Additionally, as mentioned above, we engaged a third-party conflict minerals service
provider to identify and assess risk in our supply chain and to compile and review available information on smelters and refiners in our supply chain. We utilized the CMRT as a preliminary means to identify the smelters and refiners in our supply
chain. Based on the responses we received from the Subject Suppliers, we determined that approximately 14% of the verified smelters and refiners required further diligence on the source and chain of custody of the Conflict Minerals they processed.
This determination was based on responses indicating that a Subject Supplier or its supply chain was known or thought to source Conflict Minerals from the Democratic Republic of the Congo or an adjoining country or that Conflict Minerals were
sourced from countries which are not known to have reserves.
After establishing the smelters and refiners in our supply chain, we sought
to determine those that are certified as conflict-free. To make this determination we relied on internationally accepted audit standards, including the Responsible Minerals Assurance Process, the London Bullion Market Association of Good Delivery
Program and the Responsible Jewellery Council Chain-of-Custody Certification. If a smelter or refiner was not certified by such a standard, further steps were taken to
obtain information about its sourcing practices, including countries of origin and transfer, and to determine whether the smelter or refiner maintains internal due diligence procedures or other processes that track the chain of custody of its
minerals. In these respects, our third-party conflict minerals service provider reviewed whether the facility has a documented, effective and communicated conflict-free policy, whether the facility has an accounting system to support a mass balance
of materials processed, and whether the facility retains traceability documentation. To obtain this information our service provider made up to three attempts to contact each smelter or refiner and reviewed publicly available information.
On an annual basis, we plan to review the risks identified in our supply chain and respond to such risks as necessary. We also produce this
annual Conflict Minerals Report, which describes our supply chain due diligence processes and findings in detail and is filed with the SEC and posted on our website at www.quantaservices.com.
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IV. |
Independent Private Sector Audit and Risk Mitigation |
In accordance with the guidance provided in the SECs Statement on the Effect of the Recent Court of Appeals Decision on the Conflict
Minerals Rule, issued April 29, 2014, this Conflict Minerals Report was not audited by an independent private sector auditor.
With
respect to the products we manufacture or contract to manufacture for sale to third parties that are reasonably believed to contain Conflict Minerals (described in further detail below), we plan to complete the following steps to mitigate the risk
that such Conflict Minerals directly or indirectly finance or benefit armed groups: continue to assess the presence of Conflict Minerals in our supply chain; continue to engage our direct suppliers with annual requests for Conflict Minerals
reporting information, targeting a higher response rate; and if ultimately required, conduct an audit of our Conflict Minerals due diligence measures to determine whether they conform, in all material respects, to the criteria set forth in the OECD
Framework.
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V. |
Results of Due Diligence Performed and Product Description |
After completion of our due diligence process for the calendar year ended December 31, 2023, we determined that certain of our necessary
Conflict Minerals did not originate in the Democratic Republic of the Congo or an adjoining country or originated from recycled or scrap sources. However, we were unable to obtain sufficient information to fully identify all the processing
facilities utilized to produce our necessary Conflict Minerals or all the countries of origin of our necessary Conflict Minerals.
We are
a leading provider of specialty contracting services, delivering comprehensive infrastructure solutions for the electric and gas utility, renewable energy, communications, pipeline and energy industries, providing services for infrastructure within
each of those industries. While substantially all of our revenues are attributable to the performance of these services for our customers, we do manufacture a limited range of products for use within the industries in which we operate. The products
we manufacture or contract to manufacture for sale to third parties that are reasonably believed to contain Conflict Minerals include TransBanker® transformer training labs, which are mobile
or stationary training labs that are used to train electrical lineworkers, and certain life support equipment utilized in the catalyst handling industry. The Conflict Minerals are predominantly utilized in electrical and electronic components
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