), which is the

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A.O. Smith Corporation published this content on 24 April 2019 and is solely responsible for the information contained herein. Distributed by Public, unedited and unaltered, on 24 April 2019 16:22:09 UTC