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 2025 (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. Helen of Troy has two business segments: Home & Outdoor and Beauty & Wellness. The Home & Outdoor segment offers a broad range of outstanding world-class brands that help consumers enjoy everyday living inside their homes and outdoors. Our innovative products for home activities include food preparation and storage, cooking, cleaning, organization, and beverage service. Our outdoor performance range, on-the-go food storage, and beverageware includes lifestyle hydration products, coolers and food storage solutions, backpacks, and travel gear. Sales for this global segment are primarily to online and brick & mortar retailers and through our direct-to-consumer channel. The Beauty & Wellness segment provides consumers with a broad range of outstanding world-class brands for beauty and wellness. In Beauty, we deliver innovation through products such as hair styling appliances, grooming tools, and liquid and aerosol personal care products, and nail care solutions that help consumers look and feel more beautiful. In Wellness, we are there when you need us most with highly regarded humidifiers, thermometers, water and air purifiers, heaters, and fans. Sales for this global segment are primarily to online and brick & mortar retailers, distributors, and through our direct-to-consumer channel. Helen of Troy contracts with unaffiliated manufacturers, primarily in China, Mexico, Vietnam, to manufacture a significant portion of our finished goods for the Home & Outdoor segment and our Beauty & Wellness segment’s hair tools and accessories and nail consumables and grooming tools, as well as certain wellness product categories. The hair liquids category of the Beauty & Wellness segment sources most of its products from U.S. manufacturers. 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
2 origin of these metals to determine whether its sourcing practices support conflict or human rights abuses in the 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 Jewellery Council Chain-of- Custody Certification (“RJC”). Conflict free certification information is current as of May 4, 2026. 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- Regulatory, Sustainability & 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. The Company has worked with SI since 2014. 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
3 (FAQs) concerning 3TG mineral tracing, Helen of Troy’s suppliers were given access to an online Supplier Resource 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 212 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 97%. • Out of these responding suppliers, 14% 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 222 verified SORs. • Of the 222 verified SORs, 99% are currently certified, are actively moving through the certification process or are planning to do so within two years. Approximately 83% 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 1 are currently certified or actively moving through the certification process. Related to the non-certified SOR, we required the relevant suppliers to cease any more purchases from this SOR 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 4, 2026. Number Metal Official Smelter Name Conflict-Free Certifications 1 Gold Abington Reldan Metals, LLC RMAP 2 Gold Advanced Chemical Company RMAP 3 Gold Agosi AG LBMA, RJC, RMAP 4 Gold Aida Chemical Industries Co., Ltd. RMAP 5 Gold Almalyk Mining and Metallurgical Complex (AMMC) LBMA, RMAP 6 Gold AngloGold Ashanti Corrego do Sitio Mineracao LBMA, RMAP 7 Gold Argor-Heraeus S.A. LBMA, RJC, RMAP 8 Gold ASAHI METALFINE, Inc. LBMA, RMAP 9 Gold Asahi Refining Canada Ltd. LBMA, RMAP 10 Gold Asahi Refining USA Inc. LBMA, RMAP 11 Gold Asaka Riken Co., Ltd. RMAP 12 Gold Aurubis AG LBMA, RMAP 13 Gold Bangalore Refinery RMAP 14 Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) LBMA, RMAP 15 Gold Boliden Mineral AB (Ronnskar) LBMA, RMAP 16 Gold C. Hafner GmbH + Co. KG LBMA, RJC, RMAP 17 Gold Chimet S.p.A. LBMA, RMAP 18 Gold Chugai Mining RMAP 19 Gold Coimpa Industrial LTDA RMAP 20 Gold Dowa RMAP 21 Gold DSC (Do Sung Corporation) RMAP 22 Gold Eco-System Recycling Co., Ltd. East Plant RMAP 23 Gold Eco-System Recycling Co., Ltd. North Plant RMAP 24 Gold Eco-System Recycling Co., Ltd. West Plant RMAP 25 Gold Elite Industech Co., Ltd. RMAP 26 Gold GG Refinery Ltd. RMAP 27 Gold Glencore Canada Corporation - CCR Refinery LBMA, RMAP 28 Gold Gold by Gold Colombia RMAP 29 Gold Gold Corporation - The Perth Mint LBMA, RMAP 30 Gold Heimerle + Meule GmbH LBMA, RJC, RMAP 31 Gold Heraeus Germany GmbH Co. KG RMAP 32 Gold Heraeus Metals Hong Kong Ltd. LBMA, RJC, RMAP 33 Gold Impala Platinum - Base Metal Refinery (BMR) RMAP 34 Gold Impala Platinum - Platinum Metals Refinery (PMR) RMAP 35 Gold Impala Platinum - Rustenburg Smelter RMAP 36 Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. LBMA, RMAP
6 37 Gold Ishifuku Metal Industry Co., Ltd. LBMA, RMAP 38 Gold Istanbul Gold Refinery LBMA, RMAP 39 Gold Italpreziosi RJC, RMAP 40 Gold Japan Mint LBMA, RMAP 41 Gold Jiangxi Copper Co., Ltd. LBMA, RMAP 42 Gold JX Advanced Metals Corporation LBMA, RMAP 43 Gold Kazzinc Ltd LBMA, RMAP 44 Gold Kennecott Utah Copper LLC LBMA, RMAP 45 Gold KGHM Polska Miedz Spolka Akcyjna RMAP 46 Gold Kojima Chemicals Co., Ltd. RMAP 47 Gold Korea Zinc Co., Ltd. RMAP 48 Gold LS MnM Inc. LBMA, RMAP 49 Gold LT Metal Ltd. RMAP 50 Gold Materion RMAP 51 Gold Matsuda Sangyo Co., Ltd. LBMA, RMAP 52 Gold Metal Concentrators SA (Pty) Ltd. RJC, RMAP 53 Gold Metalor Technologies (Hong Kong) Ltd. LBMA, RJC, RMAP 54 Gold Metalor Technologies (Singapore) Pte., Ltd. LBMA, RJC, RMAP 55 Gold Metalor Technologies (Suzhou) Ltd. LBMA, RJC, RMAP 56 Gold Metalor Technologies S.A. LBMA, RJC, RMAP 57 Gold Metalor USA Refining Corporation LBMA, RJC, RMAP 58 Gold Metalurgica Met-Mex Penoles S.A. De C.V. LBMA, RMAP 59 Gold Minera Titan del Peru SRL (MTP) - Belen Plant None 60 Gold Mitsubishi Materials Corporation LBMA, RMAP 61 Gold Mitsui Mining and Smelting Co., Ltd. LBMA, RMAP 62 Gold MKS PAMP SA LBMA, RMAP 63 Gold MMTC-PAMP India Pvt., Ltd. LBMA, RMAP 64 Gold Nadir Metal Rafineri San. Ve Tic. A.S. LBMA, RMAP 65 Gold Navoi Mining and Metallurgical Combinat LBMA, RMAP 66 Gold NH Recytech Company RMAP 67 Gold Nihon Material Co., Ltd. LBMA, RMAP 68 Gold Oegussa Oesterreichische Gold- und Silber- Scheideanstalt Gesm.b.H. RJC, RMAP 69 Gold Ohura Precious Metal Industry Co., Ltd. RMAP 70 Gold Planta Recuperadora de Metales SpA RMAP 71 Gold PT Aneka Tambang (Persero) Tbk LBMA, RMAP 72 Gold PX Precinox S.A. LBMA, RMAP 73 Gold Rand Refinery (Pty) Ltd. LBMA, RMAP 74 Gold REMONDIS PMR B.V. RMAP 75 Gold Royal Canadian Mint LBMA, RMAP 76 Gold SAFINA A.S. RMAP 77 Gold SEMPSA Joyeria Plateria S.A. LBMA, RJC, RMAP 78 Gold Shandong Gold Smelting Co., Ltd. LBMA, RMAP 79 Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. LBMA, RMAP
7 80 Gold Sichuan Tianze Precious Metals Co., Ltd. LBMA, RMAP 81 Gold Solar Applied Materials Technology Corp. LBMA, RMAP 82 Gold Sumitomo Metal Mining Co., Ltd. LBMA, RMAP 83 Gold SungEel HiMetal Co., Ltd. RMAP 84 Gold T.C.A S.p.A LBMA, RMAP 85 Gold Tanaka Kikinzoku Kogyo K.K. LBMA, RMAP 86 Gold Tokuriki Honten Co., Ltd. LBMA, RMAP 87 Gold TOO Tau-Ken-Altyn LBMA, RMAP 88 Gold Umicore S.A. Business Unit Precious Metals Refining LBMA, RMAP 89 Gold United Precious Metal Refining, Inc. RMAP 90 Gold Valcambi S.A. LBMA, RJC, RMAP 91 Gold WIELAND Edelmetalle GmbH RJC, RMAP 92 Gold Yamakin Co., Ltd. RMAP 93 Gold Yokohama Metal Co., Ltd. RMAP 94 Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation LBMA, RMAP 95 Gold Zijin Mining Group Gold Smelting Co. Ltd. LBMA, RMAP 96 Tantalum AMG Brasil RMAP 97 Tantalum D Block Metals, LLC RMAP 98 Tantalum F&X Electro-Materials Ltd. RMAP 99 Tantalum FIR Metals & Resource Ltd. RMAP 100 Tantalum Global Advanced Metals Aizu RMAP 101 Tantalum Global Advanced Metals Boyertown RMAP 102 Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. RMAP 103 Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. RMAP 104 Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. RMAP 105 Tantalum Jiangxi Suns Nonferrous Materials Co. Ltd. RMAP - Active 106 Tantalum Jiangxi Tuohong New Raw Material RMAP 107 Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. RMAP 108 Tantalum Jiujiang Tanbre Co., Ltd. RMAP 109 Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. RMAP 110 Tantalum KEMET de Mexico RMAP 111 Tantalum Materion Newton Inc. RMAP 112 Tantalum Metallurgical Products India Pvt., Ltd. RMAP 113 Tantalum Mineracao Taboca S.A. RMAP 114 Tantalum Mitsui Mining and Smelting Co., Ltd. RMAP 115 Tantalum Ningxia Orient Tantalum Industry Co., Ltd. RMAP 116 Tantalum NPM Silmet OU RMAP 117 Tantalum PowerX Ltd. RMAP 118 Tantalum QuantumClean RMAP 119 Tantalum Resind Industria e Comercio Ltda. RMAP 120 Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. RMAP 121 Tantalum Taki Chemical Co., Ltd. RMAP 122 Tantalum TANIOBIS Co., Ltd. RMAP
8 123 Tantalum TANIOBIS GmbH RMAP 124 Tantalum TANIOBIS Japan Co., Ltd. RMAP 125 Tantalum TANIOBIS Smelting GmbH & Co. KG RMAP 126 Tantalum Telex Metals RMAP 127 Tantalum Ulba Metallurgical Plant JSC RMAP 128 Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED RMAP 129 Tantalum XinXing Haorong Electronic Material Co., Ltd. RMAP 130 Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. RMAP 131 Tin Alpha Assembly Solutions Inc RMAP 132 Tin Aurubis Beerse RMAP 133 Tin Aurubis Berango RMAP 134 Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. RMAP 135 Tin Chifeng Dajingzi Tin Industry Co., Ltd. RMAP 136 Tin China Tin Group Co., Ltd. RMAP 137 Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda RMAP - Active 138 Tin CRM Synergies EMEA, S.L.U. RMAP 139 Tin CV Ayi Jaya RMAP 140 Tin Dongguan Best Alloys Co., Ltd. RMAP 141 Tin Dowa RMAP 142 Tin EM Vinto RMAP 143 Tin Estanho de Rondonia S.A. RMAP 144 Tin Fabrica Auricchio Industria e Comercio Ltda. RMAP 145 Tin Fenix Metals RMAP 146 Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. RMAP 147 Tin Global Advanced Metals Greenbushes Pty Ltd. RMAP 148 Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. RMAP 149 Tin HuiChang Hill Tin Industry Co., Ltd. RMAP 150 Tin Jiangxi New Nanshan Technology Ltd. RMAP - Active 151 Tin Luna Smelter, Ltd. RMAP 152 Tin Magnu's Minerais Metais e Ligas Ltda. RMAP 153 Tin Malaysia Smelting Corporation (MSC) None 154 Tin Malaysia Smelting Corporation Berhad (Port Klang) RMAP 155 Tin Metallic Resources, Inc. RMAP 156 Tin Mineracao Taboca S.A. RMAP 157 Tin Mining Minerals Resources SARL RMAP 158 Tin Minsur RMAP 159 Tin Mitsubishi Materials Corporation RMAP 160 Tin O.M. Manufacturing (Thailand) Co., Ltd. RMAP 161 Tin O.M. Manufacturing Philippines, Inc. RMAP 162 Tin Operaciones Metalurgicas S.A. RMAP 163 Tin P Kay Metal, Inc RMAP 164 Tin PT Arsed Indonesia RMAP 165 Tin PT Artha Cipta Langgeng RMAP - Active
9 166 Tin PT ATD Makmur Mandiri Jaya RMAP 167 Tin PT Bangka Prima Tin RMAP 168 Tin PT Cipta Persada Mulia RMAP 169 Tin PT Mitra Stania Prima RMAP 170 Tin PT Mitra Sukses Globalindo RMAP 171 Tin PT Premium Tin Indonesia RMAP 172 Tin PT Prima Timah Utama RMAP 173 Tin PT Putera Sarana Shakti (PT PSS) RMAP 174 Tin PT Rajehan Ariq RMAP 175 Tin PT Timah Tbk Kundur RMAP 176 Tin PT Timah Tbk Mentok RMAP 177 Tin Resind Industria e Comercio Ltda. RMAP 178 Tin Rui Da Hung RMAP 179 Tin Super Ligas RMAP 180 Tin Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. RMAP 181 Tin Thaisarco RMAP 182 Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. RMAP 183 Tin Tin Technology & Refining RMAP 184 Tin White Solder Metalurgia e Mineracao Ltda. RMAP 185 Tin Woodcross Smelting Company Limited RMAP 186 Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. None 187 Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. RMAP 188 Tungsten A.L.M.T. Corp. RMAP 189 Tungsten Asia Tungsten Products Vietnam Ltd. RMAP 190 Tungsten China Molybdenum Tungsten Co., Ltd. RMAP 191 Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. RMAP 192 Tungsten Cronimet Brasil Ltda RMAP 193 Tungsten Ganzhou Seadragon W & Mo Co., Ltd. RMAP 194 Tungsten Global Tungsten & Powders LLC RMAP 195 Tungsten Guangdong Xianglu Tungsten Co., Ltd. RMAP 196 Tungsten H.C. Starck Tungsten GmbH RMAP 197 Tungsten Hubei Green Tungsten Co., Ltd. RMAP 198 Tungsten Japan New Metals Co., Ltd. RMAP 199 Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. RMAP 200 Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. RMAP 201 Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. RMAP 202 Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. RMAP 203 Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. RMAP 204 Tungsten Jing Yuan Tungsten Technology Co., Ltd. RMAP 205 Tungsten KENEE MINING VIETNAM COMPANY LIMITED RMAP 206 Tungsten Kennametal Fallon RMAP
10 207 Tungsten Kennametal Huntsville RMAP 208 Tungsten Lianyou Metals Co., Ltd. RMAP 209 Tungsten Lianyou Resources Co., Ltd. RMAP 210 Tungsten Malipo Haiyu Tungsten Co., Ltd. RMAP 211 Tungsten Masan High-Tech Materials RMAP 212 Tungsten Niagara Refining LLC RMAP 213 Tungsten Philippine Bonway Manufacturing Industrial Corporation RMAP 214 Tungsten Philippine Chuangxin Industrial Co., Inc. RMAP 215 Tungsten S.P.T. spol.s r.o. RMAP 216 Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. RMAP 217 Tungsten TANIOBIS Smelting GmbH & Co. KG RMAP 218 Tungsten Tungamoy Metals Inc. RMAP 219 Tungsten Tungsten Vietnam Joint Stock Company RMAP 220 Tungsten Wolfram Bergbau und Hutten AG RMAP 221 Tungsten Xiamen Tungsten (H.C.) Co., Ltd. RMAP 222 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 Jewellery 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: Country or Region of Origin Angola Guyana Philippines Argentina Hong Kong Poland Armenia Hungary Portugal Australia India Russian Federation Austria Indonesia Rwanda
11 Country or Region of Origin Belarus Ireland Saudi Arabia Belgium Israel Sierra Leone Bermuda Italy Singapore Bolivia Japan Slovakia Brazil Jersey South Africa Burundi Kazakhstan South Sudan Cambodia Kenya Spain Canada Korea, Republic of Suriname Central African Republic Kyrgyzstan Sweden Chile Laos Switzerland China Luxembourg Taiwan Colombia Madagascar Tajikistan Congo Malaysia Tanzania Cote D’Ivoire Mali Thailand Czechia Mexico Turkey Djibouti Mongolia Uganda Ecuador Morocco United Arab Emirates Egypt Mozambique United Kingdom Estonia Myanmar United States of America Ethiopia Namibia Uzbekistan UzFinland Netherlands Vietnam France Niger Zambia Germany Nigeria Zimbabwe Ghana Papau New Guinea Guinea Peru
12 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 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- Regulatory, Sustainability & Governance, 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 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. 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 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 compliance standards to determine which SORs are considered DRC Conflict Free: Responsible Minerals Assurance Process compliance standard, Responsible Sourcing Programme compliance standard, and Chain of Custody of the Responsible Jewellery Council’s Code of Practices. If the SOR is not certified by these internationally-recognized schemes, attempts are made to 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 • Educate suppliers who are being contacted for the first time due to recent acquisitions and 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
14 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.