EX-1.01 2 exhibit101toformsd2024.htm EX-1.01 Document


Exhibit 1.01
Energizer Holdings, Inc.
Conflict Minerals Report
For the Reporting Period from January 1, 2024 to December 31, 2024

This Conflict Minerals Report for the year ended December 31, 2024 is provided by Energizer Holdings, Inc. (“Energizer”, “Company”, “we”, “us” and “our”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Under the Rule, we are required to make certain disclosures regarding our manufactured products that contain conflict minerals, provided those conflict minerals are necessary to the functionality or production of those products. As defined by the Rule, and for purposes of this report, the conflict minerals are cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“Conflict Minerals”; tin, tantalum, tungsten and gold collectively are referred to as “3TG”).

As detailed below, based on our reasonable country of origin inquiry, Energizer has no reason to believe that the 3TG in any of our products is funding armed conflict in the Democratic Republic of Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”). However, it remains challenging for many companies and their suppliers (including us and our suppliers) to gather complete and reliable data. Consequently, we exercised due diligence on the Conflict Minerals’ origin and chain of custody, and we are providing this Conflict Minerals Report to describe our due diligence processes and results.


Company Overview

Energizer Holdings, Inc. (NYSE: ENR), headquartered in St. Louis, Missouri, is one of the world’s largest manufacturers and distributors of primary batteries, portable lights, and auto care appearance, performance, refrigerant, and fragrance products. Our portfolio of globally recognized brands include Energizer®, Armor All®, Eveready®, Rayovac®, STP®, Varta®, A/C Pro®, Refresh Your Car!®, California Scents®, Driven®, Bahama & Co.®, LEXOL®, Eagle One®, Nu Finish®, Scratch Doctor®, Tuff Stuff®, NEVR-DULL®, Carnu® , Grand Prix®, Kit®, Tempo® and Centralsul®. As a global branded consumer products company, Energizer’s mission is to lead the charge to deliver value to our customers and consumers better than anyone else. Visit www.energizerholdings.com for more details.

The Company identified Conflict Minerals contained in products: (i) for which Conflict Minerals are necessary to the functionality or production of those products; (ii) that were manufactured by, or contracted to be manufactured for, us; (iii) for which the manufacture was completed during calendar year 2024; and (iv) with respect to Conflict Minerals in such products, for which we were unable to reasonably determine that all of the Conflict Minerals contained therein did not originate in the Covered Countries (or did not come from recycled or scrap sources) (collectively, the “Covered Products”). We believe that Conflict Minerals are present in the following products: round cell alkaline batteries, round cell carbon zinc batteries, lighting, and chargers.

Conflict Minerals Policy

We have adopted a conflict minerals policy which expresses Energizer’s goal to ensure all 3TG used in our products is “DRC conflict-free”. Our policy is publicly available on our website at https://www.energizerholdings.com/company/partners-suppliers/overview. The website and information accessible through it are not incorporated into this document.

Supply Chain

A number of Energizer’s products contain advanced components and compounds manufactured by our suppliers. These suppliers may manufacture the components themselves or source some or all of the production to their suppliers. These suppliers may do the same with lower tier suppliers. We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us - including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three to five years or more, and we cannot unilaterally impose new contract terms or flow-down requirements. As we enter into new contracts, or our contracts renew, we have sought to include a clause under which our suppliers undertake that no 3TG that originated in




the Covered Countries are incorporated in, or necessary to, the functionality or production of any product delivered to us, including in any component manufactured of such product by a third party.

Under the terms of these contracts, it will take a number of years to ensure that all of our supplier contracts contain appropriate clauses. In the meantime, as described below, we are working with our suppliers to obtain 3TG sourcing information.

Due to the size of our supply base, it is not practicable to conduct a survey of all of our suppliers and we determined a reasonable approach was to conduct a survey of the suppliers who provided raw materials for products containing 3TG in relevant product supply chains as well as sourced product suppliers in 2024. We assessed our industry as well as others and concluded that the risk-based approach was consistent with how many peer companies approached the Rule. We also implemented software designed to facilitate and track our supplier surveys.

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it was difficult to identify actors upstream from our direct suppliers. As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our sector and other sectors. Accordingly, we participate in a number of industry-wide initiatives, including the Responsible Minerals Initiative (RMI), an industry-wide initiative supporting upstream actors in the supply chain, through our supply chain data management service provider, Assent Compliance.

Reasonable Country of Origin Inquiry (RCOI) Results

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Energizer retained a third-party supply chain data management service provider, Assent Inc. (“Assent”), to assist us with reviewing the supply chain and identifying risks. The Company provided Assent with a list of suppliers and parts associated with the in-scope products. To trace materials, and demonstrate transparency procured by the supply chain, Energizer utilized the Conflict Minerals Reporting Template (“CMRT”) Version 6.31 or higher to conduct a survey of all in-scope suppliers.

During the supplier survey, Assent contacted suppliers utilizing a software-as-a-service (SaaS) platform that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The platform also provides functionality that meets the OECD Guidance (defined below) process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement.

Through Assent, Energizer requested that all in-scope suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the platform for future reporting and transparency. Energizer directly contacted suppliers that were unresponsive to communications during the diligence process and requested these suppliers complete the CMRT.

Our program continues to include automated data validation on all submitted CMRTs. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

Design of Due Diligence Framework

Our due diligence framework was designed to conform, in material respects, with the framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”) and the related Supplements for 3TG.





Due Diligence Measures Performed

Due diligence measures we performed included, but were not limited to:
Establishing strong management and controls systems and communicating our policy on conflict minerals to direct suppliers;
Communicating the commitments and requirements expected of our direct suppliers, supported by training and resources, and email and phone dialogues;
Designing and implementing a strategy to respond to risks and determining whether 3TG smelter and refiner names were included on the Responsible Minerals Initiative’s Conformant Smelter Report (“CSR”). The CSR is generally understood to contain the names of smelters and the associated risk level of their mineral sourcing;
Carrying out independent third-party audit of supply chain due diligence at identified points in the supply chain; and
Reporting annually on supply chain due diligence.

Due Diligence Results

Through requesting our suppliers to complete the CMRT, we determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain. We identified approximately 133 3TG smelters and refiners included in our suppliers’ supply chains. Nonetheless, most of our supplier responses were provided at a company level. Many suppliers did not provide verifiable smelter or processing information or responded at a company-wide level which did not allow us to conclude that the Conflict Minerals were processed by any one particular facility. Based on the information provided by our suppliers, we could not identify how many of these smelters produced materials specifically used in the Covered Products. Therefore, it is possible that none of the materials from these smelters actually entered our supply chain. The list of 3TG smelters and refiners and the identified countries of origin are included as Appendix A. Accordingly, Energizer believes it is reasonable to conclude that the Covered Products are “DRC conflict undeterminable,” as defined in the Rule.

Steps to be taken to mitigate risk

We intend to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary Conflict Minerals in our Products could benefit armed groups in the DRC or adjoining countries:
Continue to incorporate a Conflict Minerals flow-down clause in new or renewed supplier contracts;
Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses;
Engage any of our suppliers found to be supplying us with 3TG from sources that support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict; and
Work with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.















Appendix A - List of 3TG Smelters/Refiners and Identified Countries of Origin

Based on the information that was provided by the in-scope suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed below. We are unable to definitively link the identified 3TG smelters and refiners to only those products and materials in our supply chain; therefore our 3TG smelter and refiner list likely contains more processing facilities than are actually in our supply chain and used to manufacture the Covered Products.

Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information to conclusively determine the country of origin of all of the Conflict Minerals in the Covered Products. At the same time, we received no information from our in-scope suppliers indicating that the 3TG in our Covered Products directly or indirectly financed or benefited armed groups in the Covered Countries. Also, due to the manner in which our in-scope suppliers disclosed country of origin information, we do not believe that all of the countries named are actually in our supply chain or Covered Products. However, based on the information that has been obtained, the Company has reasonably determined that the Conflict Minerals may have originated from the countries listed in the table below.

Based on the information obtained pursuant to the due diligence process, the Company believes there is a risk that the Covered Products may contain Conflict Minerals from the Covered Countries. The Company’s due diligence into the supply chain was unable to determine whether any of the Covered Products did or did not contain any Conflict Minerals from any Covered Country, as defined in the Rule.


Appendix A: Smelter List

Metal
Smelter Name
Smelter Facility Location
Gold
Aida Chemical Industries Co., Ltd.
Japan
Gold
Argor-Heraeus S.A.
Switzerland
Gold
Asahi Pretec Corp.
Japan
Gold
Asaka Riken Co., Ltd.
Japan
Gold
Dowa
Japan
Gold
Eco-System Recycling Co., Ltd. East Plant
Japan
Gold
Heraeus Metals Hong Kong Ltd.
China
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Gold
Asahi Refining USA Inc.
United States Of America
Gold
Asahi Refining Canada Ltd.
Canada
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Gold
Kojima Chemicals Co., Ltd.
Japan
Gold
LS MnM Inc.
Korea, Republic Of
Gold
Matsuda Sangyo Co., Ltd.
Japan
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
Gold
Metalor Technologies S.A.
Switzerland
Gold
Metalor USA Refining Corporation
United States Of America
Gold
Mitsubishi Materials Corporation
Japan
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
Gold
Nihon Material Co., Ltd.
Japan
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China




Gold
Solar Applied Materials Technology Corp.
Taiwan, Province Of China
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Gold
Shandong Gold Smelting Co., Ltd.
China
Gold
Tokuriki Honten Co., Ltd.
Japan
Gold
United Precious Metal Refining, Inc.
United States Of America
Gold
Western Australian Mint (T/a The Perth Mint)
Australia
Gold
L'Orfebre S.A.
Andorra
Gold
Agosi AG
Germany
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
Brazil
Gold
Aurubis AG
Germany
Gold
Boliden Ronnskar
Sweden
Gold
C. Hafner GmbH + Co. KG
Germany
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Gold
Chimet S.p.A.
Italy
Gold
Heimerle + Meule GmbH
Germany
Gold
Heraeus Germany GmbH Co. KG
Germany
Gold
Istanbul Gold Refinery
Turkey
Gold
Materion
United States Of America
Gold
Metalor Technologies (Suzhou) Ltd.
China
Gold
Metalor Technologies (Hong Kong) Ltd.
China
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Mexico
Gold
Ohura Precious Metal Industry Co., Ltd.
Japan
Gold
MKS PAMP SA
Switzerland
Gold
Rand Refinery (Pty) Ltd.
South Africa
Gold
Royal Canadian Mint
Canada
Gold
SEMPSA Joyeria Plateria S.A.
Spain
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
Gold
Valcambi S.A.
Switzerland
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Gold
WIELAND Edelmetalle GmbH
Germany
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Austria
Gold
Japan Mint
Japan
Tantalum
F&X Electro-Materials Ltd.
China
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
China
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
China
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Japan
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
Tantalum
Taki Chemical Co., Ltd.
Japan
Tantalum
TANIOBIS Co., Ltd.
Thailand
Tantalum
TANIOBIS GmbH
Germany
Tantalum
Materion Newton Inc.
United States Of America
Tantalum
TANIOBIS Japan Co., Ltd.
Japan
Tantalum
TANIOBIS Smelting GmbH & Co. KG
Germany




Tantalum
Global Advanced Metals Boyertown
United States Of America
Tantalum
Global Advanced Metals Aizu
Japan
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
China
Tantalum
D Block Metals, LLC
United States Of America
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China
Tantalum
Jiangxi Tuohong New Raw Material
China
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
China
Tin
PT Timah Tbk Mentok
Indonesia
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
Tin
Thaisarco
Thailand
Tin
Dowa
Japan
Tin
Minsur
Peru
Tin
Mitsubishi Materials Corporation
Japan
Tin
PT Artha Cipta Langgeng
Indonesia
Tin
PT Refined Bangka Tin
Tin
PT Timah Tbk Kundur
Indonesia
Tin
Rui Da Hung
Taiwan, Province Of China
Tin
PT Bangka Serumpun
Indonesia
Tin
Mineracao Taboca S.A.
Brazil
Tin
Operaciones Metalurgicas S.A.
Bolivia (Plurinational State Of)
Tin
Aurubis Beerse
Belgium
Tin
Aurubis Berango
Spain
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China
Tin
Alpha
United States Of America
Tin
EM Vinto
Bolivia (Plurinational State Of)
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
Tin
China Tin Group Co., Ltd.
China
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Tin
Metallic Resources, Inc.
United States Of America
Tin
Jiangxi New Nanshan Technology Ltd.
China
Tin
PT Mitra Stania Prima
Indonesia
Tin
White Solder Metalurgia e Mineracao Ltda.
Brazil
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
China
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
China
Tin
Tin Technology & Refining
United States Of America
Tin
Luna Smelter, Ltd.
Rwanda
Tin
CRM Synergies
Spain
Tin
Fabrica Auricchio Industria e Comercio Ltda.
Brazil
Tin
Mineracao Taboca S.A.
Brazil
Tin
Fenix Metals
Poland
Tin
PT Prima Timah Utama
Indonesia
Tin
PT ATD Makmur Mandiri Jaya
Indonesia




Tin
PT Menara Cipta Mulia
Indonesia
Tungsten
A.L.M.T. Corp.
Japan
Tungsten
Kennametal Huntsville
United States Of America
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
Tungsten
Global Tungsten & Powders LLC
United States Of America
Tungsten
Japan New Metals Co., Ltd.
Japan
Tungsten
Xiamen Tungsten Co., Ltd.
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
Tungsten
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
China
Tungsten
H.C. Starck Tungsten GmbH
Germany
Tungsten
Masan High-Tech Materials
Viet Nam
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China
Tungsten
Niagara Refining LLC
United States Of America
Tungsten
Wolfram Bergbau und Hutten AG
Austria
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
Tungsten
TANIOBIS Smelting GmbH & Co. KG
Germany
Tungsten
Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
China