EX-1.01 2 fy2025_q3xsdxex101xconflic.htm EXHIBIT 1.01 Document

Exhibit 1.01


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Conflict Minerals Report For Calendar Year 2024

This is The Walt Disney Company’s 2024 (January 1 to December 31, 2024) Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”).
Background
The Walt Disney Company, together with its subsidiaries, is a diversified worldwide entertainment company with operations in three segments: Entertainment, Sports and Experiences. For convenience, the terms “Company,” “Disney,” “we” and “our” are used in this CMR to refer collectively to the parent company, The Walt Disney Company, and its consolidated subsidiaries through which its various businesses were actually conducted during calendar 2024.
The products we sell that may include gold, columbite-tantalite (coltan), cassiterite, wolframite or their derivatives, tantalum, tin and tungsten (collectively, the “Subject Minerals” or “3TG”), that are necessary to the products’ functionality or production (“necessary Subject Minerals”), are items such as clothing, accessories, electronic toys, jewelry, and other consumer goods. We classify these items together as retail merchandise, and that is the product category covered by this CMR. We sell many of these items at our entertainment venues, including our parks and resorts, and directly through Disney Stores, including our online stores. We also sell retail merchandise wholesale to other retailers.
The sale of retail merchandise in calendar 2024 was nominal. Due to the dynamic nature of our business, the items we sell change rapidly, regularly replaced by other items sourced from other suppliers. The Company does not manufacture any of the retail merchandise it sells, sourcing the specific merchandise items that may contain Subject Minerals from suppliers. Many of our suppliers themselves source components of these items from numerous other suppliers, and our direct suppliers are often many steps removed from the source of the raw materials contained in the items. In addition, in many cases the items we acquire from a supplier represent a small portion of the supplier’s total production. The number, diversity, and frequent turnover of the retail merchandise we sell, the number and turnover of suppliers, and our remote position in the supply chain make it difficult for us to determine and track the source of individual items, the nature of the raw materials included in the items, and the source of those raw materials.
Our Conflict Minerals Compliance Program (the “Program”) is designed to collect relevant information about the sources of raw materials in our products that is as complete as reasonably possible given the large number and diversity of products we sell and in light of our position in the supply chain.
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Our Program is focused on identifying suppliers of retail merchandise that may contain necessary Subject Minerals and gathering information about the supply chain practices of those suppliers. The Program conforms in all material respects to the elements of the guidance set forth in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (the “OECD Guidance”). Consistent with the OECD Guidance, our Program includes:
strong company management systems (including a Conflict Minerals Policy and an established internal management structure);
identification and assessment of risk in the supply chain through a Reasonable Country of Origin Inquiry (“RCOI”);
a strategy to respond to identified risks through due diligence procedures that include follow-up with suppliers who either provide insufficient information to identify sources of necessary Subject Minerals or who provide information indicating that they may source necessary Subject Minerals that may have originated in the Democratic Republic of the Congo or adjoining countries (“Covered Countries”);
a process to support and leverage organizations like Responsible Minerals Initiative’s (“RMI”) independent third-party audits of smelter and refiner due diligence practices1; and
reporting on results of the Program through this CMR.
Company Management Systems
The Company has developed strong management systems that include the following components:
1.Conflict Minerals Policy. A Conflict Minerals Policy that sets out the steps we are taking to comply with the Conflict Minerals Rule. These steps include: the establishment of the internal management structure described below; engagement with suppliers as described in this report; reporting required by the Conflict Minerals Rule; and monitoring developments relating to conflict minerals with an eye to enhancing the Program. Our policy was distributed to suppliers who may supply us with products covered by the Conflict Minerals Rule and is posted on our website at https://impact.disney.com/resources/conflict-minerals-policy/. The policy includes a mechanism for reporting concerns or asking questions regarding the policy.
2.Internal Management Structure. A management oversight structure that includes input from executive-level representatives of Global Product & Labor Standards, Global Public Policy, Legal, Controllership, Investor Relations, and Corporate Communications. These executives are responsible for providing governance and oversight over the execution of the Program and for monitoring the Program’s compliance with regulatory requirements and
1 The Company does not purchase raw materials or ores, does not directly purchase 3TG, and is many steps removed from the smelters and refiners that provide minerals and ores to our suppliers. Because of this, we do not audit or direct audits of smelters and refiners in the supply chain. Instead, we leverage organizations like RMI’s independent third-party audits of smelter and refiner due diligence practices.
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satisfaction of enterprise goals. The day-to-day implementation of the Program is conducted by a Conflict Minerals Compliance Program Team within our Global Product & Labor Standards organization, which is included within our Chief Financial Officer’s purview.
3.Chain of Custody and Traceability. A process that provides support for and engagement with the RMI. The data on which we relied for certain statements in this report was obtained through our membership in RMI using their RCOI report.
Identification and Assessment of Risk Through Reasonable Country of Origin Inquiry
Our RCOI for calendar 2024 included conducting surveys of 81 suppliers that manufactured retail merchandise that may include Subject Minerals to understand their supply chain relating to Subject Minerals.
The calendar 2024 survey responses used RMI’s Conflict Minerals Reporting Template (CMRT), revision 6.4. We received CMRT responses from 80 suppliers, or 99% of the survey group. We supplemented the CMRT with additional questions available in multiple languages designed to provide visibility into these suppliers’ sourcing activities, including the basis for their responses regarding the source of Subject Minerals in the retail merchandise they supplied to us. We also provided these suppliers with access to a live technical support specialist via chat during the survey phase and provided training documents in multiple languages that highlight Frequently Asked Questions on Conflict Minerals and Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, as well as instructions on how to complete the CMRT.
Our communications included our expectations for response and noted that the Conflict Minerals Rule was not intended to stop companies and their suppliers from sourcing from the Covered Countries and that such an embargo would be contrary to the intent of the Conflict Minerals Rule.
Based on CMRT survey responses, interviews, and further review of the retail merchandise supplied, we identified 28 suppliers who manufactured retail merchandise for us that most likely contained necessary Subject Minerals. Of these suppliers:
18 responded that the smelters or refiners in their supply chain did not source the necessary Subject Minerals from Covered Countries for the products they supplied to us, and they provided sufficient information regarding their supply chain program for us to determine that this response was reliable; and
10 responded that at least one smelter or refiner in their supply chain may source Subject Minerals from Covered Countries or unknown countries of origin for the products they supplied to us, and not solely from recycled or scrap sources.

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Due Diligence Measures Performed
Based on our assessment of the survey responses gathered as part of our RCOI for calendar 2024, as described above, we implemented due diligence measures with respect to the suppliers identified in the process above. These measures included:
Performance of targeted follow-up with suppliers who did not initially respond to the survey.
Verification of information regarding smelters and refiners provided by our suppliers with the RMI’s list of conformant smelters and refiners and other lists provided by accredited organizations such as London Bullion Market Association (LBMA) or Responsible Jewelry Council (RJC). Through this effort, we validated the responses of suppliers who indicated that the Subject Minerals in all the products supplied to us did not originate in the Covered Countries.

We also encouraged suppliers who may have sourced Subject Minerals (or product components from sub-suppliers who may have sourced Subject Minerals) from non-conformant smelters or refiners to source from smelters and refiners who are conformant with the relevant RMAP assessment protocols of the RMI, or from another accredited organization.

Smelters, Refiners, and Countries of Origin Information
The 28 surveyed suppliers identified 118 smelters or refiners that supplied them with Subject Minerals.
The following chart shows conformance status by mineral.
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With respect to calendar 2024, we identified through the relevant RMAP assessment protocols of the RMI or other accredited organizations that:
116 of these smelters or refiners were conformant to a responsible mineral assurance program (such as RMI)
2 of these smelters or refiners were not conformant to a responsible mineral assurance program (such as RMI)
We cannot determine whether the 2 smelters and refiners that are not conformant with the relevant RMAP assessment protocols of the RMI sourced necessary Subject Minerals for the retail merchandise we sell from Covered Countries.
Also, our surveyed suppliers could not confirm whether each smelter or refiner they used supplied Subject Minerals in retail merchandise manufactured for the Company. Therefore, we are unable to determine with certainty either the facilities used to process or the source (country, mine or other location) of the actual necessary Subject Minerals for all the retail merchandise we sell.
Listed in Attachment A are the identified smelters and refiners based on the information provided by our surveyed suppliers and listed in Attachment B are the origin of the Subject Minerals.


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Attachment A
Smelters and Refiners Identified by Suppliers

The following table identifies each of the smelters and refiners identified by our surveyed suppliers that may have processed necessary Subject Minerals in retail merchandise manufactured by the supplier. The table includes the name of the smelter or refiner, the Subject Minerals supplied by the smelter or refiner, the location of the smelter or refiner, and the certification obtained by the smelter or refiner, if any. All but 2 of the smelters and refiners identified below are conformant with RMAP assessment protocols of the RMI or other accredited organizations. Disney has encouraged its suppliers to work with the non-conformant smelters to gain certification from RMI or other accredited organizations, or to source from certified smelters or refiners.
MineralSmelter or Refiner Name
ISO Country/Region
Code2
CertificationCertified
GoldAgosi AGDE*‡†Yes
GoldAida Chemical Industries Co., Ltd.JPYes
Gold
Argor-Heraeus S.A.
CH
*‡†Yes
Gold
ASAHI METALFINE, Inc.
JP
*†Yes
Gold
Asahi Refining Canada Ltd.
CA
*†Yes
Gold
Asahi Refining USA Inc.
US
*†Yes
GoldAsaka Riken Co., Ltd.JPYes
GoldChimet S.p.A.IT*†Yes
GoldDowaJPYes
GoldHeraeus Metals Hong Kong Ltd.CN*‡†Yes
Gold
Ishifuku Metal Industry Co., Ltd.
JP
*†Yes
Gold
JX Advanced Metals Corporation
JP
*†Yes
GoldKojima Chemicals Co., Ltd.JPYes
Gold
LS MnM Inc.
KR
*†Yes
GoldMatsuda Sangyo Co., Ltd.JP*†Yes
Gold
Metalor Technologies (Hong Kong) Ltd.
CN
*‡†Yes
GoldMetalor Technologies (Singapore) Pte., Ltd.SG*‡†Yes
GoldMetalor Technologies (Suzhou) Ltd.CN*‡†Yes
Gold
Metalor Technologies S.A.
CH
*‡†Yes
GoldMetalor USA Refining CorporationUS*‡†Yes
GoldMitsubishi Materials CorporationJP*†Yes
Gold
Mitsui Mining and Smelting Co., Ltd.
JP
*†Yes
GoldMKS PAMP SACH*†Yes
Gold
Nihon Material Co., Ltd.
JP
*†Yes
Gold
Shandong Gold Smelting Co., Ltd.
CN
*†Yes
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CN*†Yes
Gold
Solar Applied Materials Technology Corp.
TW
*†Yes
GoldSumitomo Metal Mining Co., Ltd.JP*†Yes
GoldTanaka Kikinzoku Kogyo K.K.JP*†Yes
GoldTokuriki Honten Co., Ltd.JP*†Yes
2
International Standards Organization
*LBMA
RJC
RMAP
**RMAP - Active
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GoldUmicore Precious Metals ThailandTH
No
Gold
Umicore S.A. Business Unit Precious Metals Refining
BE
*†Yes
GoldUnited Precious Metal Refining, Inc.USYes
Gold
Valcambi S.A.
CH
*‡†Yes
Gold
Western Australian Mint (T/a The Perth Mint)
AU
*†Yes
Gold
Yokohama Metal Co., Ltd.
JP
Yes
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CN
*†Yes
Gold
Zijin Mining Group Gold Smelting Co. Ltd.
CN
*†Yes
Tantalum
D Block Metals, LLC
US
Yes
Tantalum
F&X Electro-Materials Ltd.
CN
Yes
Tantalum
FIR Metals & Resource Ltd.
CN
Yes
Tantalum
Global Advanced Metals Aizu
JP
Yes
Tantalum
Global Advanced Metals Boyertown
US
Yes
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CN
Yes
Tantalum
Jiangxi Tuohong New Raw Material
CN
Yes
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CN
Yes
Tantalum
Jiujiang Tanbre Co., Ltd.
CN
Yes
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CN
Yes
Tantalum
KEMET de Mexico
MX
Yes
Tantalum
Materion Newton Inc.
US
Yes
Tantalum
Metallurgical Products India Pvt., Ltd.
IN
Yes
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JP
Yes
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CN
Yes
Tantalum
NPM Silmet AS
EE
Yes
Tantalum
Taki Chemical Co., Ltd.
JP
Yes
Tantalum
TANIOBIS Co., Ltd.
TH
Yes
Tantalum
TANIOBIS GmbH
DE
Yes
Tantalum
TANIOBIS Japan Co., Ltd.
JP
Yes
Tantalum
TANIOBIS Smelting GmbH & Co. KG
DE
Yes
Tantalum
Telex Metals
US
Yes
Tantalum
Ulba Metallurgical Plant JSC
KZ
Yes
Tantalum
XIMEI RESOURCES (GUANGDONG) LIMITED
CN
Yes
Tantalum
XinXing Haorong Electronic Material Co., Ltd.
CN
Yes
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CN
Yes
Tin
Aurubis Beerse
BE
Yes
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CN
Yes
Tin
China Tin Group Co., Ltd.
CN
Yes
Tin
CRM Synergies
ES
Yes
Tin
Dowa
JP
Yes
Tin
DS Myanmar
MM
Yes
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CN
Yes
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CN
Yes
TinJiangxi New Nanshan Technology Ltd.CNYes
TinMalaysia Smelting Corporation (MSC)MYYes
Tin
Malaysia Smelting Corporation Berhad (Port Klang)
MY
Yes
Tin
Mineracao Taboca S.A.
BR
Yes
TinMinsurPEYes
Tin
Mitsubishi Materials Corporation
JP
Yes
Tin
O.M. Manufacturing Philippines, Inc.
PH
Yes
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TinOperaciones Metalurgicas S.A.BOYes
Tin
PT Aries Kencana Sejahtera
ID
Yes
Tin
PT Artha Cipta Langgeng
ID
Yes
Tin
PT Bangka Serumpun
ID
Yes
Tin
PT Bangka Tin Industry
ID
Yes
TinPT Menara Cipta MuliaIDYes
Tin
PT Prima Timah Utama
IDYes
Tin
PT Rajawali Rimba Perkasa
IDYes
TinPT Refined Bangka TinIDYes
Tin
PT Sariwiguna Binasentosa
IDYes
TinPT Timah Tbk KundurIDYes
TinPT Timah Tbk MentokIDYes
Tin
PT Tinindo Inter Nusa
IDYes
Tin
Thaisarco
TH
Yes
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
CN
Yes
Tin
Tin Technology & Refining
US
Yes
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CNYes
Tungsten
A.L.M.T. TUNGSTEN Corp.
JP
Yes
Tungsten
China Molybdenum Tungsten Co., Ltd.
CN
Yes
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CN
Yes
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CNYes
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CNYes
Tungsten
Global Tungsten & Powders LLC
US
Yes
Tungsten
H.C. Starck Tungsten GmbH
DE
Yes
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CN
Yes
Tungsten
Hunan Jintai New Material Co., Ltd.
CN
No
Tungsten
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
CN
Yes
Tungsten
Japan New Metals Co., Ltd.
JP
Yes
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CN
Yes
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CN
Yes
Tungsten
Kennametal Fallon
US
Yes
Tungsten
Kennametal Huntsville
US
Yes
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CN
Yes
Tungsten
Masan High-Tech Materials
VN
Yes
Tungsten
Niagara Refining LLC
US
Yes
Tungsten
TANIOBIS Smelting GmbH & Co. KG
DE
Yes
Tungsten
Wolfram Bergbau und Hutten AG
AT
Yes
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CN
Yes
Tungsten
Xiamen Tungsten Co., Ltd.
CN
Yes


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Attachment B
Origin of Subject Minerals

The following table identifies the origin of the Subject Minerals as reported by our suppliers.
AngolaGuyanaPeru
ArgentinaHong KongPhilippines
ArmeniaHungaryPoland
AustraliaIndiaPortugal
AustriaIndonesiaRussian Federation
Belarus
IrelandRwanda
BelgiumIsrael
Saudi Arabia
Bermuda
ItalySierra Leone
BoliviaIvory CoastSingapore
BrazilJapanSlovakia
BurundiJerseySouth Africa
CambodiaKazakhstanSouth Sudan
CanadaKenyaSpain
Central African RepublicKorea, Republic ofSuriname
ChileKyrgyzstanSweden
China
Lao People’s Democratic Republic
Switzerland
ColombiaLuxembourgTaiwan
Congo (Brazzaville)MadagascarTajikistan
Cote d’lvoire
Malaysia
Tanzania
Czechia
Mali
Thailand
DjiboutiMexicoTurkey
Democratic Republic of the
 Congo (Kinshasa)
MongoliaUganda
EcuadorMoroccoUnited Kingdom
EgyptMozambiqueUnited States
EstoniaMyanmarUzbekistan
EthiopiaNamibiaViet Nam
FranceNetherlandsZambia
GermanyNigerZimbabwe
Ghana
Nigeria
Guinea
Papua New Guinea


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