EX-1.01 2 exhibit101conflictminerals.htm EX-1.01 Document
Exhibit 1.01
Celanese Corporation
Conflict Minerals Report

Introduction
This Conflict Minerals Report ("Report") of Celanese Corporation ("Celanese") is filed pursuant to Rule 13p-1 and Form SD ("Rule") promulgated under the Securities Exchange Act of 1934, as amended. This Report covers the reporting period from January 1, 2023, to December 31, 2023. The Rule provides that companies manufacturing or contracting to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products must conduct in good faith a reasonable country of origin inquiry regarding those specified minerals that is reasonably designed to determine whether any of the specified minerals originated in certain covered countries. The specified minerals include columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives (tantalum, tin, and tungsten), collectively known as "Conflict Minerals." The "Covered Countries" include the Democratic Republic of the Congo and adjoining countries.

Product Scope
The Report pertains to products manufactured or contracted to be manufactured by Celanese for which Conflict Minerals are necessary to the functionality or production.

Reasonable Country of Origin Inquiry (“RCOI”)
Celanese conducted a good faith RCOI to determine the origin of Conflict Minerals in its products. This involved identifying product categories likely to contain Conflict Minerals through product specifications and other information known to Celanese, identifying and contacting each supplier of such minerals, and assessing whether the minerals were sourced from a Covered Country or from recycled or scrap materials. Three Conflict Minerals—gold, tin, and tantalum—were identified through this process.

Gold: Gold is a chemical component of catalysts used in the manufacture of certain of Celanese’s products. Celanese (i) identified its suppliers of, and lessors that trade in, gold used in its catalysts and (ii) obtained certifications or written confirmations from these suppliers and lessors indicating that the gold did not originate from any Covered Country or that the suppliers and lessors were members of the London Bullion Market Association (“LBMA”), adhering to the LBMA’s responsible sourcing program.

Tin, gold, or tantalum: Celanese identified products from its Engineered Materials business containing tin, gold, or tantalum. Twenty two suppliers were identified, and Conflict Minerals Reporting Templates (“CMRTs”) were sent to these suppliers as part of the due diligence process. Responses indicated that the Conflict Minerals used in Celanese products were either conflict-free or were sourced from smelters audited and validated by the Responsible Minerals Assurance Process (“RMAP”).

Some of the CMRT responses Celanese received from its suppliers were made on a company-level basis and did not provide detail as to source and chain of custody for the specific quantities of Conflict Minerals that were actually supplied to Celanese. As a result, Celanese does not possess sufficient information to draw definitive conclusions as to the exact smelter, country of origin, mine location or location of origin of the tin contained in our in-scope products. For all companies downstream from such suppliers (in particular those several steps removed from the



original mines or smelters), it may be difficult to know the ultimate country or location of origin of the mine from which the Conflict Minerals originated.

Due Diligence Process
Celanese followed the due diligence framework outlined by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This included:
- Identifying Suppliers: Contacting suppliers and requesting information through CMRTs.
- Assessing Responses: Evaluating supplier responses to determine the source and chain of custody of Conflict Minerals.
- Follow-up Actions: Engaging with suppliers who did not provide timely or complete responses.

Results of Due Diligence
Celanese does not purchase Conflict Minerals directly from mines or smelters and relies on its direct suppliers to ensure responsible sourcing. The supply chains are complex, involving many third parties between the ultimate manufacture of the products and the original sources of the Conflict Minerals. The identified products in the Celanese’s portfolio are used in various industrial applications. Based on supplier responses, Celanese believes that the Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to be manufactured, by Celanese during calendar year 2023 were either:
- From countries other than the Covered Countries,
- From recycled or scrap sources, or
- Validated as conflict-free by the Responsible Minerals Initiative (“RMI”).

Celanese directly contacted its raw material suppliers and received supplier declarations or completed CMRTs that denoted the Conflict Minerals used in Celanese products were either certified to be conflict free or sourced from smelters and refineries that had been audited and validated by the RMAP. The list of smelters is included below:

Metal
Smelter
Country
Tin
Minsur
PERU
Tin
Mineracao Taboca S.A.
BRAZIL
Tin
White Solder Metalurgica
BRAZIL
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Fabrica Auricchio Industria e Comercio Ltda.
BRAZIL
Tin
ENAF
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Dowa
JAPAN
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Thaisarco
THAILAND
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Timah Tbk Mentok
INDONESIA
Tin
Aurubis Beerse
BELGIUM
Tin
Fenix Metals
POLAND
Tin
Tin Smelting Branch of Yunnan Tin Co., Ltd.
CHINA



Tin
PT Timah Tbk Kundur
INDONESIA
Gold
Royal Canadian Mint
CANADA
Gold
MKS PAMP SA
SWITZERLAND
Tin
Alpha
UNITED STATES OF AMERICA
Tin
Aurubis Beerse
BELGIUM
Tin
Aurubis Berango
SPAIN
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
CRM Synergies
SPAIN
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
Luna Smelter, Ltd.
RWANDA
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Bangka Serumpun
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA


Celanese is committed to preventing the use of Conflict Minerals that fund armed conflict in the Covered Countries. The Company’s Statement of Responsible Sourcing of Minerals is available at its website at https://www.celanese.com/en/legal/conflict-minerals-policy-and-disclosure. This Statement aligns with the Company’s Sustainable Procurement policy, which is available at its website at https://www.celanese.com/-/media/cewebjssapp/project/documents/celanese-sustainable-procurement-policy.pdfundefined. As part of its ongoing risk management and assessment program, the Company has taken the following steps: (i) obtain a membership in the Responsible Minerals Initiative and (ii) integrated the Mobility & Materials business of DuPont de Nemours, Inc. into Celanese’s enterprise resource planning system; and intends to continue the due diligence measures described in this Report.