Exhibit 1.01

Quanta Services, Inc.

Conflict Minerals Report

(for the Year Ended December 31, 2019)

This Conflict Minerals Report for Quanta Services, Inc. (the “Company,” “Quanta,” “we” or “our”) for the calendar year ended December 31, 2019 is filed in compliance with the reporting requirements of Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended. Certain terms included in this Conflict Minerals Report are defined within Rule 13p-1 and Release No. 34-67716 issued by the Securities and Exchange Commission (the “SEC”) on August 22, 2012. Therefore, please refer to those sources for such definitions. A copy of this Conflict Minerals Report can be found on our website at www.quantaservices.com.

 

I.

Applicability of Rule 13p-1

For the calendar year ended December 31, 2019, the Company determined that certain of our subsidiaries were subject to Rule 13p-1 as a result of manufacturing or contracting to manufacture products for sale to third parties reasonably believed to contain tin, tantalum, tungsten and/or gold (the “Conflict Minerals”), where such Conflict Minerals are necessary to the functionality or production of such products.

 

II.

Reasonable Country of Origin Inquiry

The Company does not source any Conflict Minerals used in the production of its products directly from any smelters or refiners. However, we identified 33 suppliers from whom we may have purchased components containing necessary Conflict Minerals (the “Subject Suppliers”). After identifying this group, we conducted a reasonable country of origin inquiry (“RCOI”) to determine whether any of the Conflict Minerals used in the production of our products originated in the Democratic Republic of the Congo or an adjoining country or whether they came from recycled or scrap sources. The Company and our third party conflict minerals service provider engaged in a systematic outreach to all Subject Suppliers, utilizing the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (“CMRT”) to request confirmation of the presence of Conflict Minerals in the raw materials or components they supplied to the Company and information regarding the country and facility of origin of any such Conflict Minerals. Specifically, our efforts included sending to each Subject Supplier an initial communication containing the CMRT and providing access to an engagement portal with various educational resources intended to facilitate their understanding of the RCOI process and the CMRT questions. Further, if a Subject Supplier was unable to provide a completed CMRT, other suppliers in the supply chain were engaged in an effort to establish a chain of custody to the smelter or refiner.

After establishing an initial deadline for return of completed CMRTs, several follow-up requests were sent to non-responsive Subject Suppliers. We ultimately received responses from a portion of the Subject Suppliers, certain of which indicated one or more Conflict Minerals was necessary to the functionality or production of the products they supplied to the Company. The responses were evaluated for plausibility, consistency and missing information, and additional information was requested as needed to clarify any imprecise responses. The smelter and refiner information collected was compared against our service provider’s smelter/refiner database, which contains companies that are known metal processors, companies that are exclusive recyclers, countries of origin for certain mines, and conflict-free certification status for certain smelters and refiners.

Based on the results of our RCOI, we have reason to believe that the Conflict Minerals necessary to one or more of the Company’s products may have originated within the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources. As such, we conducted further due diligence as described below.

 

III.

Due Diligence Measures Performed

The Company’s due diligence program was designed based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”), an internationally recognized due diligence framework. As an initial step in our program, we established an internal, cross-functional team and internal reporting processes to identify the presence of Conflict Minerals within Quanta’s products and supply chain and to determine the applicability of Rule 13p-1.

 

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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 15% 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.

 

IV.

Independent Private Sector Audit and Risk Mitigation

In accordance with the guidance provided in the SEC’s 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.

 

V.

Results of Due Diligence Performed and Product Description

After completion of our due diligence process for the calendar year ended December 31, 2019, 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.

The products we manufacture or contract to manufacture for sale to third parties that are reasonably believed to contain Conflict Minerals include TransBankers, which are mobile transformer training tools that can be operated at a service center or at a worksite to train electrical line workers. The Conflict Minerals are predominantly utilized in electrical components within these products (e.g., fused disconnects, electric meters and gang switches). Our efforts to determine the mine or location of origin of the necessary Conflict Minerals are set forth above under Due Diligence Measures Performed. Set forth below are the processing facilities and countries of origin that the Company has been able to confirm based on the information provided by our Subject Suppliers and our subsequent due diligence.

 

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Because Quanta is a downstream user of Conflict Minerals, we must rely on the representations and information provided by our Subject Suppliers and other third parties within our supply chain. As a result, incomplete or inaccurate information provided by the Subject Suppliers or by a smelter or refiner could affect the accuracy or completeness of the information set forth below or other information contained in this Conflict Minerals Report.

Processing Facilities

 

 

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*	Smelter certified as conflict-free by the Responsible Minerals Assurance Process, the London Bullion Market Association Good Delivery Program and /or the Responsible Jewellery Council Chain-of-Custody Certification as of April 1, 2020.

 

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Countries of Origin
Angola		Guyana		Peru
Argentina		Hong Kong		Philippines
Armenia		Hungary		Poland
Australia		India		Portugal
Austria		Indonesia		Russia
Belarus		Ireland		Rwanda
Belgium		Israel		Saudi Arabia
Bermuda		Italy		Sierra Leone
Bolivia		Ivory Coast		Singapore
Brazil		Japan		Slovakia
Burundi		Jersey		South Africa
Cambodia		Kazakhstan		South Korea
Canada		Kenya		South Sudan
Central African Republic		Kyrgyzstan		Spain
Chile		Laos		Suriname
China		Luxembourg		Sweden
Colombia		Madagascar		Switzerland
Congo (Brazzaville)		Malaysia		Taiwan
Czech Republic		Mali		Tajikistan
Djibouti		Mexico		Tanzania
DRC – Congo (Kinshasa)		Mongolia		Thailand
Ecuador		Morocco		Turkey
Egypt		Mozambique		Uganda
Estonia		Myanmar		United Arab Emirates
Ethiopia		Namibia		United Kingdom
Finland		Netherlands		United States of America
France		New Zealand		Uzbekistan
Germany		Niger		Vietnam
Ghana		Nigeria		Zambia
Guinea		Papua New Guinea		Zimbabwe

 

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