[SD] Simpson Manufacturing Co., Inc. Specialized Disclosure Report

Rhea-AI Filing Summary

Simpson Manufacturing Co., Inc. conducted a reasonable country-of-origin inquiry for the period January 1, 2024 to December 31, 2024 and determined that a small number of its products may require conflict minerals for functionality or production. The company does not source minerals directly from smelters or refineries and received conflict minerals through intermediaries.

The company contacted relevant suppliers, obtained certifications about the source of the minerals, and concluded in good faith that it has no reason to believe the minerals originated in the Covered Countries or that they came from non-recycled sources. Based on this RCOI, Simpson is not required to file a separate Conflict Minerals Report and has posted its disclosure on its investor website.

Positive

• Performed a reasonable country-of-origin inquiry (RCOI) covering January 1, 2024 to December 31, 2024
• Obtained supplier certifications confirming the reported sources of conflict minerals in the supply chain
• Concluded no reason to believe the minerals originated in Covered Countries or were non-recycled, so no separate Conflict Minerals Report is required
• Disclosure published online at the company investor website

Negative

• Some products rely on conflict minerals for functionality or production
• Company does not source directly from smelters or refineries and instead receives minerals through intermediaries

Insights

Financial Analyst

TL;DR: Compliance-focused disclosure; no evidence found that minerals originated in Covered Countries for 2024.

The Form SD shows Simpson performed a reasonable country-of-origin inquiry for 2024, identified a limited set of products that may contain conflict minerals, and obtained supplier certifications about mineral sources. The company explicitly states it does not source directly from smelters or refineries and received materials via intermediaries. The disclosed conclusion—that there is no reason to believe minerals originated in the Covered Countries or were non-recycled—means Simpson is not filing a separate Conflict Minerals Report for the period, reflecting procedural compliance with Rule 13p-1.

Corporate Governance Expert

TL;DR: Governance process documented; supplier certifications obtained and disclosure published online.

Simpson documents an internal inquiry process and outreach to suppliers, and it obtained certifications regarding the origin of conflict minerals used in applicable products. The company publicly posted the disclosure and determined, based on its RCOI, that further reporting via a Conflict Minerals Report was not required for the covered period. These steps demonstrate adherence to the Rule 13p-1 disclosure framework as presented in the filing.

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

Simpson Manufacturing Co., Inc.

(Exact name of registrant as specified in its charter)

Delaware

1-13429

94-3196943

(State or other jurisdiction of incorporation)

(Commission file number)

(I.R.S. Employer Identification No.)

5956 W. Las Positas Boulevard, Pleasanton, CA 94588

(Address of principal executive offices) (Zip code)

Matt Dunn, (925) 560-9000

 (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:

ý			Rule 13p-1 under the Securities Exchange Act (17CFR 240.13p-1) for the reporting period January 1 to December 31, 2024.
☐			Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ________.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

Simpson Manufacturing Co., Inc. (the “Company”), is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period from January 1, 2024 to December 31, 2024 (the "Covered Period").

Rule 13p-1 requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain "conflict minerals" (as defined below) are necessary to the functionality or production of such products. Form SD defines: "conflict minerals" as: cassiterite, columbite-tantalite (coltan), wolframite and their derivatives, which are limited to tin, tantalum and tungsten and gold; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an "adjoining country," as such term is defined in Form SD (collectively, the "Covered Countries"). The Company evaluated its products and determined that the Company's operations may at times manufacture, or contract to manufacture, a small number of products which conflict minerals are necessary to the functionality or production of those products (collectively, the "products"). The Company does not source any conflict minerals directly from any smelters or refineries, but rather receives the conflict minerals for its applicable products through intermediaries. The Company has conducted, in good faith, a reasonable country of origin inquiry ("RCOI") to determine whether any conflict minerals contained in the products originated in the Covered Countries or from recycled or scrap source taking into consideration the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas approved by the Organization for Economic Co-operation and Development. The Company’s inquiry included internal inquiries of the Company's personnel who would know the elemental or chemical composition of the products to determine if the conflict minerals were necessary for the products’ functionality or production and identified the use of the conflict minerals; the Company then traced each use of the conflict minerals to a specific supplier. All suppliers of conflict minerals were contacted to certify the source of the conflict minerals that were in the Company’s supply chain during the Covered Period. The Company obtained all such certifications. Based on the RCOI described above, the Company has in good faith concluded that (a) it has no reason to believe that the conflict minerals, necessary for the functionality or production of the products for the Covered Period, may have originated in the Covered Countries or (b) the conflict minerals necessary for the functionality or production of the products for the Covered Period came from recycled or scrap sources. Pursuant to Item 1.01 (b) of Form SD, based on the results of the RCOI, the Company is providing information pursuant to this Form SD and is not required to file a separate Conflict Minerals Report for the Covered Period.

A copy of the Company's Conflict Minerals Disclosure is publicly available at https://ir.simpsonmfg.com.

Item 1.02 Exhibit

Not Applicable.

Section 3 - Exhibits

Item 3.01 Exhibits

Not Applicable

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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 undersigned hereunto duly authorized.

									Simpson Manufacturing Co., Inc.
									(Registrant)
Date:			August 13, 2025			By			/s/ Matt Dunn
									Matt Dunn
									Chief Financial Officer and Treasurer

3

FAQ

What period does Simpson Manufacturing's (SSD) Form SD cover?

The disclosure covers the reporting period January 1, 2024 to December 31, 2024.

Did Simpson Manufacturing (SSD) find conflict minerals originating in the Democratic Republic of the Congo (DRC)?

Based on its RCOI, the company concluded it has no reason to believe the conflict minerals originated in the Covered Countries, including the DRC.

Does Simpson Manufacturing (SSD) source conflict minerals directly from smelters or refineries?

No. The company stated it does not source directly from smelters or refineries and receives minerals through intermediaries.

Will Simpson Manufacturing (SSD) file a separate Conflict Minerals Report for 2024?

No. The company states that based on the RCOI results it is not required to file a separate Conflict Minerals Report for the covered period.

Where can I view Simpson Manufacturing's conflict minerals disclosure?

The company posted its Conflict Minerals Disclosure on its investor site at https://ir.simpsonmfg.com.