Exhibit 1.01

 

 

 

Conflict Minerals Report

 

Organon & Co. - For Year Ending December 31, 2024

 

Company Overview

 

This report has been prepared by the management of Organon & Co. (“Organon”). Organon is a global health care company that develops and delivers innovative health solutions through a portfolio of prescription therapies within women's health, biosimilars and established brands ("Organon Products"). Organon has a portfolio of more than 60 medicines and products across a range of therapeutic areas. Organon sells these products through various channels including drug wholesalers and retailers, hospitals, government agencies and managed health care providers such as health maintenance organizations, pharmacy benefit managers and other institutions. Organon operates six manufacturing facilities, which are in Belgium, Brazil, Indonesia, Mexico, the Netherlands and the United Kingdom ("UK").

 

Introduction

 

For the 2024 calendar year, Organon determined that columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin, and tungsten (“3TGs” or “conflict minerals”) were necessary to the functionality or production of products that were manufactured or contracted to be manufactured. Therefore, Organon conducted a reasonable country of origin inquiry in good faith to determine whether any of the 3TGs in its products originated from Conflict-Affected and High-Risk Areas (CAHRAs), such as the Democratic Republic of the Congo (DRC) or an adjoining country (collectively referred to as the “Covered Countries”) or are from recycled or scrap sources.

 

Based on the country of origin data, Organon believes its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), due diligence was performed on the source and chain of custody of the 3TGs in question to determine whether its products are “conflict free or responsibly sourced.” Organon designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework of the Organization for Economic Co-Operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum, and tungsten (Third Edition) (the “OECD Guidance”).

 

Organon is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, Organon has put into place a robust due diligence program to ensure its contributions to upholding human rights and responsible practices across the supply chain.

 

Conflict Minerals Program & Policy

 

Organon has adopted a conflict minerals policy (“Conflict Minerals Policy”) articulating the conflict minerals supply chain due diligence process and Organon’s commitments to reporting obligations regarding conflict minerals. Organon has actively engaged with its suppliers over the last year with respect to the use of conflict minerals.

 

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Description of Products

 

Only some Organon products fall in scope of the Rule, as they contain (or may contain) one or more of the 3TGs in our products that are necessary to their functionality or production. The following product line descriptions provide additional detail on products that contain, or may contain, necessary 3TGs:

 

4Actuators and Pumps used in Nasonex® — Respiratory product, used for the treatment of hay fever symptoms and perennial rhinitis. It is sold to international markets and contains Tin.

 

4Re-usable Injection Pen used in FOLLISTIM® AQ Cartridge (follitropin beta injection) – Fertility product, indicated for the induction of ovulation and pregnancy in anovulatory infertile women in whom the cause of infertility is functional and not due to primary ovarian failure. It is sold to the international markets and contains 3TG substances.

 

4Needle Microfine used in FOLLISTIM® AQ Cartridge (follitropin beta injection) – Fertility product, indicated for the induction of ovulation and pregnancy in anovulatory infertile women in whom the cause of infertility is functional and not due to primary ovarian failure. It is sold to the international markets and contains 3TG substances.

 

4Silicon Molded Components used in Jada® system 2.0 convenience kit — a medical device intended to provide control and treatment of abnormal postpartum uterine bleeding or hemorrhage.

 

Reasonable Country of Origin Inquiry

 

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Organon retained Assent Inc. (“Assent”), a third-party service provider, to assist Organon in reviewing the supply chain and identifying risks. Organon provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager. As used herein, “suppliers” means those suppliers of products or materials that Organon determined contain (or may contain) conflict minerals.

 

Organon utilized the Conflict Minerals Reporting Template (“CMRT”) Version 6.4 or higher to conduct a survey of all in-scope suppliers.

 

During the supplier survey, Organon contacted suppliers via the Assent Compliance Manager, a software-as-a-service (SaaS) platform provided by Assent 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 Assent Compliance Manager also provides functionality that is intended to meet the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this Conflict Minerals Report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform.

 

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Via the Assent Compliance Manager and Assent team, Organon requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included in Assent’s communications. Assent monitored and tracked all communications in the Assent Compliance Manager for future reporting and transparency. Organon directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to Assent.

 

Organon’s program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 suppliers. 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.

 

All submitted declaration forms are accepted so that data is retained, but they are classified by Assent as valid or invalid based on a set criteria of validation errors (see Appendix C for CMRT validation criteria). Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Organon tracks program gaps to account for future improvement opportunities.

 

As of May 5, 2025, there were 22 suppliers in scope of Organon’s conflict minerals program and 21 provided a completed CMRT. Organon’s total response rate for this reporting year was 95.5%, which is an improvement over the 72% response rate for the previous reporting year. These metrics are summarized in the table below to assess progress over time:

 

Year  Suppliers in Scope   % Responded 
RY 2024   22    95.5%

 

Through reasonable due diligence practices, Organon was able to take advantage of a broader set of country of origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Organon was able to determine at least some of the possible countries of origin of the conflict minerals contained in its products. Covered Countries are among the possible countries of origin. Therefore, Organon performed due diligence on the source and chain of custody of the conflict minerals in question.

 

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Due Diligence

 

Design of Due Diligence

 

Organon designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance and Organon continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.

 

Due diligence requires Organon’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete, inaccurate, and over-inclusive data as the process cannot be fully confirmed by Organon. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, risk gaps can be mitigated. This process aligns with industry standards and market expectations for downstream companies’ due diligence.

 

Due Diligence Performed

 

1) Establish Strong Company Management Systems

 

Internal Compliance Team

 

Organon has established a cross-functional Conflict Minerals Compliance Team led by Global Procurement & Supplier Management. The Conflict Minerals Compliance Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts.

 

Organon also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that Organon will undertake with suppliers and/or respective stakeholders in regard to conflict minerals sourcing.

 

Organon leverages Assent’s Managed Services to work with dedicated program specialists who support Organon’s conflict minerals program. Organon communicates regularly with the Assent team to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of reporting templates such as CMRT and conflict minerals reports, as well as the requirements of the conflict minerals rule adopted by the U.S. Securities and Exchange Commission.

 

Control Systems

 

Organon expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Organon are “conflict free or responsibly sourced.” This means that the products should not contain “3TGs” that directly or indirectly finance or benefit armed groups in any of the Covered Countries. Organon expects direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.

 

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Organon’s Business Partner Code of Conduct applies to all direct suppliers and outlines certain expected behaviors and practices. This code of conduct is based on industry and internationally-accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Business Partner Code of Conduct is provided to all direct suppliers. If a supplier does not meet Organon’s requirements, the relationship with this supplier may be evaluated. The Business Partner Code of Conduct will be reviewed annually to ensure it continues to align with industry best practices.

 

Conflict Minerals Policy

 

Organon’s Conflict Minerals Policy is available online, and can be found here: LINK.

 

Supplier Engagement

 

Organon has a strong relationship with its Tier 1 direct suppliers. As an extremely important part of the supply chain, Organon has leveraged processes and educational opportunities to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support, and other multilingual resources. Organon’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete a CMRT. Suppliers are provided guidance in their native language, if needed.

 

Organon engages with suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to Organon. With respect to the OECD requirement to strengthen engagement with suppliers, the Company has developed an internal procedure that includes supplier risk identification process that then leads to further steps of supplier engagement in the form of escalations, such as in-person meetings and/or corrective actions. Feedback from this engagement process has allowed Organon to oversee improvements in supplier responses and supplier compliance for this initiative.

 

Additionally, Organon’s Conflict Minerals Policy is included in supplier contracts, requiring new suppliers to read and accept the policy as a requirement of doing business with Organon. When entering or renewing supplier contracts, a clause is added that requires suppliers to provide information about the source of 3TGs and smelters and refiners in their supply chains.

 

Organon continues to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources. Also, Assent’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain risks associated with sourcing of conflict minerals.

 

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Organon believes that the combination of the Business Partner Code of Conduct, Conflict Minerals Policy, and direct engagement with in-scope suppliers for conflict minerals training and support constitute a strong supplier engagement program.

 

Grievance Mechanisms

 

Organon established multiple longstanding grievance mechanisms (also referred to as whistleblowing or speak-up tools) whereby employees and suppliers can report violations of Organon’s policies, including conflict minerals. Suppliers and others outside of Organon may report grievances, via a dedicated email address that is published in the Conflict Minerals Policy, the Business Partner Code of Conduct, and in other communications with suppliers. In addition, employees and suppliers may anonymously report suspected violations using Organon’s Speak Up Process. Any violations are reported to the Corporate Compliance Committee. If any concerns were to be reported, Organon would investigate appropriately.

 

Violations or grievances at the industry level can be reported to the Responsible Minerals Initiative (“RMI”) directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/ This website is not considered part of this Conflict Minerals Report and is not incorporated by reference herein.

 

Maintain Records

 

Organon has adopted a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. Organon manages its own record retention policy and stores all the information and findings from this process in a database that can be audited by internal or external parties.

 

2) Identifying & Assessing Risk in the Supply Chain

 

Supplier Risk Evaluation

 

Risks associated with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on a CMRT, which the Global Procurement Team identifies automatically based on established criteria. These risks are addressed by Assent staff and members of Organon’s internal Conflict Minerals Team, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”

 

Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Organon is unable to determine which specified smelters/refiners actually processed the 3TGs in the products supplied to Organon.

 

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Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a Organon’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter/refiner level via an analysis that takes into account multiple conflict minerals factors.

 

Smelter/Refiners Risk Evaluation

 

Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s smelter validation program compared listed facilities to the list of smelters/refiners consolidated by the RMI to ensure that the facilities listed met the recognized definition of a 3TG processing facility that was operational during the 2024 calendar year.

 

Assent determined whether the smelter/refiner had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Organon does not have a direct relationship with smelters/refiners, and does not perform direct audits of these entities within their pre-supply chain. Smelters/refiners that are conformant to RMAP audit standards are considered to have their sourcing validated as “responsibly sourced.” In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or where they are considered non-conformant by RMAP, further due diligence steps are followed by Assent to notify suppliers that reported these facilities. Smelters/refiners are actively monitored by Assent to proactively identify other risks pertaining to conflict minerals.

 

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter/refiner poses to the supply chain by identifying red flags. These factors include:

 

4Geographic proximity to Conflict-Affected and High-Risk Areas.

 

4Known mineral source country of origin.

 

4RMAP audit status.

 

4Credible evidence of unethical or conflict sourcing.

 

4Peer assessments conducted by credible third-party sources.

 

4Sanctions risks

 

3) Design & Implement A Strategy to Respond to Identified Risks

 

Together with Assent, Organon developed processes to respond to the risks identified in its supply chain. Organon has a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and Organon’s expectations.

 

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Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent, suppliers with submissions that included any smelters or refiners of concern were provided with feedback instructing suppliers to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to Organon. Additional escalation may have been necessary to address any continued sourcing from these smelters or refiners of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters or refiners of concern from the supply chain.

 

In addition, suppliers are guided to educational materials provided by Assent on mitigating the risks identified through the data collection process.

 

Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

 

Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, Organon will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Team and Organon’s Executive Leadership Team to ensure transparency within Organon.

 

4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

 

Organon does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, Organon relies on third-party audits of smelters/refiners (industry recognized audit/assessment programs). As an example, RMAP uses independent auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals processed by smelters/refiners that agree to participate in the program.

 

Assent directly engages smelters/refiners that are not currently enrolled in an industry recognized audit/assessment program to encourage their participation and for those smelters/refiners already conformant to the corresponding program’s standards, Assent thanks them for their efforts on behalf of its compliance partners. Organon is a signatory of these communications in accordance with the requirements of downstream companies detailed in the OECD Guidance.

 

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5) Report Annually on Supply Chain Due Diligence

 

Organon has published the Form SD for the year ended December 31, 2024. This Conflict Minerals Report is available on the Investor Relations section of Organon’s website at LINK. Information found on or accessed through this website is not considered part of this Conflict Minerals Report and is not incorporated by reference herein. Organon has also publicly filed a Form SD and this Conflict Minerals Report with the SEC.

 

Organon has also considered impacts from the EU Conflict Minerals Regulation when disclosing details with regards to due diligence efforts. Organon will continue to expand efforts both for transparency through the data collection process and risk evaluation.

 

Due Diligence Results

 

Facilities Used to Process the Necessary 3TG in Our Products

 

Supply chain outreach is required to identify the upstream sources of origin of 3TG necessary to the functionality or production of Organon’s products. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process with their own suppliers until the smelter and refiner sources are identified. The following is the result of the outreach conducted by Organon for the 2024 reporting year.

 

Supply Chain Outreach Metrics

 

Number of in-scope
suppliers
   Change in number of in-scope
suppliers from 2023
   Response rate 
 22    3    95.5%

 

Upstream Data Transparency

 

Appendix A includes all smelters/refiners that Organon’s responding suppliers listed in completed CMRTs that met the recognized definition of a 3TG processing facility and were operational during the 2024 calendar year. As is common when requests are sent upstream in the supply chain, those who purchase materials from smelters/refiners may not be able to discern exactly which of the company’s product lines contain the materials processed by those smelters/refiners. As a result, those providing the CMRT responses on a company level list all smelters/refiners they may purchase from within the reporting period. Therefore, Organon believes that the smelters/refiners listed in Appendix A are likely to include smelters and refiners that do not actually process the 3TGs contained in Organon’s products.

 

Suppliers that identified specific smelters/refiners of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections.

 

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Status  Number of smelters/refiners listed by
responding suppliers
 
RMAP Conformant   224 
RMAP Active   3 
Not Enrolled   89 
Non-Conformant   32 

 

Country of Origin

 

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country of origin data obtained via Assent’s supply chain database (or other Reasonable Country of Origin Inquiry data, in the scenario Organon used alternative data sources). As mentioned in the above section, it is understood that overreporting of smelters/refiners often occurs when company-level CMRTs are provided. Therefore, Organon believes that Appendix B is likely to include more countries than those that are actually sources of the 3TG in Organon’s products.

 

Mine or Location of Origin

 

Organon attempted to determine the mine or location of origin of the necessary 3TG contained in its products by requesting that its suppliers provide it with a completed supplier-level CMRT. Its suppliers’ responses and the information made available by the RMI did not provide sufficiently detailed information for Organon to determine the mine or location of origin of those 3TG.

 

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Steps Taken and to Be Taken to Mitigate Risk

 

Since the start of calendar year 2024, Organon has taken, or intends to take, the following steps to improve the due diligence conducted to further mitigate the risk that the necessary 3TGs in Organon’s products could finance or benefit armed groups in Conflict-Affected and High-Risk Areas:

 

4Continue to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:

 

4Using a comprehensive smelter and refiner library with detailed status and notes for each entity.

 

4Scanning for verifiable media sources on each smelter and refiner to flag risk issues.

 

4Comparing the list of smelters/refiners against government watch and denied parties lists.

 

4Engage with suppliers more closely, and provide more information and training resources regarding responsible sourcing of 3TGs.

 

4Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.

 

4Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts, as well as included in the terms and conditions of each purchase order issued.

 

Following the OECD Guidance process, increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter/refiner analysis.

 

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Appendix A: Smelter and Refiner List

 

Appendix A includes all smelters/refiners that Organon’s responding suppliers listed in completed CMRTs that met the recognized definition of a 3TG processing facility and were operational during the 2024 calendar year. Organon believes that the smelters/refiners listed in Appendix A are likely to include smelters and refiners that do not actually process the 3TGs contained in Organon’s products.

 

Metal Smelter Name Smelter Facility Location
Gold Advanced Chemical Company United States Of America
Gold Aida Chemical Industries Co., Ltd. Japan
Gold Agosi AG Germany
Gold Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan
Gold AngloGold Ashanti Corrego do Sitio Mineracao Brazil
Gold Argor-Heraeus S.A. Switzerland
Gold Asahi Pretec Corp. Japan
Gold Asaka Riken Co., Ltd. Japan
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey
Gold Aurubis AG Germany
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines
Gold Boliden Ronnskar Sweden
Gold C. Hafner GmbH + Co. KG Germany
Gold Caridad Mexico
Gold CCR Refinery - Glencore Canada Corporation Canada
Gold Cendres + Metaux S.A. Switzerland
Gold Yunnan Copper Industry Co., Ltd. China
Gold Chimet S.p.A. Italy
Gold Chugai Mining Japan
Gold Daye Non-Ferrous Metals Mining Ltd. China
Gold DSC (Do Sung Corporation) Korea, Republic Of
Gold Dowa Japan
Gold Eco-System Recycling Co., Ltd. East Plant Japan
Gold JSC Novosibirsk Refinery Russian Federation
Gold Refinery of Seemine Gold Co., Ltd. China
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. China
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. China
Gold LT Metal Ltd. Korea, Republic Of
Gold Heimerle + Meule GmbH Germany
Gold Heraeus Metals Hong Kong Ltd. China
Gold Heraeus Germany GmbH Co. KG Germany
Gold Hunan Chenzhou Mining Co., Ltd. China
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China
Gold HwaSeong CJ CO., LTD. Korea, Republic Of
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China
Gold Ishifuku Metal Industry Co., Ltd. Japan
Gold Istanbul Gold Refinery Turkey
Gold Japan Mint Japan

 

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Metal Smelter Name Smelter Facility Location
Gold Jiangxi Copper Co., Ltd. China
Gold Asahi Refining USA Inc. United States Of America
Gold Asahi Refining Canada Ltd. Canada
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation
Gold JSC Uralelectromed Russian Federation
Gold JX Nippon Mining & Metals Co., Ltd. Japan
Gold Kazakhmys Smelting LLC Kazakhstan
Gold Kazzinc Kazakhstan
Gold Kennecott Utah Copper LLC United States Of America
Gold Kojima Chemicals Co., Ltd. Japan
Gold Kyrgyzaltyn JSC Kyrgyzstan
Gold L'azurde Company For Jewelry Saudi Arabia
Gold Lingbao Gold Co., Ltd. China
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. China
Gold LS MnM Inc. Korea, Republic Of
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China
Gold Materion United States Of America
Gold Matsuda Sangyo Co., Ltd. Japan
Gold Metalor Technologies (Suzhou) Ltd. China
Gold Metalor Technologies (Hong Kong) Ltd. China
Gold Metalor Technologies (Singapore) Pte., Ltd. Singapore
Gold Metalor Technologies S.A. Switzerland
Gold Metalor USA Refining Corporation United States Of America
Gold Metalurgica Met-Mex Penoles S.A. De C.V. Mexico
Gold Mitsubishi Materials Corporation Japan
Gold Mitsui Mining and Smelting Co., Ltd. Japan
Gold Moscow Special Alloys Processing Plant Russian Federation
Gold Nadir Metal Rafineri San. Ve Tic. A.S. Turkey
Gold Navoi Mining and Metallurgical Combinat Uzbekistan
Gold Nihon Material Co., Ltd. Japan
Gold Ohura Precious Metal Industry Co., Ltd. Japan
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation
Gold MKS PAMP SA Switzerland
Gold Penglai Penggang Gold Industry Co., Ltd. China
Gold Prioksky Plant of Non-Ferrous Metals Russian Federation
Gold PT Aneka Tambang (Persero) Tbk Indonesia
Gold PX Precinox S.A. Switzerland
Gold Rand Refinery (Pty) Ltd. South Africa
Gold Royal Canadian Mint Canada
Gold Sabin Metal Corp. United States Of America
Gold Samduck Precious Metals Korea, Republic Of
Gold Samwon Metals Corp. Korea, Republic Of
Gold SEMPSA Joyeria Plateria S.A. Spain

 

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Metal Smelter Name Smelter Facility Location
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. China
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China
Gold Sichuan Tianze Precious Metals Co., Ltd. China
Gold SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation
Gold Solar Applied Materials Technology Corp. Taiwan, Province Of China
Gold Sumitomo Metal Mining Co., Ltd. Japan
Gold Super Dragon Technology Co., Ltd. Taiwan, Province Of China
Gold Tanaka Kikinzoku Kogyo K.K. Japan
Gold Great Wall Precious Metals Co., Ltd. of CBPM China
Gold Shandong Gold Smelting Co., Ltd. China
Gold Tokuriki Honten Co., Ltd. Japan
Gold Tongling Nonferrous Metals Group Co., Ltd. China
Gold Torecom Korea, Republic Of
Gold Umicore S.A. Business Unit Precious Metals Refining Belgium
Gold United Precious Metal Refining, Inc. United States Of America
Gold Valcambi S.A. Switzerland
Gold Western Australian Mint (T/a The Perth Mint) Australia
Gold Yamakin Co., Ltd. Japan
Gold Yokohama Metal Co., Ltd. Japan
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation China
Gold Gold Refinery of Zijin Mining Group Co., Ltd. China
Gold Morris and Watson New Zealand
Gold SAFINA A.S. Czechia
Gold Guangdong Jinding Gold Limited China
Gold Umicore Precious Metals Thailand Thailand
Gold MMTC-PAMP India Pvt., Ltd. India
Gold Fidelity Printers and Refiners Ltd. Zimbabwe
Gold Singway Technology Co., Ltd. Taiwan, Province Of China
Gold Shandong Humon Smelting Co., Ltd. China
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. China
Gold Al Etihad Gold Refinery DMCC United Arab Emirates
Gold Emirates Gold DMCC United Arab Emirates
Gold International Precious Metal Refiners United Arab Emirates
Gold Kaloti Precious Metals United Arab Emirates
Gold Sudan Gold Refinery Sudan
Gold T.C.A S.p.A Italy
Gold REMONDIS PMR B.V. Netherlands
Gold Fujairah Gold FZC United Arab Emirates
Gold Industrial Refining Company Belgium
Gold Shirpur Gold Refinery Ltd. India
Gold Korea Zinc Co., Ltd. Korea, Republic Of
Gold Marsam Metals Brazil
Gold TOO Tau-Ken-Altyn Kazakhstan
Gold Abington Reldan Metals, LLC United States Of America

 

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Metal Smelter Name Smelter Facility Location
Gold Shenzhen CuiLu Gold Co., Ltd. China
Gold Albino Mountinho Lda. Portugal
Gold SAAMP France
Gold L'Orfebre S.A. Andorra
Gold 8853 S.p.A. Italy
Gold Italpreziosi Italy
Gold WIELAND Edelmetalle GmbH Germany
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria
Gold AU Traders and Refiners South Africa
Gold GGC Gujrat Gold Centre Pvt. Ltd. India
Gold Sai Refinery India
Gold Modeltech Sdn Bhd Malaysia
Gold Bangalore Refinery India
Gold Kyshtym Copper-Electrolytic Plant ZAO Russian Federation
Gold Degussa Sonne / Mond Goldhandel GmbH Germany
Gold Pease & Curren United States Of America
Gold JALAN & Company India
Gold SungEel HiMetal Co., Ltd. Korea, Republic Of
Gold Planta Recuperadora de Metales SpA Chile
Gold ABC Refinery Pty Ltd. Australia
Gold Safimet S.p.A Italy
Gold State Research Institute Center for Physical Sciences and Technology Lithuania
Gold African Gold Refinery Uganda
Gold Gold Coast Refinery Ghana
Gold NH Recytech Company Korea, Republic Of
Gold QG Refining, LLC United States Of America
Gold Dijllah Gold Refinery FZC United Arab Emirates
Gold CGR Metalloys Pvt Ltd. India
Gold Sovereign Metals India
Gold Eco-System Recycling Co., Ltd. North Plant Japan
Gold Eco-System Recycling Co., Ltd. West Plant Japan
Gold Augmont Enterprises Private Limited India
Gold Kundan Care Products Ltd. India
Gold Emerald Jewel Industry India Limited (Unit 1) India
Gold Emerald Jewel Industry India Limited (Unit 2) India
Gold Emerald Jewel Industry India Limited (Unit 3) India
Gold Emerald Jewel Industry India Limited (Unit 4) India
Gold K.A. Rasmussen Norway
Gold Alexy Metals United States Of America
Gold MD Overseas India
Gold Metallix Refining Inc. United States Of America
Gold Metal Concentrators SA (Pty) Ltd. South Africa
Gold WEEEREFINING France
Gold Gold by Gold Colombia Colombia

 

Page 15 of 22May 2025

 

 

 

 

Metal Smelter Name Smelter Facility Location
Gold Dongwu Gold Group China
Gold Sam Precious Metals United Arab Emirates
Gold Coimpa Industrial LTDA Brazil
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. China
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 AMG Brasil Brazil
Tantalum Metallurgical Products India Pvt., Ltd. India
Tantalum Mineracao Taboca S.A. Brazil
Tantalum Mitsui Mining and Smelting Co., Ltd. Japan
Tantalum NPM Silmet AS Estonia
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. China
Tantalum QuantumClean United States Of America
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. China
Tantalum Solikamsk Magnesium Works OAO Russian Federation
Tantalum Taki Chemical Co., Ltd. Japan
Tantalum Telex Metals United States Of America
Tantalum Ulba Metallurgical Plant JSC Kazakhstan
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. China
Tantalum D Block Metals, LLC United States Of America
Tantalum FIR Metals & Resource Ltd. China
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China
Tantalum XinXing HaoRong Electronic Material Co., Ltd. China
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China
Tantalum KEMET de Mexico Mexico
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 Resind Industria e Comercio Ltda. Brazil
Tantalum Jiangxi Tuohong New Raw Material China
Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. China
Tantalum 5D Production OU Estonia
Tantalum PowerX Ltd. Rwanda
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China
Tin Alpha United States Of America
Tin PT Aries Kencana Sejahtera Indonesia
Tin PT Premium Tin Indonesia Indonesia
Tin Dowa Japan

 

Page 16 of 22May 2025

 

 

 

 

Metal Smelter Name Smelter Facility Location
Tin EM Vinto Bolivia (Plurinational State Of)
Tin Estanho de Rondonia S.A. Brazil
Tin Fenix Metals Poland
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. China
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. China
Tin Gejiu Kai Meng Industry and Trade LLC China
Tin China Tin Group Co., Ltd. China
Tin Malaysia Smelting Corporation (MSC) Malaysia
Tin Metallic Resources, Inc. United States Of America
Tin Mineracao Taboca S.A. Brazil
Tin Minsur Peru
Tin Mitsubishi Materials Corporation Japan
Tin Jiangxi New Nanshan Technology Ltd. China
Tin Novosibirsk Tin Combine Russian Federation
Tin O.M. Manufacturing (Thailand) Co., Ltd. Thailand
Tin Operaciones Metalurgicas S.A. Bolivia (Plurinational State Of)
Tin PT Artha Cipta Langgeng Indonesia
Tin PT Babel Inti Perkasa Indonesia
Tin PT Babel Surya Alam Lestari Indonesia
Tin PT Bangka Tin Industry Indonesia
Tin PT Belitung Industri Sejahtera Indonesia
Tin PT Bukit Timah Indonesia
Tin PT Mitra Stania Prima Indonesia
Tin PT Panca Mega Persada Indonesia
Tin PT Prima Timah Utama Indonesia
Tin PT Refined Bangka Tin Indonesia
Tin PT Sariwiguna Binasentosa Indonesia
Tin PT Stanindo Inti Perkasa Indonesia
Tin PT Timah Tbk Kundur Indonesia
Tin PT Timah Tbk Mentok Indonesia
Tin PT Tinindo Inter Nusa Indonesia
Tin PT Tommy Utama Indonesia
Tin Rui Da Hung Taiwan, Province Of China
Tin Thaisarco Thailand
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China
Tin VQB Mineral and Trading Group JSC Viet Nam
Tin White Solder Metalurgia e Mineracao Ltda. Brazil
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. China
Tin CV Venus Inti Perkasa Indonesia
Tin Magnu's Minerais Metais e Ligas Ltda. Brazil
Tin PT Tirus Putra Mandiri Indonesia
Tin Melt Metais e Ligas S.A. Brazil

 

Page 17 of 22May 2025

 

 

 

 

Metal Smelter Name Smelter Facility Location
Tin PT ATD Makmur Mandiri Jaya Indonesia
Tin O.M. Manufacturing Philippines, Inc. Philippines
Tin CV Ayi Jaya Indonesia
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company Viet Nam
Tin PT Rajehan Ariq Indonesia
Tin PT Cipta Persada Mulia Indonesia
Tin An Vinh Joint Stock Mineral Processing Company Viet Nam
Tin Resind Industria e Comercio Ltda. Brazil
Tin Super Ligas Brazil
Tin Aurubis Beerse Belgium
Tin Aurubis Berango Spain
Tin PT Bangka Prima Tin Indonesia
Tin PT Sukses Inti Makmur Indonesia
Tin PT Menara Cipta Mulia Indonesia
Tin HuiChang Hill Tin Industry Co., Ltd. China
Tin Modeltech Sdn Bhd Malaysia
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China
Tin Chifeng Dajingzi Tin Industry Co., Ltd. China
Tin PT Bangka Serumpun Indonesia
Tin Pongpipat Company Limited Myanmar
Tin Tin Technology & Refining United States Of America
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. China
Tin Ma'anshan Weitai Tin Co., Ltd. China
Tin PT Rajawali Rimba Perkasa Indonesia
Tin Luna Smelter, Ltd. Rwanda
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. China
Tin Precious Minerals and Smelting Limited India
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. China
Tin PT Mitra Sukses Globalindo Indonesia
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil
Tin CRM Synergies Spain
Tin Fabrica Auricchio Industria e Comercio Ltda. Brazil
Tin DS Myanmar Myanmar
Tin PT Putera Sarana Shakti (PT PSS) Indonesia
Tin Mining Minerals Resources SARL Congo, Democratic Republic Of The
Tin Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. Japan
Tin Malaysia Smelting Corporation Berhad (Port Klang) Malaysia
Tungsten A.L.M.T. Corp. Japan
Tungsten Kennametal Huntsville United States Of America
Tungsten Guangdong Xianglu Tungsten Co., Ltd. China

 

Page 18 of 22May 2025

 

 

 

 

Metal Smelter Name Smelter Facility Location
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. China
Tungsten CNMC (Guangxi) PGMA Co., Ltd. China
Tungsten Global Tungsten & Powders LLC United States Of America
Tungsten Hunan Chenzhou Mining Co., Ltd. China
Tungsten Hunan Jintai New Material Co., Ltd. China
Tungsten Japan New Metals Co., Ltd. Japan
Tungsten Kennametal Fallon United States Of America
Tungsten Wolfram Bergbau und Hutten AG Austria
Tungsten Xiamen Tungsten Co., Ltd. China
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. China
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. China
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. China
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China
Tungsten Malipo Haiyu Tungsten Co., Ltd. China
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. China
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. China
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. China
Tungsten Asia Tungsten Products Vietnam Ltd. Viet Nam
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China
Tungsten H.C. Starck Tungsten GmbH Germany
Tungsten TANIOBIS Smelting GmbH & Co. KG 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 China Molybdenum Tungsten Co., Ltd. China
Tungsten Hydrometallurg, JSC Russian Federation
Tungsten Unecha Refractory metals plant Russian Federation
Tungsten Philippine Chuangxin Industrial Co., Inc. Philippines
Tungsten ACL Metais Eireli Brazil
Tungsten Moliren Ltd. Russian Federation
Tungsten Lianyou Metals Co., Ltd. Taiwan, Province Of China
Tungsten JSC "Kirovgrad Hard Alloys Plant" Russian Federation
Tungsten NPP Tyazhmetprom LLC Russian Federation
Tungsten Hubei Green Tungsten Co., Ltd. China
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil
Tungsten Cronimet Brasil Ltda Brazil
Tungsten Artek LLC Russian Federation
Tungsten Fujian Xinlu Tungsten Co., Ltd. China
Tungsten OOO “Technolom” 2 Russian Federation
Tungsten OOO “Technolom” 1 Russian Federation
Tungsten LLC Vostok Russian Federation
Tungsten YUDU ANSHENG TUNGSTEN CO., LTD. China

 

Page 19 of 22May 2025

 

 

 

 

Metal Smelter Name Smelter Facility Location
Tungsten HANNAE FOR T Co., Ltd. Korea, Republic Of
Tungsten Tungsten Vietnam Joint Stock Company Viet Nam
Tungsten Nam Viet Cromit Joint Stock Company Viet Nam
Tungsten DONGKUK INDUSTRIES CO., LTD. Korea, Republic Of
Tungsten Lianyou Resources Co., Ltd. Taiwan, Province Of China
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. China
Tungsten Kenee Mining Corporation Vietnam Viet Nam

 

Page 20 of 22May 2025

 

 

 

 

Appendix B: Countries of Origin

 

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs. Organon believes that Appendix B is likely to include more countries than those that are actually sources of the 3TG in Organon’s products.

 

Albania Cyprus Indonesia Netherlands Sudan
Andorra Democratic Republic of Congo Ireland New Zealand Suriname
Angola Djibouti Israel Nicaragua Sweden
Argentina Dominica Italy Niger Switzerland
Armenia Dominican Republic Ivory Coast Nigeria Taiwan
Australia Ecuador Japan Norway Tajikistan
Austria Egypt Jersey Oman Tanzania
Azerbaijan El Salvador Kazakhstan Panama Thailand
Belarus Eritrea Kenya Papua New Guinea Togo
Belgium Estonia Korea Peru Turkey
Benin Ethiopia Kyrgyzstan Philippines Uganda
Bermuda Fiji Liberia Poland United Arab Emirates
Bolivia (Plurinational State of) Finland Liechtenstein Portugal United Kingdom
Botswana France Lithuania Russian Federation United States of America
Brazil Georgia Luxembourg Rwanda Uruguay
Bulgaria Germany Madagascar Saudi Arabia Uzbekistan
Burkina Faso Ghana Malaysia Senegal VietNam
Burundi Guam Mali Serbia Zambia
Cambodia Guatemala Mauritania Sierra Leone  
Canada Guinea Mexico Singapore  
Central African Republic Guyana Mongolia Slovakia  
Chile Honduras Morocco Solomon Islandss  
China Hong Kong Mozambique South Africa  
Colombia Hungary Myanmar South Sudan  
Congo India Namibia Spain  

 

Page 21 of 22May 2025

 

 

 

 

Appendix C: CMRT Declaration Rejection/Approval Criteria

 

Assent Sustainability Platform Logic Structure

 

The following table maps the Assent Sustainability Platform’s status outputs and CMRT logic structure when determining supplier conflict mineral statuses as displayed on the Assent platform dashboard. Using this table, and referencing certain CMRT questions, Organon was able to determine what answers were provided by its suppliers to earn their conflict minerals response statuses designated by Assent.

 

Dashboard Supplier Response Statuses

 

Supplier Status   Description
Not Submitted   A CMRT has not been submitted by the supplier
Complete   A CMRT has been submitted, and is valid and complete
Incomplete   A supplier with parts associated to them has submitted a partially completed Product-Level or User-Defined CMRT
Invalid Submission   A CMRT has been submitted and deemed invalid based on contradicting responses in the template
Out of Scope   The supplier is out of scope for conflict minerals and does not need to be contacted

 

Page 22 of 22May 2025