AMFW Amec Foster Wheeler Plc American Depositary Shares (delisted)

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, DC 20549

FORM SD

Specialized Disclosure Report

AMEC FOSTER WHEELER PLC

(formerly AMEC plc)

(Exact Name of Registrant as Specified in Its Charter)

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 230.13p-1) for the reporting period

from January 1 to December 31, 2016.

Section 1 – Conflict Minerals Disclosure

In order to comply with Section 13(p) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and related regulations (collectively, the “Conflict Minerals Rule”), Amec Foster Wheeler plc conducted a review of products that it manufactures or contracts to manufacture to ascertain if such products contain conflict minerals that are necessary to the functionality or production of such products. Except as the context otherwise requires, the terms “Amec Foster Wheeler”, “the Company”, “we”, “us” and “our,” as used herein refer to Amec Foster Wheeler plc and its direct and indirect subsidiaries. As defined in Form SD issued under the Exchange Act, Conflict Minerals currently consist of:

During this review, we ascertained that certain of our products contain or may contain Conflict Minerals necessary to the functionality or production of those products.

Our Conflict Minerals Compliance Program

We have established a project team to lead our Conflict Minerals compliance program. This team, comprised of individuals from our legal, commercial, project delivery, supply chain and compliance departments, provided Conflict Mineral Rule training internally to our management and engineering teams to educate them on the rule. The project team worked with our commercial, supply chain, engineering and materials experts to conduct extensive reviews of our standard purchasing requisition codes to identify materials we purchase which contain or may contain Conflict Minerals which are used either to manufacture products in our own fabrication facilities, or which are used in products for which we contract the manufacturing of (and in the latter case we identified those materials for which we possess a degree of influence over the material specifications and manufacturing process). After identifying such materials, which we refer to as “in scope materials”, our purchasing group identified all Company suppliers of such in scope materials. We then conducted a reasonable country of origin inquiry, described below.

Based on the review described above, our in scope materials included pressure parts, piping and ductwork used in the manufacture of steam generating equipment, environmental equipment for cleaning flue gas, fired heaters and mine conveying and bulk material handling systems.

Our Supply Chain Code of Business Conduct, which is included in purchase orders with suppliers, includes the following statement: “Supply chain companies must have adequate policies and reliable systems to prevent the use of illegally or unethically sourced materials, in particular policies and systems to procure tantalum, tin, tungsten and gold from sources that have been verified as conflict free, and provide supporting data on its supply chain for those materials to Amec Foster Wheeler promptly when requested.”

Our Reasonable Country of Origin Inquiry

Amec Foster Wheeler’s supply chain is multi-tiered and we do not purchase Conflict Minerals directly from mines, smelters or refiners. Therefore, Amec Foster Wheeler must rely on our suppliers to provide information on the origin of the Conflict Minerals in our in scope materials.

Our reasonable country of origin inquiry consisted of the following steps:

1.        The project team created a conflict minerals supplier database for conflict mineral disclosure tracking purposes and suppliers of in scope materials were entered into such database.

2.        Our purchasing group contacted our suppliers of in scope materials to inform them about the Conflict Minerals Rule, and to ask each supplier to complete a standard conflict minerals reporting survey. Suppliers who had previously delivered a conflict minerals reporting survey to us were asked to complete an annual update and re-certification if new materials were purchased from the supplier in the current reporting year. The conflict minerals reporting survey requires suppliers to identify if the materials which may contain Conflict Minerals originate from the Democratic Republic of the Congo, Zambia, Angola, Republic of the Congo, Central African Republic, South Sudan, Uganda, Rwanda, Burundi or Tanzania (the “Covered Countries”) or come from a recycler or scrap supplier. For materials that originate from the Covered Countries, suppliers must identify the smelter or refiner that such supplier and/or its suppliers use to supply us with such materials. To the extent necessary, suppliers were required to ask their suppliers of materials which may contain Conflict Minerals to complete a conflict minerals reporting survey, and so forth along the supply chain until the smelters or refiners of any Conflict Minerals had been identified. In addition, suppliers of in scope materials were asked to certify to us that statements of the supplier in the conflict minerals reporting survey were true, complete and accurate in all respects.

3.        Our project team collected the supplier surveys, certifications and re-certifications and reviewed them to identify any warning signs including incomplete or inconsistent reporting which required follow-up with the supplier.

4.        We recorded the supplier survey responses and certifications and re-certifications in our conflict minerals supplier database and analyzed the results.

Based on these results, we have determined that the in scope materials and therefore our products containing those materials for the 2016 reporting period were all within one of the following three categories:

We have therefore concluded that we are not required to conduct further due diligence on the supply chain or submit a Conflict Minerals Report with this disclosure.

Ongoing Activities

As part of our global Ethics & Compliance programme we monitor ongoing developments in respect of conflict minerals regimes, including the developing EU legislation around conflict minerals and the OECD Guidelines for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas we plan to update the conflict minerals supplier database on an ongoing basis to capture any new in scope materials and suppliers. We intend to continue our practice of seeking annual updates and re-certifications from the suppliers who responded to the surveys we have distributed to date.

Furthermore, in accordance with Section 13(p) of the Exchange Act, as soon as reasonably practicable after we file this Form SD with the Securities and Exchange Commission, this report will be available at the Investor Relations section of our website, www.amecfw.com.

Not required.

Section 2 – Exhibits

Not required.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the Registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

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