SD

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

Helen of Troy Limited

(Exact name of the registrant as specified in its charter)

Bermuda	001-14669
(State or other jurisdiction of	(Commission
incorporation)	File Number)

Clarendon House

2 Church Street

Hamilton, Bermuda

(Address of principal executive offices)

Tessa Judge	(915) 225-8000
(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed:

ý Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022.

☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended _________.

Section 1 — Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

Helen of Troy Limited (“Helen of Troy” or “Company”) has concluded in good faith that during 2022,

•Helen of Troy contracted to have manufactured products for which “conflict minerals” (as defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act) may be necessary to the functionality or production.

•Based on a “reasonable country of origin inquiry” and subsequent due diligence, Helen of Troy is unable to determine whether or not various components/materials, which contribute to products sold by its business segments, are Democratic Republic of Congo (“DRC”) conflict free.

In accord with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), Helen of Troy has filed this Specialized Disclosure Form and the associated Conflict Minerals Report, and both reports are posted to a publicly available Internet site at www.helenoftroy.com.

Item 1.02 Exhibit

The Conflict Minerals Report for the calendar year ended December 31, 2022 is filed as Exhibit 1.01.

Section 2 — Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

Section 3 — Exhibits

Item 3.01 Exhibits

The following exhibit is filed as part of this Form SD:

Exhibit Number	Description
Exhibit 1.01	Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

SIGNATURES

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

Helen of Troy Limited
/s/ Brian L. Grass	May 25, 2023
Brian L. Grass
Chief Financial Officer, Principal Financial Officer and Principal Accounting Officer

EX-1.01

1 EXHIBIT 1.01 Conflict Minerals Report of Helen of Troy Limited In accord with Rule 13p-1 under the Securities Exchange Act of 1934 This is the Conflict Minerals Report of Helen of Troy Limited (“Helen of Troy”, the “Company”) for calendar year 2022 (excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accord with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”). 1. Introduction Helen of Troy is a leading global consumer products company offering creative solutions for our customers through a diversified portfolio of well-recognized and widely trusted brands. The Company has built leading market positions through new product innovation, product quality and competitive pricing. Helen of Troy was incorporated as Helen of Troy Corporation in Texas in 1968 and reorganized as Helen of Troy Limited in Bermuda in 1994. During the fourth quarter of fiscal 2023, we made changes to the structure of our organization in connection with our global restructuring plan (as further described below) that resulted in our previous Health & Wellness and Beauty operating segments being combined into a single reportable segment which is referred to herein as “Beauty & Wellness. Helen of Troy has two business segments: Home & Outdoor and Beauty & Wellness. The Home & Outdoor segment provides a broad range of innovative consumer products for home activities such as food preparation, cooking, cleaning, and organization; as well as products for outdoor and on the go activities such as hydration, food storage, backpacks, and travel gear. This segment sells primarily to retailers as well as through our direct-to-consumer channel. The Beauty & Wellness segment provides beauty and wellness products including mass and prestige market beauty appliances, prestige market liquid- based hair and personal care products, and wellness devices including thermometers, water and air filtration systems, humidifiers, and fans. Sales for the segment are primarily to retailers, distributors, beauty supply wholesalers and through our direct-to-consumer channel. Helen of Troy purchases its products from unaffiliated manufacturers, most of which are located in China, Mexico, Vietnam and the United States. Helen of Troy contracts to have products manufactured that may contain gold, tantalum, tin and tungsten (“3TG”). As these materials may be necessary to Helen of Troy’s products, the Company has embarked on a process to trace the origin of these metals to determine whether its sourcing practices support conflict or human rights abuses in the

2 Democratic Republic of Congo (“DRC”) and the surrounding area (the “Covered Countries”). The intent of this Conflict Minerals Report (“CMR”) is to describe this due diligence process. 2. Product Description Helen of Troy contracts to have products manufactured that may contain 3TG, such as home, outdoor, wellness, and beauty consumer products. Helen of Troy purchases finished product and is therefore several tiers removed from the mining operations. The Company does not purchase any materials directly from smelters or refiners, so Helen of Troy must rely on its suppliers to provide reliable and accurate information about 3TG. Helen of Troy’s suppliers were requested to use the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (“CMRT”) to identify gold, tantalum, tin and tungsten smelters or refiners (“SORs”) and associated countries of origin. Verified SORs were matched against available lists of processors that have been certified by internationally- recognized industry validation schemes, such as the Responsible Minerals Assurance Process (RMAP), the London Bullion Market Association Good Delivery Program (“LBMA”), and the Responsible Jewelry Council Chain-of-Custody Certification (“RJC”). Conflict free certification information is current as of May 5, 2023. 3. Reasonable Country of Origin Inquiry Description Helen of Troy obtained the aforementioned product information by implementing a Reasonable Country of Origin Inquiry (“RCOI”). Helen of Troy assembled an internal team, led by its Vice President, Global ESG (Environmental, Social and Governance), comprised of representatives from Helen of Troy’s finance, legal and supply chain departments. Helen of Troy engaged Source Intelligence (“SI”), a third-party information management service provider, to gather information from suppliers and establish a system of controls and transparency over its supply chain. This is the ninth consecutive year the Company worked with SI. Helen of Troy’s Tier 1 suppliers were engaged by SI to collect information regarding the presence and sourcing of 3TG used in the products supplied to them. Information was collected and stored using an online platform provided by SI. Supplier Engagement As in previous years, the RCOI began with an introduction email from Helen of Troy to suppliers describing its conflict minerals reporting requirements. Following that introduction email, a subsequent email was sent to suppliers containing a registration and survey request link to the online data collection platform. In an effort to increase awareness of the Company’s Conflict Minerals Compliance Program (CMCP), supporting regulation, and frequently asked questions (FAQs) concerning 3TG mineral tracing, Helen of Troy’s suppliers were given access to an online Supplier Resource

3 Center. The Supplier Resource Center provided educational information to facilitate a deeper understanding of conflict minerals and to inform suppliers as to why information was being requested. There were also opportunities to participate in webinars providing information on the Conflict Minerals Rule. Subsequent engagement followed these steps: • Following the initial introductions to the program and information request, up to three reminder emails were sent to each non-responsive supplier requesting survey completion. • Suppliers who remained non-responsive were contacted by email and offered assistance. This assistance included, but was not limited to, further information about the Conflict Minerals Compliance Program, an explanation of why the information was being collected, a review of how the information would be used, and clarification regarding how the information could be provided. • If, after these efforts, a given supplier still did not register with the system or provide the information requested, an escalation process was initiated. The escalation process consisted of direct outreach by Helen of Troy. Specifically, Helen of Troy contacted these suppliers by email to request their participation in the program. SI followed up with an email in a timely manner. Information Requested Suppliers were asked to provide information regarding the sourcing of their materials with the ultimate goal of identifying the 3TG SORs and associated mine countries of origin. Suppliers who had already performed a RCOI through the use of the CMRT were asked to upload this document into the online data collection platform or to provide this information in the online survey version. Where a supplier was unable to provide a CMRT, SI requested information on its suppliers of products or components which may require 3TG for their production or functionality. These Tier 2 suppliers, and subsequent tiers of suppliers as needed, were then engaged following the contact procedures explained above. When contact information was provided, Tier 2 and beyond suppliers were contacted via email in order to build a chain-of-custody back to the 3TG SOR. Every effort was made to address and meet the concerns of suppliers regarding their need to maintain the confidentiality of their data. In order to address this concern, SI executed non-disclosure agreements with Helen of Troy suppliers when requested. Helen of Troy chose to give their suppliers the ability to share information at a level with which they were most comfortable, i.e. company, product or user-defined, but the declaration scope had to be specified. Suppliers were requested to provide an electronic signature before submitting their data to Helen of Troy to verify that all answers

4 submitted were accurate to the best of the supplier’s knowledge, but the suppliers were not required to provide an electronic signature to submit their data. Quality Assurance Supplier responses were evaluated for plausibility, consistency, and gaps. If any of the following “quality control” (QC) flags were raised, suppliers were automatically contacted by the SI platform on a bi-weekly basis up to 3 contacts. • One or more smelter or refiners (SORs) were listed for an unused metal; • SOR information was not provided for a used metal, or SOR information provided was not a verified metal processor; • Supplier answered yes to sourcing from the Democratic Republic of the Congo or adjoining countries (“DRC”), but none of the SORs listed are known to source from the region; • Supplier indicated that they have not received conflict minerals data for each metal from all relevant suppliers; • Supplier indicated they have not identified all of the SORs used for the products included in the declaration scope; • Supplier indicated they have not provided all applicable SOR information received; and • Supplier indicated 100% of the 3TG for products covered by the declaration originates from scrap/recycled sources, but one or more SORs listed are not known to be exclusive recyclers. 4. RCOI Results Helen of Troy’s RCOI process revealed the following: • A total of 127 Tier 1 suppliers were identified by Helen of Troy as potentially in-scope for conflict mineral reporting purposes and all were contacted as part of the RCOI process. The survey response rate among these suppliers was 98.4%. • Out of these responding suppliers, 24% indicated conflict minerals were necessary to the functionality or production of the products they supply to Helen of Troy. • The responding suppliers using conflict minerals provided names of 235 verified SORs. • Of the 235 verified SORs, 90.2% are currently certified, of those that are not yet certified, 0.4% are actively moving through the certification process. Around 80% of verified SORs had no indication of sourcing from the DRC/Covered Countries. Of those SORs that show indication of sourcing from the DRC/Covered Countries, all but 3 are currently certified or actively moving through the certification process. Related to the 3 SORs, we required the relevant suppliers to cease any more purchases from these SORs for our products.

5 The following table lists the verified SORs provided by Helen of Troy’s suppliers, along with the certification status of each SOR as of May 5, 2023. Number Metal Official Smelter Name Conflict-Free Certifications 1 Gold 8853 S.p.A. NA 2 Gold Advanced Chemical Company RMAP 3 Gold Aida Chemical Industries Co., Ltd. RMAP 4 Gold Al Etihad Gold Refinery DMCC RMAP 5 Gold Allgemeine Gold-und Silberscheideanstalt A.G. LBMA, RJC, RMAP 6 Gold Almalyk Mining and Metallurgical Complex (AMMC) LBMA, RMAP 7 Gold AngloGold Ashanti Corrego do Sitio Mineracao LBMA, RMAP 8 Gold Argor-Heraeus S.A. LBMA, RMAP 9 Gold Asahi Pretec Corp. LBMA, RMAP 10 Gold Asahi Refining Canada Ltd. LBMA, RMAP 11 Gold Asahi Refining USA Inc. LBMA, RMAP 12 Gold Asaka Riken Co., Ltd. RMAP 13 Gold Aurubis AG LBMA, RMAP 14 Gold Bangalore Refinery RMAP 15 Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) LBMA, RMAP 16 Gold Boliden AB LBMA, RMAP 17 Gold C. Hafner GmbH + Co. KG LBMA, RJC, RMAP 18 Gold CCR Refinery - Glencore Canada Corporation LBMA, RMAP 19 Gold Cendres + Metaux S.A. NA 20 Gold Chimet S.p.A. LBMA, RMAP 21 Gold Chugai Mining RMAP 22 Gold Dowa RMAP 23 Gold DSC (Do Sung Corporation) RMAP 24 Gold Eco-System Recycling Co., Ltd. East Plant RMAP 25 Gold Eco-System Recycling Co., Ltd. North Plant RMAP 26 Gold Eco-System Recycling Co., Ltd. West Plant RMAP 27 Gold Emirates Gold DMCC RMAP 28 Gold Geib Refining Corporation RMAP 29 Gold Gold Refinery of Zijin Mining Group Co., Ltd. LBMA, RMAP 30 Gold Guangdong Jinding Gold Limited NA 31 Gold Heimerle + Meule GmbH LBMA, RMAP 32 Gold Heraeus Metals Hong Kong Ltd. LBMA, RJC, RMAP 33 Gold Heraeus Precious Metals GmbH & Co. KG RMAP 34 Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. LBMA, RMAP 35 Gold Ishifuku Metal Industry Co., Ltd. LBMA, RMAP 36 Gold Istanbul Gold Refinery LBMA, RMAP 37 Gold Italpreziosi RJC, RMAP 38 Gold Japan Mint LBMA, RMAP 39 Gold Jiangxi Copper Co., Ltd. LBMA, RMAP

6 40 Gold JSC Uralelectromed NA 41 Gold JX Nippon Mining & Metals Co., Ltd. LBMA, RMAP 42 Gold Kazzinc LBMA, RMAP 43 Gold Kennecott Utah Copper LLC LBMA, RMAP 44 Gold KGHM Polska Miedz Spolka Akcyjna RMAP 45 Gold Kojima Chemicals Co., Ltd. RMAP 46 Gold Korea Zinc Co., Ltd. RMAP 47 Gold L'Orfebre S.A. RMAP 48 Gold LS-NIKKO Copper Inc. LBMA, RMAP 49 Gold LT Metal Ltd. RMAP 50 Gold Marsam Metals NA 51 Gold Materion RMAP 52 Gold Matsuda Sangyo Co., Ltd. LBMA, RMAP 53 Gold Metal Concentrators SA (Pty) Ltd. RMAP 54 Gold Metalor Technologies (Hong Kong) Ltd. LBMA, RJC, RMAP 55 Gold Metalor Technologies (Singapore) Pte., Ltd. LBMA, RJC, RMAP 56 Gold Metalor Technologies (Suzhou) Ltd. RJC, RMAP 57 Gold Metalor Technologies S.A. LBMA, RJC, RMAP 58 Gold Metalor USA Refining Corporation LBMA, RJC, RMAP 59 Gold Metalurgica Met-Mex Penoles S.A. De C.V. LBMA, RMAP 60 Gold Mitsubishi Materials Corporation LBMA, RMAP 61 Gold Mitsui Mining and Smelting Co., Ltd. LBMA, RMAP 62 Gold MMTC-PAMP India Pvt., Ltd. LBMA, RMAP 63 Gold Moscow Special Alloys Processing Plant NA 64 Gold Nadir Metal Rafineri San. Ve Tic. A.S. LBMA, RMAP 65 Gold Navoi Mining and Metallurgical Combinat RMAP 66 Gold NH Recytech Company RMAP 67 Gold Nihon Material Co., Ltd. LBMA, RMAP 68 Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH RJC, RMAP 69 Gold Ohura Precious Metal Industry Co., Ltd. RMAP 70 Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) NA 71 Gold OJSC Novosibirsk Refinery NA 72 Gold PAMP S.A. LBMA, RMAP 73 Gold Planta Recuperadora de Metales SpA RMAP 74 Gold PT Aneka Tambang (Persero) Tbk LBMA, RMAP 75 Gold PX Precinox S.A. LBMA, RMAP 76 Gold Rand Refinery (Pty) Ltd. LBMA, RMAP 77 Gold REMONDIS PMR B.V. RMAP 78 Gold Royal Canadian Mint LBMA, RMAP 79 Gold SAAMP RJC, RMAP 80 Gold Safimet S.p.A NA 81 Gold SAFINA A.S. RMAP 82 Gold Samduck Precious Metals NA 83 Gold SEMPSA Joyeria Plateria S.A. LBMA, RMAP

7 84 Gold Shandong Gold Smelting Co., Ltd. LBMA, RMAP 85 Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. LBMA, RMAP 86 Gold Sichuan Tianze Precious Metals Co., Ltd. LBMA, RMAP 87 Gold Singway Technology Co., Ltd. NA 88 Gold SOE Shyolkovsky Factory of Secondary Precious Metals NA 89 Gold Solar Applied Materials Technology Corp. LBMA, RMAP 90 Gold Sumitomo Metal Mining Co., Ltd. LBMA, RMAP 91 Gold SungEel HiMetal Co., Ltd. RMAP 92 Gold T.C.A S.p.A LBMA, RMAP 93 Gold Tanaka Kikinzoku Kogyo K.K. LBMA, RMAP 94 Gold Tokuriki Honten Co., Ltd. LBMA, RMAP 95 Gold TOO Tau-Ken-Altyn RMAP 96 Gold Torecom RMAP 97 Gold Umicore Precious Metals Thailand NA 98 Gold Umicore S.A. Business Unit Precious Metals Refining LBMA, RMAP 99 Gold United Precious Metal Refining, Inc. RMAP 100 Gold Valcambi S.A. LBMA, RJC, RMAP 101 Gold Western Australian Mint (T/a The Perth Mint) LBMA, RMAP 102 Gold WIELAND Edelmetalle GmbH RMAP 103 Gold Yamakin Co., Ltd. RMAP 104 Gold Yokohama Metal Co., Ltd. RMAP 105 Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation LBMA, RMAP 106 Tantalum AMG Brasil RMAP 107 Tantalum Changsha South Tantalum Niobium Co., Ltd. RMAP 108 Tantalum D Block Metals, LLC RMAP 109 Tantalum F&X Electro-Materials Ltd. RMAP 110 Tantalum FIR Metals & Resource Ltd. RMAP 111 Tantalum Global Advanced Metals Aizu RMAP 112 Tantalum Global Advanced Metals Boyertown RMAP 113 Tantalum H.C. Starck Inc. RMAP 114 Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. RMAP 115 Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. RMAP 116 Tantalum Jiangxi Tuohong New Raw Material RMAP 117 Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. RMAP 118 Tantalum Jiujiang Tanbre Co., Ltd. RMAP 119 Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. RMAP 120 Tantalum KEMET de Mexico RMAP 121 Tantalum Metallurgical Products India Pvt., Ltd. RMAP 122 Tantalum Mineracao Taboca S.A. RMAP 123 Tantalum Mitsui Mining and Smelting Co., Ltd. RMAP 124 Tantalum Ningxia Orient Tantalum Industry Co., Ltd. RMAP 125 Tantalum NPM Silmet AS RMAP 126 Tantalum QuantumClean RMAP 127 Tantalum Resind Industria e Comercio Ltda. RMAP 128 Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. RMAP

8 129 Tantalum Taki Chemical Co., Ltd. RMAP 130 Tantalum TANIOBIS Co., Ltd. RMAP 131 Tantalum TANIOBIS GmbH RMAP 132 Tantalum TANIOBIS Japan Co., Ltd. RMAP 133 Tantalum TANIOBIS Smelting GmbH & Co. KG RMAP 134 Tantalum Telex Metals RMAP 135 Tantalum Ulba Metallurgical Plant JSC RMAP 136 Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED RMAP 137 Tantalum XinXing Haorong Electronic Material Co., Ltd. RMAP 138 Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. RMAP 139 Tin Alpha RMAP 140 Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. RMAP 141 Tin Chifeng Dajingzi Tin Industry Co., Ltd. RMAP 142 Tin China Tin Group Co., Ltd. RMAP 143 Tin CRM Synergies RMAP 144 Tin CV Venus Inti Perkasa RMAP 145 Tin Dowa RMAP 146 Tin EM Vinto RMAP 147 Tin Estanho de Rondonia S.A. RMAP 148 Tin Fabrica Auricchio Industria e Comercio Ltda. RMAP 149 Tin Fenix Metals RMAP 150 Tin Gejiu Kai Meng Industry and Trade LLC NA 151 Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. RMAP 152 Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. NA 153 Tin Gejiu Zili Mining And Metallurgy Co., Ltd. NA 154 Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. RMAP 155 Tin Jiangxi New Nanshan Technology Ltd. RMAP 156 Tin Luna Smelter, Ltd. RMAP 157 Tin Magnu's Minerais Metais e Ligas Ltda. RMAP 158 Tin Malaysia Smelting Corporation (MSC) RMAP 159 Tin Melt Metais e Ligas S.A. NA 160 Tin Metallic Resources, Inc. RMAP 161 Tin Metallo Belgium N.V. RMAP 162 Tin Metallo Spain S.L.U. RMAP 163 Tin Mineracao Taboca S.A. RMAP 164 Tin Minsur RMAP 165 Tin Mitsubishi Materials Corporation RMAP 166 Tin O.M. Manufacturing (Thailand) Co., Ltd. RMAP 167 Tin O.M. Manufacturing Philippines, Inc. RMAP 168 Tin Operaciones Metalurgicas S.A. RMAP 169 Tin PT Aries Kencana Sejahtera RMAP 170 Tin PT Artha Cipta Langgeng RMAP 171 Tin PT ATD Makmur Mandiri Jaya RMAP 172 Tin PT Babel Inti Perkasa RMAP 173 Tin PT Babel Surya Alam Lestari RMAP

9 174 Tin PT Bangka Serumpun RMAP 175 Tin PT Bukit Timah RMAP 176 Tin PT Cipta Persada Mulia RMAP 177 Tin PT Menara Cipta Mulia RMAP 178 Tin PT Mitra Stania Prima RMAP 179 Tin PT Mitra Sukses Globalindo RMAP 180 Tin PT Premium Tin Indonesia RMAP 181 Tin PT Prima Timah Utama RMAP 182 Tin PT Putera Sarana Shakti (PT PSS) RMAP 183 Tin PT Rajawali Rimba Perkasa RMAP 184 Tin PT Refined Bangka Tin RMAP 185 Tin PT Sariwiguna Binasentosa RMAP 186 Tin PT Stanindo Inti Perkasa RMAP 187 Tin PT Sukses Inti Makmur RMAP 188 Tin PT Timah Nusantara RMAP - Active 189 Tin PT Timah Tbk Kundur RMAP 190 Tin PT Timah Tbk Mentok RMAP 191 Tin PT Tinindo Inter Nusa NA 192 Tin Resind Industria e Comercio Ltda. RMAP 193 Tin Rui Da Hung RMAP 194 Tin Thaisarco RMAP 195 Tin Tin Technology & Refining RMAP 196 Tin White Solder Metalurgia e Mineracao Ltda. RMAP 197 Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. RMAP 198 Tin Yunnan Tin Company Limited RMAP 199 Tungsten A.L.M.T. TUNGSTEN Corp. RMAP 200 Tungsten ACL Metais Eireli NA 201 Tungsten Asia Tungsten Products Vietnam Ltd. RMAP 202 Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. RMAP 203 Tungsten China Molybdenum Co., Ltd. RMAP 204 Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. RMAP 205 Tungsten Cronimet Brasil Ltda RMAP 206 Tungsten Fujian Ganmin RareMetal Co., Ltd. RMAP 207 Tungsten Ganzhou Haichuang Tungsten Co., Ltd. RMAP 208 Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. RMAP 209 Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. RMAP 210 Tungsten Ganzhou Seadragon W & Mo Co., Ltd. RMAP 211 Tungsten Global Tungsten & Powders Corp. RMAP 212 Tungsten Guangdong Xianglu Tungsten Co., Ltd. RMAP 213 Tungsten H.C. Starck Tungsten GmbH RMAP 214 Tungsten Hunan Chenzhou Mining Co., Ltd. RMAP 215 Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. RMAP 216 Tungsten Hydrometallurg, JSC NA 217 Tungsten Japan New Metals Co., Ltd. RMAP 218 Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. RMAP

10 219 Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. RMAP 220 Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. RMAP 221 Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. RMAP 222 Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. RMAP 223 Tungsten Kennametal Fallon RMAP 224 Tungsten Kennametal Huntsville RMAP 225 Tungsten Lianyou Metals Co., Ltd. RMAP 226 Tungsten Malipo Haiyu Tungsten Co., Ltd. RMAP 227 Tungsten Masan High-Tech Materials RMAP 228 Tungsten Moliren Ltd. NA 229 Tungsten Niagara Refining LLC RMAP 230 Tungsten Philippine Chuangxin Industrial Co., Inc. RMAP 231 Tungsten TANIOBIS Smelting GmbH & Co. KG RMAP 232 Tungsten Unecha Refractory Metals Plant NA 233 Tungsten Wolfram Bergbau und Hutten AG RMAP 234 Tungsten Xiamen Tungsten (H.C.) Co., Ltd. RMAP 235 Tungsten Xiamen Tungsten Co., Ltd. RMAP Certification Status: 1. Responsible Minerals Assurance Process (RMAP) • RMAP: The smelter has an active certification or is in the process of renewing their certification. • RMAP -Active: The smelter is actively moving through the certification process. 2. Responsible Gold Certificate: London Bullion Market Association (LBMA) • LBMA: The smelter has obtained a Responsible Gold Certification. 3. Chain of Custody Certificate: Responsible Jewelry Council (RJC) • RJC: The smelter has obtained a Chain-of-Custody Certification. *NA refers to no applicable standard identified Countries of origin for these SORs are believed to include:

11 Country of Origin Angola Guyana Peru Argentina Hong Kong Philippines Armenia Hungary Poland Australia India Portugal Austria Indonesia Russian Federation 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 Sudan Canada Kenya Spain Central African Republic Korea, Republic of Suriname Chile Kyrgyzstan Sweden China Laos Switzerland Colombia Luxembourg Taiwan Congo (Brazzaville) Madagascar Tajikistan Czech Republic Malaysia Tanzania Djibouti Mali Thailand DRC- Congo (Kinshasa) Mexico Turkey Ecuador Mongolia Uganda Egypt Morocco United Arab Emirates Estonia Mozambique United Kingdom Ethiopia Myanmar United States Finland Namibia Uzbekistan France Netherlands Viet Nam Germany Niger Zambia Ghana Nigeria Zimbabwe Guinea Papua New Guinea 5. Due Diligence Process Helen of Troy’s due diligence process was designed to conform to the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements1. It is important to note that the OECD Guidance was written for 1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplement on Tin, Tantalum and Tungsten and Supplement on Gold, 2013; http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.

12 both upstream2 and downstream3 companies in the supply chain. As Helen of Troy is a downstream company in the supply chain, due diligence practices were tailored accordingly. • Step 1- Establish strong company management systems Helen of Troy’s conflict minerals policy is publicly available at www.helenoftroy.com. The Company utilizes an internal team, led by the Vice President, Global ESG, comprised of representatives from the finance, legal and supply chain departments to communicate and manage compliance initiatives. Team members work with the suppliers on a continual basis to maintain an open dialog and transparency in the procurement process. Findings are reported to senior management, as well as to the internal audit department. The Company’s internal team efforts are supplemented with a third-party service provider’s extensive knowledge and experience, as well as training seminars on conflict minerals. • Step 2- Identify and assess risk in the supply chain The Company continues to refine its list of product categories and suppliers that may fall within the scope of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Expectations with regard to supplier performance, transparency and sourcing are clearly communicated through supplier training. Quality assessments with suppliers are being expanded to encompass compliance initiatives. Suppliers are being encouraged to implement conflict mineral policies with their vendors. • Step 3- Design and implement a strategy to respond to identified risks Helen of Troy continues to make improvements on risk management. As RCOI are conducted and additional information becomes available regarding components and materials being used in the Company’s products, potential risks can be tracked and mitigated. The online platform maintained by SI allows Helen of Troy to access and analyze supplier responses as well as SOR information. Any suppliers found to be sourcing from SORs that support conflict in the DRC region will be required to explore alternative sources. • Step 4- Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain As part of Helen of Troy’s due diligence, and in conjunction with SI, the Company relies upon the following internationally accepted audit standards to determine which SORs are considered DRC Conflict Free: RMAP, LBMA and RJC. If the SOR is not certified by these internationally-recognized schemes, attempts are made to 2 Upstream companies refer to those between the mine and SORs. As such, the companies typically include miners, local traders, or exporters from the country of mineral origin, international concentrate traders and SORs. 3 Downstream companies refer to those entities between the SORs and the retailer. As such, the companies typically include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers and retailers.

13 contact the SOR to gain more information about their sourcing practices, including countries of origin and transfer, and whether there are any internal due diligence procedures in place or other processes to track the chain-of-custody on the source of the SOR’s mineral ores. Relevant information to review includes: whether the SOR has a documented, effective and communicated conflict free policy, an accounting system to support a mass balance of materials processed, and traceability documentation. Internet research is also performed to determine whether there are any outside sources of information regarding the SOR’s sourcing practices. • Step 5- Report on supply chain due diligence Helen of Troy reports annually on supply chain due diligence through the Form SD and this CMR filed with the Securities and Exchange Commission. The Form SD is publicly available at www.helenoftroy.com. 6. Steps to Improve Due Diligence Helen of Troy will endeavor to continuously improve upon its supply chain due diligence efforts via the following measures: • Continue to assess the presence of 3TG in its supply chain • Clearly communicate expectations with regard to supplier performance, transparency and sourcing • Maintain the response rate for the RCOI process • Continue to compare RCOI results to information collected via independent conflict free smelter validation programs 7. Product Determination Based on its RCOI process, Helen of Troy is unable to determine whether or not various components/materials, which contribute to products sold by its business segments, are DRC conflict free. 8. Independent Private Sector Audit Based on Helen of Troy’s declaration, a private sector audit is not required.