Section 1 - Conflict Minerals Disclosure
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Item 1.01
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Conflict Minerals Disclosure and Report
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Conflict Minerals Disclosure
NewMarket Corporation,
including its subsidiaries (the “Company”), is filing this Form SD for the reporting period of January 1, 2018 to December 31, 2018 (the “Reporting Period”) pursuant to and in accordance with Rule
13p-1
under the Securities Exchange Act of 1934, as amended (“Rule
13p-1”).
Rule
13p-1
requires disclosure of certain
information related to a product manufactured or contracted to be manufactured by an issuer where “conflict minerals” are necessary to the functionality or production of those products. As defined in the Rule, “conflict minerals”
means gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten.
Based
on a review of the Company’s products manufactured or contracted to be manufactured during the Reporting Period, including a review of the raw materials used to produce those products, the Company determined that one vendor supplied a
tin-based
compound necessary to the functionality or production of the final product (“necessary conflict mineral”). The product in question was a metalworking fluid additive (the “Specified
Product”). The results of the Company’s review are consistent with its belief, based on the nature of its business, that its products generally did not contain conflict minerals.
Because the Specified Product contained a necessary conflict mineral, the Company conducted a good faith reasonable country of origin inquiry, which was
designed to determine whether any necessary conflict minerals originated in the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia or Angola (the
“Covered Countries”). A brief description of the reasonable country of origin inquiry is as follows:
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The Company’s team overseeing its conflict minerals diligence efforts is a global interdisciplinary team
comprised of personnel representing the Company’s procurement, research and development, legal and manufacturing functions. The team oversaw a diligence process designed to determine if any conflict minerals are necessary to the functionality
or production of its products manufactured during the Reporting Period.
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The Company maintains a comprehensive database of raw materials used to manufacture its products. The
Company’s procurement director reviewed this database to determine if there were any necessary conflict minerals in the Company’s products. The procurement director also surveyed the Company’s global research and development directors
to identify any products they believe may include necessary conflict minerals.
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This diligence process identified the Specified Product as the only product manufactured during the Reporting
Period that included a necessary conflict mineral and determined the necessary conflict mineral was provided by a single vendor (the “Supplier”).
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In November 2018, the Supplier certified to the Company that the necessary conflict mineral supplied to it during
the Reporting Period did not originate in the Covered Countries.
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The Company periodically asks its Supplier for additional documentation in support of such certification, and in
December 2018, the Supplier provided the Company with a copy of its completed Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting template, including smelter information.
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Based on the Company’s reasonable country of origin inquiry described above, the Company determined that it has no reason to believe that any necessary
conflict mineral within any products manufactured or contracted to be manufactured in the Reporting Period may have originated in the Covered Countries.
This information is also publicly available on the Company’s website at: www.newmarket.com. Information on the Company’s website does not constitute
a part of this Form SD.