EXHIBIT 1.01

 

THE EASTERN COMPANY

CONFLICT MINERALS REPORT

REPORTING YEAR: 2025

 

COMPANY OVERVIEW

 

The Eastern Company (the “Company”) designs, manufactures and markets a diverse product line of custom and standard vehicular and industrial hardware, including turnkey returnable packaging solutions, access and security hardware, mirrors, and mirror-cameras.

   

During 2025, the Company identified certain of its products were likely to contain conflict minerals (as that term is defined by Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”)) necessary to the functionality or production of a product manufactured or contracted by the Company, due to the presence of such minerals in parts obtained from suppliers, either contract manufacturers or original equipment manufacturers (“OEM”), or from the utilization of conflict minerals in manufacturing processes employed by Company suppliers. Supplier parts obtained by the Company and used in Company products include electronic components such as motors, switches, harnesses, connectors, and various electronic locks the Company contracts to manufacture. The Company does not directly purchase conflict minerals and instead purchases components for use in higher level assemblies. The Company is therefore several levels removed from the actual mining of conflict minerals. Because the Company is several tiers removed from smelters and refiners, the Company relies on supplier representations and industry-standard reporting tools in conducting its due diligence. The Company does not make purchases of raw ore or unrefined conflict minerals and makes no purchases in the Democratic Republic of the Congo or an adjoining country.

 

REASONABLE COUNTRY OF ORIGIN INQUIRY

 

Subsequent to the Company’s initial assessment that certain supplier parts are likely to contain conflict minerals, the Company conducted a reasonable country of origin inquiry (“RCOI”) based on 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 to determine which of the Company-utilized parts contain conflict minerals and whether such conflict minerals originated in the Democratic Republic of the Congo or an adjoining country.  The Company contacted each of its suppliers and asked them to provide information on (1) the conflict minerals contained in each of the parts supplied by that supplier and (2) the source of the conflict minerals, including smelter/refinery information and location of mines. Each supplier was asked to complete the Responsible Minerals Initiative (“RMI”) (formerly the Conflict-Free Sourcing Initiative) Conflict Minerals Reporting Template, a standardized reporting template developed by the RMI, an initiative of the Responsible Business Alliance and the Global e-Sustainability Initiative, which facilitates the transfer of relevant and necessary information through the supply chain regarding mineral country of origin and smelters and refiners being utilized.  Of the suppliers identified as supplying the Company with product in 2025 containing Conflict Minerals and subsequently contacted, several were unable to determine the source of certain conflict minerals or provided the name and address of smelters not contained on RMI's Conflict Free Smelter (“CFS”) reference list. Therefore, in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, the Company proceeded to engage in due diligence regarding the sources and chain of custody of its conflict minerals.

 

 
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DUE DILIGENCE - STANDARD UTILIZED

 

The Company designed its due diligence framework to conform in all material respects with the framework provided by 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, an internationally recognized due diligence framework.

 

DUE DILIGENCE - PROCESS

 

The Company’s due diligence exercise included:

 

1.  Submitting the Responsible Minerals Initiative (“RMI”) (formerly the Conflict-Free Sourcing Initiative) Conflict Minerals Reporting Template, a standardized reporting template developed by the RMI, to each supplier of parts potentially containing conflict minerals. That template provided a standardized method for the Company to use in the collection of representations, statements, and data from the Company’s suppliers relative to the presence, use, source, and chain of custody of conflict minerals in supplier parts that are incorporated in the Company’s products for sale to end-use customers.

 

2. Accessing the RMI's Conflict Free Smelter (“CFS”) reference list - a listing of known smelters to be validated as “conformant” in RMI’s Standard Smelters and Refiners List.

 

3. Comparing smelters identified in the reporting templates against the list of smelter facilities which have been identified as "conflict free" by the RMI's Conflict Free Sourcing (“CFS”) program. The CFS program is a voluntary program whereby an independent third party evaluates smelter procurement activities to determine whether a smelter has sufficiently demonstrated that all materials processed by that smelter originated from sources that do not directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining country.

 

In some instances, the Company received, after repeat inquiries, conflicting or incomplete information regarding those facilities utilized to process necessary conflict minerals in supplier parts, as well as insufficient information regarding the mine(s) or source(s) of origin of those conflict minerals. Nevertheless, each supplier response was evaluated and, where possible, validated to determine sufficiency, accuracy, and completeness of its response. For each supplier response, the Company subsequently assessed whether the conflict minerals identified, or those conflict minerals that may not have been identified, were consistent with the nature and characteristics of the supplied part. For each supplier response that was insufficient or incomplete, the Company contacted the supplier for follow-up, sometimes contacting certain suppliers on multiple occasions. No supplier response indicated that conflict minerals were sourced from the Democratic Republic of the Congo or an adjoining country. However, of the several hundred suppliers the Company purchases from, several suppliers could not identify the smelter of the conflict mineral or the country where the conflict minerals were smelted. If a supplier stated that conflict minerals in its product were not sourced from the Democratic Republic of the Congo or an adjacent country but did not substantiate that information, the Company proceeded to verify that supplier response. Typically, verification involved a more detailed review of the supplier's smelter response and, where possible, discussion with the supplier. If a supplier's response could not be validated through details provided to the Company regarding the smelter and/or smelters involved, then the supplier response in question was determined to be uncertain or unknown relative to the question of sourcing of raw material and was reflected as such in the Company RMI template summary.

 

Pursuant to guidance issued by the SEC’s Division of Corporation Finance on April 29, 2014 and the SEC order issued May 2, 2014, the Company is not required to describe any of its products as “DRC conflict free” (as defined in Section 1, Item 1.01(d)(4) of Form SD), “DRC conflict undeterminable” (as defined in Section 1, Item 1.01(d)(5) of Form SD) or “having not been found to be ‘DRC conflict free,’” and therefore makes no conclusion in this regard in the report presented herein. Furthermore, given that the Company has not voluntarily elected to describe any of its products as “DRC conflict free,” an independent private sector audit of the report presented herein has not been conducted.

 

 
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DUE DILIGENCE - RESULTS

 

Based on our due diligence efforts, we were not able to conclusively determine the country of origin or mine or location of origin of the conflict minerals in our products.

  

RISK MITIGATION - IMPROVEMENT PROGRAM

 

The steps that the Company will take in reporting year 2026 to mitigate the risk that the Company’s conflict minerals benefit or finance armed groups are as follows:

 

1. The Company will continue to work with suppliers who provided incomplete or insufficient information to obtain complete and accurate information in 2026.

 

2. The Company will again request information and supporting data from each supplier providing parts to the Company that are subject to 2026 reporting requirements by utilizing the RMI Conflict Minerals Reporting Template and will pursue a completed template response that identifies material down to the smelter and mine.

 

3. The Company will again follow its due diligence process to review and validate supplier responses that are obtained in support of the Company 2026 conflict minerals reporting.

 

4. The Company will provide its Conflict Minerals Policy to suppliers as part of its RMI Conflict Minerals Reporting Template based supplier inquiry process for 2026.

 

5. The Company will encourage smelters and refiners to obtain conflict-free status through the RMI CFS voluntary compliance program.

 

 
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