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 2023 (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 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 purchases its products from unaffiliated manufacturers, most of which are located in China, Mexico, Vietnam and the United States. Helen of Troy contracts to have products manufactured that may contain gold, tantalum, tin and tungsten (“3TG”). As these materials may be necessary to Helen of Troy’s products, the Company has embarked on a process to trace the origin of these metals to determine whether its sourcing practices support conflict or human rights abuses in the 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 2. Product Description Helen of Troy contracts to have products manufactured that may contain 3TG, such as home, outdoor, wellness, and beauty consumer products. Helen of Troy purchases finished product and is therefore several tiers removed from the mining operations. The Company does not purchase any materials directly from smelters or refiners, so Helen of Troy must rely on its suppliers to provide reliable and accurate information about 3TG. Helen of Troy’s suppliers were requested to use the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (“CMRT”) to identify gold, tantalum, tin and tungsten smelters or refiners (“SORs”) and associated countries of origin. Verified SORs were matched against available lists of processors that have been certified by internationally- recognized industry validation schemes, such as the Responsible Minerals Assurance Process (RMAP), the London Bullion Market Association Good Delivery Program (“LBMA”), and the Responsible Jewelry Council Chain-of-Custody Certification (“RJC”). Conflict free certification information is current as of April 23, 2024. 3. Reasonable Country of Origin Inquiry Description Helen of Troy obtained the aforementioned product information by implementing a Reasonable Country of Origin Inquiry (“RCOI”). Helen of Troy assembled an internal team, led by its Vice President, Global ESG (Environmental, Social and Governance), comprised of representatives from Helen of Troy’s finance, legal and supply chain departments. Helen of Troy engaged Source Intelligence (“SI”), a third-party information management service provider, to gather information from suppliers and establish a system of controls and transparency over its supply chain. This is the ninth consecutive year the Company worked with SI. Helen of Troy’s Tier 1 suppliers were engaged by SI to collect information regarding the presence and sourcing of 3TG used in the products supplied to them. Information was collected and stored using an online platform provided by SI. Supplier Engagement As in previous years, the RCOI began with an introduction email from Helen of Troy to suppliers describing its conflict minerals reporting requirements. Following that introduction email, a subsequent email was sent to suppliers containing a registration and survey request link to the online data collection platform. In an effort to increase awareness of the Company’s Conflict Minerals Compliance Program (CMCP), supporting regulation, and frequently asked questions (FAQs) concerning 3TG mineral tracing, Helen of Troy’s suppliers were given access to an online Supplier Resource Center. The Supplier Resource Center provided educational information to facilitate a deeper understanding of conflict
3 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 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.
4 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 147 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 93%. The decrease in response rate was due to the inclusion of suppliers from recent acquisitions. For some of these suppliers, this was the first time they were requested to provide such information. We anticipate response rates will improve in the future as these suppliers are further engaged in this process. • Out of these responding suppliers, 22% 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 260 verified SORs. • Of the 260 verified SORs, 86.2% are currently certified, of those that are not yet certified, 2.7% are actively moving through the certification process or are planning to do so within two years. Around 82.3% 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 1 SOR, we required the relevant supplier to cease any more purchases from these SORs for our products.
5 The following table lists the verified SORs provided by Helen of Troy’s suppliers, along with the certification status of each SOR as of April 23, 2024. Number Metal Official Smelter Name Conflict-Free Certifications 1 Gold 8853 S.p.A. None 2 Gold Abington Reldan Metals, LLC RMAP 3 Gold Advanced Chemical Company RMAP - Active 4 Gold Agosi AG LBMA, RJC, RMAP 5 Gold Aida Chemical Industries Co., Ltd. RMAP 6 Gold Al Etihad Gold Refinery DMCC None 7 Gold Alexy Metals None 8 Gold Almalyk Mining and Metallurgical Complex (AMMC) LBMA, RMAP 9 Gold AngloGold Ashanti Corrego do Sitio Mineracao LBMA, RMAP 10 Gold Argor-Heraeus S.A. LBMA, RMAP 11 Gold Asahi Pretec Corp. LBMA, RMAP 12 Gold Asahi Refining Canada Ltd. LBMA, RMAP 13 Gold Asahi Refining USA Inc. LBMA, RMAP 14 Gold Asaka Riken Co., Ltd. RMAP 15 Gold Augmont Enterprises Private Limited RMAP - Active 16 Gold Aurubis AG LBMA, RMAP 17 Gold Bangalore Refinery RMAP - Active 18 Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) LBMA, RMAP 19 Gold Boliden AB LBMA, RMAP 20 Gold C. Hafner GmbH + Co. KG LBMA, RJC, RMAP 21 Gold CCR Refinery - Glencore Canada Corporation LBMA, RMAP 22 Gold Cendres + Metaux S.A. None 23 Gold Chimet S.p.A. LBMA, RMAP 24 Gold Chugai Mining RMAP 25 Gold Coimpa Industrial LTDA RMAP 26 Gold Dowa RMAP 27 Gold DSC (Do Sung Corporation) RMAP 28 Gold Eco-System Recycling Co., Ltd. East Plant RMAP 29 Gold Eco-System Recycling Co., Ltd. North Plant RMAP 30 Gold Eco-System Recycling Co., Ltd. West Plant RMAP 31 Gold Emirates Gold DMCC None 32 Gold Geib Refining Corporation None 33 Gold GGC Gujrat Gold Centre Pvt. Ltd. RMAP - Active 34 Gold Gold by Gold Colombia RMAP 35 Gold Gold Refinery of Zijin Mining Group Co., Ltd. LBMA, RMAP 36 Gold Guangdong Jinding Gold Limited None
6 Number Metal Official Smelter Name Conflict-Free Certifications 37 Gold Heimerle + Meule GmbH LBMA, RMAP 38 Gold Heraeus Germany GmbH Co. KG RMAP 39 Gold Heraeus Metals Hong Kong Ltd. LBMA, RJC, RMAP 40 Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. LBMA, RMAP 41 Gold Ishifuku Metal Industry Co., Ltd. LBMA, RMAP 42 Gold Istanbul Gold Refinery LBMA, RMAP 43 Gold Italpreziosi RJC, RMAP 44 Gold Japan Mint LBMA, RMAP 45 Gold Jiangxi Copper Co., Ltd. LBMA, RMAP 46 Gold JX Nippon Mining & Metals Co., Ltd. LBMA, RMAP 47 Gold Kazzinc LBMA, RMAP 48 Gold Kennecott Utah Copper LLC LBMA, RMAP 49 Gold KGHM Polska Miedz Spolka Akcyjna RMAP 50 Gold Kojima Chemicals Co., Ltd. RMAP 51 Gold Korea Zinc Co., Ltd. RMAP 52 Gold L'Orfebre S.A. RMAP 53 Gold LS-NIKKO Copper Inc. LBMA, RMAP 54 Gold LT Metal Ltd. RMAP 55 Gold Materion RMAP 56 Gold Matsuda Sangyo Co., Ltd. LBMA, RMAP 57 Gold Metal Concentrators SA (Pty) Ltd. RMAP 58 Gold Metalor Technologies (Hong Kong) Ltd. LBMA, RJC, RMAP 59 Gold Metalor Technologies (Singapore) Pte., Ltd. LBMA, RJC, RMAP 60 Gold Metalor Technologies (Suzhou) Ltd. RJC, RMAP 61 Gold Metalor Technologies S.A. LBMA, RJC, RMAP 62 Gold Metalor USA Refining Corporation LBMA, RJC, RMAP 63 Gold Metalurgica Met-Mex Penoles S.A. De C.V. LBMA, RMAP 64 Gold Mitsubishi Materials Corporation LBMA, RMAP 65 Gold Mitsui Mining and Smelting Co., Ltd. LBMA, RMAP 66 Gold MKS PAMP SA LBMA, RMAP 67 Gold MMTC-PAMP India Pvt., Ltd. LBMA, RMAP 68 Gold Nadir Metal Rafineri San. Ve Tic. A.S. LBMA, RMAP 69 Gold Navoi Mining and Metallurgical Combinat RMAP 70 Gold NH Recytech Company RMAP 71 Gold Nihon Material Co., Ltd. LBMA, RMAP 72 Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH RJC, RMAP 73 Gold Ohura Precious Metal Industry Co., Ltd. RMAP 74 Gold Planta Recuperadora de Metales SpA RMAP
7 Number Metal Official Smelter Name Conflict-Free Certifications 75 Gold PT Aneka Tambang (Persero) Tbk LBMA, RMAP 76 Gold PX Precinox S.A. LBMA, RMAP 77 Gold Rand Refinery (Pty) Ltd. LBMA, RMAP 78 Gold REMONDIS PMR B.V. RMAP 79 Gold Royal Canadian Mint LBMA, RMAP 80 Gold SAAMP None 81 Gold Safimet S.p.A None 82 Gold SAFINA A.S. RMAP 83 Gold Samduck Precious Metals None 84 Gold SEMPSA Joyeria Plateria S.A. LBMA, RMAP 85 Gold Shandong Gold Smelting Co., Ltd. LBMA, RMAP 86 Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. None 87 Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. LBMA, RMAP 88 Gold Sichuan Tianze Precious Metals Co., Ltd. LBMA, RMAP 89 Gold Singway Technology Co., Ltd. None 90 Gold Solar Applied Materials Technology Corp. LBMA, RMAP 91 Gold Sumitomo Metal Mining Co., Ltd. LBMA, RMAP 92 Gold SungEel HiMetal Co., Ltd. RMAP 93 Gold T.C.A S.p.A LBMA, RMAP 94 Gold Tanaka Kikinzoku Kogyo K.K. LBMA, RMAP 95 Gold Tokuriki Honten Co., Ltd. LBMA, RMAP 96 Gold Tongling Nonferrous Metals Group Co., Ltd. None 97 Gold TOO Tau-Ken-Altyn RMAP 98 Gold Torecom RMAP 99 Gold Umicore Precious Metals Thailand None 100 Gold Umicore S.A. Business Unit Precious Metals Refining LBMA, RMAP 101 Gold United Precious Metal Refining, Inc. RMAP 102 Gold Valcambi S.A. LBMA, RJC, RMAP 103 Gold WEEEREFINING RMAP 104 Gold Western Australian Mint (T/a The Perth Mint) LBMA, RMAP 105 Gold WIELAND Edelmetalle GmbH RMAP 106 Gold Yamakin Co., Ltd. RMAP 107 Gold Yokohama Metal Co., Ltd. RMAP 108 Gold Yunnan Copper Industry Co., Ltd. None 109 Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation LBMA, RMAP 110 Tantalum AMG Brasil RMAP 111 Tantalum Changsha South Tantalum Niobium Co., Ltd. RMAP 112 Tantalum D Block Metals, LLC RMAP 113 Tantalum F&X Electro-Materials Ltd. RMAP
8 Number Metal Official Smelter Name Conflict-Free Certifications 114 Tantalum FIR Metals & Resource Ltd. RMAP 115 Tantalum Global Advanced Metals Aizu RMAP 116 Tantalum Global Advanced Metals Boyertown RMAP 117 Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. RMAP 118 Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. RMAP 119 Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. RMAP 120 Tantalum Jiangxi Tuohong New Raw Material RMAP 121 Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. RMAP 122 Tantalum Jiujiang Tanbre Co., Ltd. RMAP 123 Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. RMAP 124 Tantalum KEMET de Mexico RMAP 125 Tantalum Materion Newton Inc. RMAP 126 Tantalum Metallurgical Products India Pvt., Ltd. RMAP 127 Tantalum Mineracao Taboca S.A. RMAP 128 Tantalum Mitsui Mining and Smelting Co., Ltd. RMAP 129 Tantalum Molycorp Silmet A.S. RMAP 130 Tantalum Ningxia Orient Tantalum Industry Co., Ltd. RMAP 131 Tantalum PowerX Ltd. RMAP 132 Tantalum QuantumClean RMAP 133 Tantalum Resind Industria e Comercio Ltda. RMAP 134 Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd. RMAP 135 Tantalum Taki Chemical Co., Ltd. RMAP 136 Tantalum TANIOBIS Co., Ltd. RMAP 137 Tantalum TANIOBIS GmbH RMAP 138 Tantalum TANIOBIS Japan Co., Ltd. RMAP 139 Tantalum TANIOBIS Smelting GmbH & Co. KG RMAP 140 Tantalum Telex Metals RMAP 141 Tantalum Ulba Metallurgical Plant JSC RMAP 142 Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED RMAP 143 Tantalum XinXing Haorong Electronic Material Co., Ltd. RMAP 144 Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. RMAP 145 Tin Alpha RMAP 146 Tin An Vinh Joint Stock Mineral Processing Company None 147 Tin Aurubis Beerse RMAP 148 Tin Aurubis Berango RMAP 149 Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. RMAP 150 Tin Chifeng Dajingzi Tin Industry Co., Ltd. RMAP 151 Tin China Tin Group Co., Ltd. RMAP 152 Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda RMAP
9 Number Metal Official Smelter Name Conflict-Free Certifications 153 Tin CRM Synergies RMAP 154 Tin CV Ayi Jaya RMAP 155 Tin CV Venus Inti Perkasa RMAP 156 Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. None 157 Tin Dowa RMAP 158 Tin DS Myanmar RMAP 159 Tin EM Vinto RMAP 160 Tin Estanho de Rondonia S.A. RMAP 161 Tin Fabrica Auricchio Industria e Comercio Ltda. RMAP 162 Tin Fenix Metals RMAP 163 Tin Gejiu Kai Meng Industry and Trade LLC None 164 Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. RMAP 165 Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. None 166 Tin Gejiu Zili Mining And Metallurgy Co., Ltd. None 167 Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. RMAP 168 Tin HuiChang Hill Tin Industry Co., Ltd. RMAP 169 Tin Jiangxi New Nanshan Technology Ltd. RMAP 170 Tin Luna Smelter, Ltd. RMAP 171 Tin Ma'anshan Weitai Tin Co., Ltd. None 172 Tin Magnu's Minerais Metais e Ligas Ltda. RMAP 173 Tin Malaysia Smelting Corporation (MSC) RMAP 174 Tin Melt Metais e Ligas S.A. None 175 Tin Metallic Resources, Inc. RMAP 176 Tin Mineracao Taboca S.A. RMAP 177 Tin Mining Minerals Resources SARL RMAP 178 Tin Minsur RMAP 179 Tin Mitsubishi Materials Corporation RMAP 180 Tin Modeltech Sdn Bhd None 181 Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company None 182 Tin O.M. Manufacturing (Thailand) Co., Ltd. RMAP 183 Tin O.M. Manufacturing Philippines, Inc. RMAP 184 Tin Operaciones Metalurgicas S.A. RMAP 185 Tin Pongpipat Company Limited None 186 Tin Precious Minerals and Smelting Limited RMAP - Active 187 Tin PT Aries Kencana Sejahtera RMAP 188 Tin PT Artha Cipta Langgeng RMAP 189 Tin PT ATD Makmur Mandiri Jaya RMAP 190 Tin PT Babel Inti Perkasa RMAP 191 Tin PT Babel Surya Alam Lestari RMAP
10 Number Metal Official Smelter Name Conflict-Free Certifications 192 Tin PT Bangka Prima Tin RMAP 193 Tin PT Bangka Serumpun RMAP 194 Tin PT Bangka Tin Industry RMAP - Active 195 Tin PT Belitung Industri Sejahtera RMAP 196 Tin PT Bukit Timah RMAP 197 Tin PT Cipta Persada Mulia RMAP 198 Tin PT Menara Cipta Mulia RMAP 199 Tin PT Mitra Stania Prima RMAP 200 Tin PT Mitra Sukses Globalindo RMAP 201 Tin PT Panca Mega Persada None 202 Tin PT Premium Tin Indonesia RMAP 203 Tin PT Prima Timah Utama RMAP 204 Tin PT Putera Sarana Shakti (PT PSS) RMAP 205 Tin PT Rajawali Rimba Perkasa RMAP 206 Tin PT Rajehan Ariq RMAP 207 Tin PT Refined Bangka Tin RMAP 208 Tin PT Sariwiguna Binasentosa RMAP 209 Tin PT Stanindo Inti Perkasa RMAP 210 Tin PT Sukses Inti Makmur RMAP 211 Tin PT Timah Tbk Kundur RMAP 212 Tin PT Timah Tbk Mentok RMAP 213 Tin PT Tinindo Inter Nusa RMAP 214 Tin PT Tirus Putra Mandiri None 215 Tin PT Tommy Utama RMAP 216 Tin Resind Industria e Comercio Ltda. RMAP 217 Tin Rui Da Hung RMAP 218 Tin Super Ligas RMAP 219 Tin Thaisarco RMAP 220 Tin Tin Smelting Branch of Yunnan Tin Co., Ltd. RMAP 221 Tin Tin Technology & Refining RMAP 222 Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company None 223 Tin White Solder Metalurgia e Mineracao Ltda. RMAP 224 Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. RMAP 225 Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. RMAP 226 Tungsten A.L.M.T. TUNGSTEN Corp. RMAP 227 Tungsten Asia Tungsten Products Vietnam Ltd. RMAP 228 Tungsten China Molybdenum Co., Ltd. RMAP 229 Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. RMAP 230 Tungsten Cronimet Brasil Ltda RMAP
11 Number Metal Official Smelter Name Conflict-Free Certifications 231 Tungsten DONGKUK INDUSTRIES CO., LTD. RMAP - Progressing 232 Tungsten Fujian Xinlu Tungsten Co., Ltd. RMAP 233 Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. RMAP 234 Tungsten Ganzhou Seadragon W & Mo Co., Ltd. RMAP 235 Tungsten Global Tungsten & Powders LLC RMAP 236 Tungsten Guangdong Xianglu Tungsten Co., Ltd. RMAP 237 Tungsten H.C. Starck Tungsten GmbH RMAP 238 Tungsten Hubei Green Tungsten Co., Ltd. RMAP 239 Tungsten Hunan Chenzhou Mining Co., Ltd. RMAP 240 Tungsten Hunan Jintai New Material Co., Ltd. None 241 Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch RMAP 242 Tungsten Japan New Metals Co., Ltd. RMAP 243 Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. RMAP 244 Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. RMAP 245 Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. RMAP 246 Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. RMAP 247 Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. RMAP 248 Tungsten Kennametal Fallon RMAP 249 Tungsten Kennametal Huntsville RMAP 250 Tungsten Lianyou Metals Co., Ltd. RMAP 251 Tungsten Malipo Haiyu Tungsten Co., Ltd. RMAP 252 Tungsten Masan High-Tech Materials RMAP 253 Tungsten Niagara Refining LLC RMAP 254 Tungsten Philippine Chuangxin Industrial Co., Inc. RMAP 255 Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd. RMAP 256 Tungsten TANIOBIS Smelting GmbH & Co. KG RMAP 257 Tungsten Tungsten Vietnam Joint Stock Company RMAP 258 Tungsten Wolfram Bergbau und Hutten AG RMAP 259 Tungsten Xiamen Tungsten (H.C.) Co., Ltd. RMAP 260 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.
12 2. Responsible Gold Certificate: London Bullion Market Association (LBMA) • LBMA: The smelter has obtained a Responsible Gold Certification. 3. Chain of Custody Certificate: Responsible Jewelry Council (RJC) • RJC: The smelter has obtained a Chain-of-Custody Certification. *NA refers to no applicable standard identified Countries of origin for these SORs are believed to include: Country of Origin Angola Guyana Peru Argentina Hong Kong Philippines Armenia Hungary Poland Australia India Portugal Austria Indonesia Russian Federation Belarus Ireland Rwanda Belgium Israel Saudi Arabia Bermuda Italy Sierra Leone Bolivia Ivory Coast Singapore Brazil Japan Slovakia Burundi Jersey South Africa Cambodia Kazakhstan South Sudan Canada Kenya Spain Central African Republic Korea, Republic of Suriname Chile Kyrgyzstan Sweden China Laos Switzerland Colombia Luxembourg Taiwan Congo (Brazzaville) Madagascar Tajikistan Czech Republic Malaysia Tanzania Djibouti Mali Thailand DRC- Congo (Kinshasa) Mexico Turkey Ecuador Mongolia Uganda Egypt Morocco United Arab Emirates Estonia Mozambique United Kingdom Ethiopia Myanmar United States Finland Namibia Uzbekistan France Netherlands Viet Nam Germany Niger Zambia Ghana Nigeria Zimbabwe Guinea Papua New Guinea
13 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, Global ESG, comprised of representatives from the finance, legal and supply chain departments to communicate and manage compliance initiatives. Team members work with the suppliers on a continual basis to maintain an open dialog and transparency in the procurement process. Findings are reported to senior management, as well as to the internal audit department. The Company’s internal team efforts are supplemented with a third-party service provider’s extensive knowledge and experience, as well as training seminars on conflict minerals. • Step 2- Identify and assess risk in the supply chain The Company continues to refine its list of product categories and suppliers that may fall within the scope of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Expectations with regard to supplier performance, transparency and sourcing are clearly communicated through supplier training. Quality assessments with suppliers are being expanded to encompass compliance initiatives. Suppliers are being encouraged to implement conflict mineral policies with their vendors. • Step 3- Design and implement a strategy to respond to identified risks Helen of Troy continues to make improvements on risk management. As RCOI are conducted and additional information becomes available regarding components and materials being used in the Company’s products, potential risks can be tracked and mitigated. The online platform maintained by SI allows Helen of Troy to 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.
14 access and analyze supplier responses as well as SOR information. Any suppliers found to be sourcing from SORs that support conflict in the DRC region will be required to explore alternative sources. • Step 4- Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain As part of Helen of Troy’s due diligence, and in conjunction with SI, the Company relies upon the following internationally accepted audit standards to determine which SORs are considered DRC Conflict Free: RMAP, LBMA and RJC. If the SOR is not certified by these internationally-recognized schemes, attempts are made to 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 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.
15 8. Independent Private Sector Audit Based on Helen of Troy’s declaration, a private sector audit is not required.