Form SD STEELCASE INC

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

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FORM SD

Specialized Disclosure Report

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STEELCASE INC.

(Exact name of registrant as specified in its charter)

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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:

[ X ] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

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Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Form SD of Steelcase Inc. is filed in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1, 2021 to December 31, 2021. As used in this Form SD, unless otherwise expressly stated or the context otherwise requires, all references to “Steelcase,” “we,” “our,” “Company” and similar references are to Steelcase Inc. and its consolidated subsidiaries.

Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in Rule 13p-1 are necessary to the production or functionality of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“Conflict Minerals”). The “Covered Countries” for the purposes of Rule 13p-1 are the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

Certain of our operations manufacture or contract to manufacture products for which Conflict Minerals are necessary to the production or functionality of those products. We conducted a reasonable country of origin inquiry regarding such Conflict Minerals, which was designed to determine whether any of the Conflict Minerals originated in the Covered Countries or were from recycled or scrap sources. For those Conflict Minerals which we believe may have originated in the Covered Countries and which we were unable to conclude were from scrap or recycled sources, we exercised due diligence on the source and chain of custody of those Conflict Minerals. Our reasonable country of origin inquiry and due diligence processes are described in our Conflict Minerals Report, which is filed as Exhibit 1.01 to this Form SD, and is publicly available at ir.steelcase.com/financial-information/sec-filings/default.aspx..

Item 1.02 Exhibit

As specified in Section 2, Item 2.01, Steelcase Inc. is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

Section 2 – Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report.

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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.

Date: May 20, 2022

        Exhibit 1.01

STEELCASE INC.

Conflict Minerals Report

For the reporting period from January 1, 2021 to December 31, 2021

Introduction

This Conflict Minerals Report (“Report”) of Steelcase Inc. has been prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period January 1, 2021 to December 31, 2021. As used in this Report and unless otherwise expressly stated or the context otherwise requires, all references to “Steelcase,” “we,” “our,” “Company” and similar references are references to Steelcase Inc. and its consolidated subsidiaries.

Rule 13p-1 was adopted by the Securities and Exchange Commission (“SEC”) to implement certain disclosure requirements related to minerals specified in the rule. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“Conflict Minerals”). Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which Conflict Minerals are necessary to the production or functionality of those products (such minerals are referred to herein as “Necessary Conflict Minerals”).

Company Overview

We offer a comprehensive portfolio of furniture, architectural products and technology solutions that support people at work.

Conflict Minerals Policy and Supplier Code of Conduct

Our Conflict Minerals Policy states our intent to refrain from purchasing products, components or materials containing any Necessary Conflict Minerals from the Covered Countries that directly or indirectly finance or benefit armed groups and are not otherwise from recycled or scrap sources. The policy also expresses our expectation that our suppliers follow this same practice, establish appropriate due diligence programs and provide us with information, upon our request, regarding the source and chain of custody of any Necessary Conflict Minerals in the products, components or materials they sell to us. In addition, our Supplier Code of Conduct includes a Fair Operating Practices section regarding “Responsible Sourcing of Minerals” which is consistent with our Conflict Minerals Policy. Our policy and our Supplier Code of Conduct are publicly available on our website at www.steelcase.com/about/steelcase/suppliers/.

Reasonable Country of Origin Inquiry

Pursuant to Rule 13p-1, we conducted a Reasonable Country of Origin Inquiry (“RCOI”). Our RCOI began with an evaluation of our global suppliers who provided materials, components or products that became part of products we manufactured or contracted to be manufactured in 2021 which contained or were likely to contain Necessary Conflict Minerals. This evaluation consisted of examining internal records such as bills of materials or other product specifications and performing a qualitative review of purchasing records and/or information provided by the supplier.

Based on our evaluation, we surveyed a total of 177 suppliers that provided materials, components or products which we concluded contained or were likely to contain Necessary Conflict Minerals. The suppliers were asked to report on the presence of any Necessary Conflict Minerals in the goods sold to us. We achieved a greater than 87% response rate from the surveyed suppliers (measured by spend

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during the reporting period) with Conflict Minerals Reporting Templates (“CMRTs”) completed at either the company or product level.

Due Diligence

Design of Due Diligence

We designed our due diligence measures to conform to the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on tin, tantalum, tungsten, and gold (collectively, the “OECD Guidance”).

Due Diligence Measures Performed

Pursuant to Rule 13p-1, we undertook due diligence measures on the source and chain of custody of the Necessary Conflict Minerals in our products which we had reason to believe may have originated from the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”) and which may not have come from recycled or scrap sources. Following is a summary of the due diligence actions we performed with regard to the reporting period:

1.    Establish strong company management systems

•As referenced previously, we have a Conflict Minerals Policy which is shared with our supply chain and publicly available on our website.

•We have an established project team from our Sustainability department which leads the RCOI, due diligence and reporting processes. Our Conflict Minerals Governance Committee provides oversight for the project team and is comprised of senior management from our legal, compliance and internal audit functions.

•We are a “downstream company” in our supply chain, meaning we are generally several tiers removed from the smelters and refiners which process the Necessary Conflict Minerals present in some of our products. Accordingly, we rely on communication with and through our immediate suppliers to provide us with information relating to the presence and sourcing of the Necessary Conflict Minerals present in our products.

•We intend to maintain our records relating to Conflict Minerals reporting for a minimum of five years after each applicable reporting period, in accordance with the OECD Guidance and our own Records Retention Policy.

•Our Supplier Code of Conduct includes language that reinforces our Conflict Minerals Policy, and we have included Conflict Minerals reporting requirements in our purchasing contract templates.

•We have implemented Conflict Minerals checkpoints into both our supplier qualification and product development processes to begin engaging new suppliers and suppliers of new materials early in the process.

•We have continued to educate our suppliers and employees about Conflict Minerals and the related reporting requirements in each of the regions in which we operate: the Americas, Europe, Middle East and Africa, and Asia Pacific.

•We have continued to provide a grievance mechanism channel through our international integrity helpline to both employees and non-employees for reporting ethics and compliance issues, including those related to Conflict Minerals. Information about contacting the helpline can be found at integrity.steelcase.com.

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2.    Identify and assess risks in the supply chain

•We surveyed suppliers we either knew or had reason to believe may have provided materials, components or products which may contain Necessary Conflict Minerals, using the due diligence tool created by the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GESI”)’s Responsible Minerals Initiative (“RMI”)’s CMRT, which is a survey designed to identify the smelters and refiners that process, and the country of origin of, Conflict Minerals contained in the products supplied by the applicable supplier.

•We selected a subset of suppliers among all surveyed suppliers to be targeted for prioritized follow up. We referred to this subset as “prioritized suppliers.” Prioritized suppliers were selected for additional follow up to capture the greatest risk in our supply chain. The criteria used to select prioritized suppliers included: material composition, previously submitted smelter and refiner information, geographic region, spend, type of supplier and quantity of parts purchased.

•We followed up with prioritized suppliers that did not respond to our survey request or that we identified as providing incomplete or potentially inaccurate information to seek additional clarification or remediation and to bring them into conformity with our Conflict Minerals Policy and contractual agreements.

•We cross-referenced smelters and refiners identified in the CMRTs submitted by our suppliers against the list of facilities that have received a “conformant” designation from the Responsible Minerals Assurance Process (“RMAP”) and its cross-recognized programs (e.g. the Responsible Jewellery Council and the London Bullion Market Association, otherwise known as “RJC” and “LBMA,” respectfully), whose designations provide country of origin and additional due diligence information on the Conflict Minerals sourced by such facilities.

•We continued to encourage the participation of smelters and refiners in the RMAP, through our continued membership and active participation in the RMI and related working groups, and by conducting outreach to those smelters and refiners identified by our supply chain which are not yet participating in the RMAP or require additional assistance with the process.

3.    Design and implement a strategy to respond to identified risks

•The status and findings of our RCOI and due diligence efforts were reported to our Conflict Minerals Governance Committee during regular updates between the months of October 2021 and May 2022.

•We intend to follow a risk mitigation plan that is consistent with our Conflict Minerals Policy. If a smelter or refiner in our supply chain were known to be sourcing from a mine within a Covered Country which directly or indirectly finances or benefits armed groups, we would consider all available options, including, but not limited to, making changes to our sourcing of those items.

4.     Independent third-party audit of smelter or refiner’s due diligence practices

•As a downstream company and an active member of the RMI, we support the independent third-party audits of smelters and refiners performed by the RMAP and other cross-recognized programs (e.g. RJC and LBMA) to audit the conformant status of smelters and refiners.

5.     Report annually on supply chain due diligence

•We plan to report annually to the SEC by filing a Form SD and Conflict Minerals Report as required by applicable law.

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Results of Due Diligence Measures Performed

Inherent Limitations of Due Diligence Measures

As a downstream company in a complex supply chain, our due diligence measures can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Necessary Conflict Minerals contained in our products. Our due diligence processes rely on obtaining data from our tier one suppliers and those suppliers seeking similar information from their supply chains to identify the original sources of the Necessary Conflict Minerals. We also rely on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information.

Product Description

For the reporting period, we identified the following types of products which we either manufactured or contracted with others to manufacture that contained Necessary Conflict Minerals which may have originated in the Covered Countries but for which we could not confirm the countries of origin of all the Necessary Conflict Minerals

Some of our desking products, wall systems, doors, tiles, panels, lighting, and other office furniture products which contain one or more of the following: electronic and electrical components, including lighting, and glass panels.

Determination

Based on the information provided by our suppliers, the facilities that may have been used to process the Necessary Conflict Minerals used in our products may include the smelters and refiners listed in Annex I.

Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of all the Necessary Conflict Minerals in the products described above in the “Product Description” section of this report or whether the Necessary Conflict Minerals were from recycled or scrap sources. However, based on the information provided by our suppliers and available from the RMI, the countries of origin of the Necessary Conflict Minerals contained in the products described above may include, but may not be limited to, the countries listed in Annex II, in addition to recycled or scrap sources.

Smelter and Refiner Summary

In response to our survey, our suppliers identified 318 smelter and refiner facilities which may have processed the Necessary Conflict Minerals contained in the materials provided to us. Of those facilities, as of May 20, 2022:

•228 have received a “conformant” designation from the RMAP;

•27 have not yet received a “conformant” designation but are considered “active” in the RMAP or are “in communication” with the RMAP or other cross-recognized programs; and

•the remaining facilities are not currently actively participating in the RMAP.

Under the RMAP’s standards, “conformant” means a facility has been audited and found to be conformant with the relevant RMAP protocol or cross-recognized program, and “active” means a facility that is engaged in the RMAP program but has not yet been found to be “conformant.” Facilities characterized as “in communication” are not yet “active” but are in communication with the RMAP or cross-recognized program.

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Each of the facilities which we believe may source Conflict Minerals from the Covered Countries has received a “conformant” designation from the RMAP.

To our knowledge, none of the Necessary Conflict Minerals contained in the products we manufactured or contracted to be manufactured during the reporting period directly or indirectly financed or benefitted armed groups in the Covered Countries.

Risk Mitigation

We remain committed to familiarizing our supply chain with our compliance process and enhancing our internal systems of controls, and we expect to continue improving upon the steps outlined below. These are the steps we took for our 2021 reporting cycle to mitigate the risk that the Necessary Conflict Minerals contained in the products we manufacture or contract to be manufactured may have benefited armed groups:

•further educated our supply chain and employees about Conflict Minerals reporting requirements;

•continued pursuing Conflict Minerals identification during our supplier qualification and product development processes;

•continued including our Conflict Minerals clause in purchasing contracts, either upon establishment or during the renewal process;

•performed additional material research and further identified where Necessary Conflict Minerals are present in our existing products and likely to be present in future products, especially with regard to recent acquisitions that will impact future reporting;

•surveyed suppliers and collected responses for the respective reporting period;

•prioritized supplier follow up by using criteria which captured the greatest risk and leverage in our supply chain;

•continued to encourage our suppliers to obtain current, accurate and complete smelter and refiner information that is specific to the products they sell to us;

•compared and validated supplier-identified smelters and refiners to information collected via independent smelter and refiner audit programs such as the RMAP; and

•maintained our membership and active participation in the RMI and related working groups.

Conclusion Statement

We have provided the information in this Report as of the date of filing with the SEC.

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Annex I

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Annex II

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