Exhibit 1.01
Conflict Minerals Report of Nordson Corporation
For The Year Ended December 31, 2021
I. Introduction
Nordson Corporation (“our,” “we” or “us”) engineers, manufactures and markets differentiated products and systems used for dispensing and processing adhesives, coatings, polymers, sealants and biomaterials, and for managing fluids, testing and inspecting for quality, treating surfaces and curing. These products are supported with extensive application expertise and direct global sales and service. We serve a wide variety of consumer non-durable, consumer durable and technology end markets including packaging, nonwovens, electronics, medical, appliances, energy, transportation, building and construction, and general product assembly and finishing.
Headquartered in Westlake, Ohio, our products are marketed through a network of direct operations in more than 35 countries. Our principal manufacturing facilities are located in the United States, the People’s Republic of China, Germany, Ireland, Israel, Mexico, the Netherlands, Thailand, and the United Kingdom.
Pursuant to the Securities and Exchange Commission’s conflict minerals rule adopted pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Rule”) and to the guidance provided by the Securities and Exchange Commission in its Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued on April 29, 2014, this Report was not subject to an independent private sector audit.
II. Reasonable Country of Origin Inquiry
Organization for Economic Co-operation and Development (OECD) Step 1 – Establish strong management systems
Internal Management
We have established a Conflict Minerals Reporting Oversight Committee. The team members include representatives from our Supply Chain Management, one of whom is our designated member of senior management, Legal, Product Compliance, Finance and Internal Audit departments. Periodic reports are made to the audit committee of the board of directors with respect to our due diligence process and compliance obligations.
We have been an active member of the Responsible Materials Initiative (RMI), formerly known as the Conflict-Free Sourcing Initiative (CFSI), since 2015. Through the RMI, we participate in the monthly RMI Plenary Call.
External Communications and Supply Chain Engagement
Our customers can access our conflict minerals statement on our public website,
https://www.nordson.com/en/our-company/ethics-and-compliance/conflict-minerals. Our conflict minerals statement informs customers of where we are in our Rule compliance efforts. Customer inquiries are handled on a case by case basis, utilizing the conflict minerals statement or customized responses using the conflict mineral reporting template (CMRT) developed by the RMI, as appropriate.
Because we are an industrial equipment supplier, many of our products are not incorporated into our customers’ products and, therefore, do not fall within the scope of the Rule as applied to our customers.
In addition to our conflict minerals statement, our Conflict Minerals Policy, adopted on May 6, 2014, is available on our website, https://www.nordson.com/en/our-company/ethics-and-compliance/conflict-minerals. In conjunction with the adoption of the Conflict Minerals Policy, we revised our Supplier Code of Ethics, which outlines the ethical standards with which we expect our suppliers to comply, to reflect our expectations that our suppliers procure materials from sources that do not directly or indirectly support non-state armed groups. The Conflict Minerals Policy and Supplier Code of Ethics have been distributed to our suppliers.
Reasonable Country of Origin Survey Process
We evaluated our products and determined that certain products manufactured during calendar year 2021 were manufactured with materials or components that contain, or likely contain, conflict minerals, i.e., tin, tantalum, tungsten and gold, that are necessary to the functionality or production of those products. The areas of conflict mineral usage within our supply chain were identified based on the results of previous surveys. Future surveys will focus efforts on these areas.
We identified in-scope suppliers that we believed provided materials or components containing conflict minerals. Based on commodity analysis, responses from prior years, and a focus on the highest spend suppliers, 29% of our total direct material spend was classified as in-scope. Given the size and complexity of our supply chain, we focused on our largest suppliers, ranked by the amount that we paid to each supplier.
We surveyed our suppliers utilizing the CMRT and our supplier portal, Nordson’s Supply Chain Central (SCC). The SCC software was used by the majority of product lines to automate surveying our suppliers, and to collect and analyze the survey data. Suppliers were provided training materials on the SCC website regarding conflict minerals and the CMRT.
As part of our grievance mechanism, we rely on RMI to provide us with information regarding grievances shared among group members, and we encourage our suppliers to send inquiries or other information concerning conflict minerals to productcompliance@nordson.com.
For the period covered by this Report, we prioritized collection of responses from in-scope suppliers representing approximately 29% of our total direct material spend. For this group of suppliers, we had about an 90% response rate. Based on the information obtained pursuant to the reasonable country of inquiry process described above, we do not have sufficient information to determine the country of origin of all of the conflict minerals in our supply chain. We continue to work to improve our reasonable country of origin process as described in more detail below.
OECD Step 2 – Identify and assess risk in the supply chain
An escalation process was initiated with those surveyed suppliers who continued to be nonresponsive after the above contacts were made, or whose initial (or subsequent) response was not complete or otherwise warranted clarification or confirmation. We evaluated responses from the surveyed suppliers for plausibility, consistency, and gaps both in terms of which materials or components were stated to contain or not contain conflict minerals and the origin of such conflict minerals. We will be engaging certain surveyed suppliers, holding discussions and reviewing the results of their internal due diligence efforts, to ensure that our inquiries regarding conflict minerals were understood and complied with.
III. Due Diligence Framework
Our due diligence process has been designed to conform, in all material respects relevant to the disclosure requirements under the Rule, with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
IV. Due Diligence Undertaken
OECD Step 3 – Design and implement a strategy to respond to identified risks
We supported audits of conflict mineral smelters and refiners conducted by third parties through our participation in the RMI. Suppliers were evaluated based on their smelter and refiner information obtained from CMRT declarations. If supplier information indicated that they used conflict minerals from the Democratic Republic of the Congo, including Angola, Burundi, Central African Republic, the Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (collectively, the “Covered Countries”), then we used the flagship program of the RMI, the Responsible Minerals Assurance Process (RMAP) and general public information to determine a smelter or refiner’s conflict minerals program status.
If, through our smelters lists, we discover that certain of our products contain conflict minerals that finance or benefit armed groups in the Covered Countries, or we cannot definitively deem a product to be free of conflict minerals that finance or benefit armed groups in the Covered Countries, we will analyze the adverse impact of this determination pursuant to the standards set forth in our Conflict Minerals Policy and Supplier Code of Ethics.
Findings regarding the compiled supply chain information through the processes described above will be reported to our executive officer committee. Identified areas of risk in our supply chain will be subject to a risk management plan developed pursuant to our Supplier Code of Ethics and Conflict Minerals Policy. Such risk management plan may include continuing trade throughout the course of measurable risk mitigation efforts, temporarily suspending trade while pursuing ongoing measurable risk mitigation, or disengaging with a supplier after failed attempts at mitigation or where we deem risk mitigation not feasible or unacceptable.
Once our risk management plan is implemented, we will track performance of our risk mitigation efforts and report the results back to our executive officer committee. For risks requiring additional mitigation, or after a change of circumstances, we will undertake additional fact and risk assessments.
V.Results of Due Diligence Undertaken
OECD Step 4 – Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
We will rely on third party assurances and certifications. For example, if a supplier provides the name of a smelter or source mine, we would compare that reply to the listing of smelters from the RMI thereby relying on the program’s processes.
OECD Step 5 – Report on supply chain due diligence
We have taken the information gathered through the above-described due diligence process and compiled this Report. In the future, we will take such information and compile it in a Report or in our specialized disclosure report as required by the Rule, whichever is applicable.
We have not identified any occurrence where our conflict mineral sourcing has directly or indirectly financed or benefited armed groups in the Covered Countries.
VI.Smelter and Refiner Disclosures
Schedule 1 lists the RMI verified smelters and refiners identified by collection of supplier conflict mineral reporting templates where sourcing is unknown. Please note these reported smelters and refiners have not been verified as contributing to components or parts that are in our products.
Schedule 2 lists the countries of the direct and indirect sourcing for conformant smelters reported by the RMI.
VII.Future Improvements
We intend to undertake the following steps during the next compliance period:
•Continue to collect conflict minerals information from all suppliers included in our conflict mineral survey process.
•Strive to improve the response rate from our suppliers.
•Continue to engage with relevant trade associations to define and improve best practices.
•Continue to support the RMI through our membership and participation in monthly meetings.
•Direct suppliers to the RMI organization for information.
Schedule 1
| | | | | | | | | | | |
| ID | Metal | Reference | Country |
| CID000103 | Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| CID000180 | Gold | Caridad | MEXICO |
| CID000197 | Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| CID000281 | Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| CID000309 | Tin | PT Aries Kencana Sejahtera | INDONESIA |
| CID000343 | Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| CID000493 | Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| CID000522 | Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
| CID000651 | Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| CID000671 | Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| CID000767 | Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| CID000773 | Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| CID000778 | Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| CID000927 | Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| CID000929 | Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| CID000942 | Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| CID000956 | Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| CID001029 | Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| CID001032 | Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| CID001056 | Gold | Lingbao Gold Co., Ltd. | CHINA |
| CID001058 | Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| CID001093 | Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| CID001204 | Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| CID001305 | Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION |
| CID001326 | Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| CID001362 | Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| CID001386 | Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| CID001421 | Tin | PT Belitung Industri Sejahtera | INDONESIA |
| CID001428 | Tin | PT Bukit Timah | INDONESIA |
| CID001457 | Tin | PT Panca Mega Persada | INDONESIA |
| CID001486 | Tin | PT Timah Nusantara | INDONESIA |
| CID001493 | Tin | PT Tommy Utama | INDONESIA |
| CID001546 | Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| CID001562 | Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| CID001619 | Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| CID001756 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| CID001810 | Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| CID001909 | Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| CID001947 | Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| CID002015 | Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| CID002180 | Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| CID002282 | Gold | Morris and Watson | NEW ZEALAND |
| CID002312 | Gold | Guangdong Jinding Gold Limited | CHINA |
| CID002313 | Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| CID002455 | Tin | CV Venus Inti Perkasa | INDONESIA |
| CID002478 | Tin | PT Tirus Putra Mandiri | INDONESIA |
| CID002515 | Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| | | | | | | | | | | |
| CID002525 | Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
| CID002527 | Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| CID002562 | Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| CID002563 | Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| CID002567 | Gold | Sudan Gold Refinery | SUDAN |
| CID002570 | Tin | CV Ayi Jaya | INDONESIA |
| CID002572 | Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| CID002573 | Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| CID002574 | Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| CID002584 | Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| CID002587 | Gold | Industrial Refining Company | BELGIUM |
| CID002588 | Gold | Shirpur Gold Refinery Ltd. | INDIA |
| CID002703 | Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| CID002708 | Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| CID002756 | Tin | Super Ligas | BRAZIL |
| CID002816 | Tin | PT Sukses Inti Makmur | INDONESIA |
| CID002850 | Gold | AU Traders and Refiners | SOUTH AFRICA |
| CID002852 | Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| CID002853 | Gold | Sai Refinery | INDIA |
| CID002857 | Gold | Modeltech Sdn Bhd | MALAYSIA |
| CID002858 | Tin | Modeltech Sdn Bhd | MALAYSIA |
| CID002865 | Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| CID002867 | Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| CID002872 | Gold | Pease & Curren | UNITED STATES OF AMERICA |
| CID002893 | Gold | JALAN & Company | INDIA |
| CID003153 | Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| CID003185 | Gold | African Gold Refinery | UGANDA |
| CID003186 | Gold | Gold Coast Refinery | GHANA |
| CID003208 | Tin | Pongpipat Company Limited | MYANMAR |
| CID003324 | Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
| CID003348 | Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| CID003356 | Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| CID003382 | Gold | CGR Metalloys Pvt Ltd. | INDIA |
| CID003383 | Gold | Sovereign Metals | INDIA |
| CID003397 | Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| CID003409 | Tin | Precious Minerals and Smelting Limited | INDIA |
| CID003410 | Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| CID003416 | Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| CID003421 | Gold | C.I Metales Procesados Industriales SAS | COLOMBIA |
| CID003427 | Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| CID003449 | Tin | PT Mitra Sukses Globalindo | INDONESIA |
| CID003461 | Gold | Augmont Enterprises Private Limited | INDIA |
| CID003463 | Gold | Kundan Care Products Ltd. | INDIA |
| CID003486 | Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| CID003487 | Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| CID003488 | Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| CID003489 | Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| CID003490 | Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| CID003497 | Gold | K.A. Rasmussen | NORWAY |
| | | | | | | | | | | |
| CID003500 | Gold | Alexy Metals | UNITED STATES OF AMERICA |
| CID003529 | Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA |
| CID003540 | Gold | Sellem Industries Ltd. | MAURITANIA |
| CID003548 | Gold | MD Overseas | INDIA |
| CID003553 | Tungsten | Artek LLC | RUSSIAN FEDERATION |
| CID003557 | Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| CID003612 | Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION |
| CID003614 | Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION |
| CID003615 | Gold | WEEEREFINING | FRANCE |
| CID003617 | Gold | Value Trading | BELGIUM |
Schedule 2
Andorra, Angola, Antigua and Barbuda, Argentina, Australia, Austria, Bahamas, Bangladesh, Barbados, Belarus, Belgium, Benin, Bolivia, Brazil, Bulgaria, Burundi, Canada, Cayman Islands, Chile, China, Colombia, Croatia, Cuba, Curacao, Cyprus, Czechia, Democratic Republic of the Congo , Denmark, Dominica, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Finland, France, Gabon, Germany, Ghana, Grenada, Greece, Guatemala, Guernsey, Guinea, Guyana, Honduras, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Laos, Latvia, Lebanon, Libya, Lithuania, Luxembourg, Madagascar, Malaysia, Malta, Mexico, Monaco, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Norway, Pakistan, Panama, Peru, Philippines, Poland, Portugal, Puerto Rico, Qatar, Romania, Russia, Russian Federation, Rwanda, Saint Kitts and Nevis, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Sint Maarten, Slovakia, Slovenia, South Africa, South Korea, Spain, St Vincent and Grenadines, Sudan, Swaziland, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Turks and Caicos, Uganda, Ukraine, United Arab Emirates, United Kingdom, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Virgin Islands, Yemen, Zimbabwe
