EX-1.01 2 exhibit101.htm EX-1.01 Document


Exhibit 1.01

Conflict Minerals Report of Nordson Corporation
For The Year Ended December 31, 2021

I. Introduction
Nordson Corporation (“our,” “we” or “us”) engineers, manufactures and markets differentiated products and systems used for dispensing and processing adhesives, coatings, polymers, sealants and biomaterials, and for managing fluids, testing and inspecting for quality, treating surfaces and curing. These products are supported with extensive application expertise and direct global sales and service. We serve a wide variety of consumer non-durable, consumer durable and technology end markets including packaging, nonwovens, electronics, medical, appliances, energy, transportation, building and construction, and general product assembly and finishing.

Headquartered in Westlake, Ohio, our products are marketed through a network of direct operations in more than 35 countries. Our principal manufacturing facilities are located in the United States, the People’s Republic of China, Germany, Ireland, Israel, Mexico, the Netherlands, Thailand, and the United Kingdom.

Pursuant to the Securities and Exchange Commission’s conflict minerals rule adopted pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Rule”) and to the guidance provided by the Securities and Exchange Commission in its Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued on April 29, 2014, this Report was not subject to an independent private sector audit.

II. Reasonable Country of Origin Inquiry
Organization for Economic Co-operation and Development (OECD) Step 1 – Establish strong management systems
Internal Management
We have established a Conflict Minerals Reporting Oversight Committee. The team members include representatives from our Supply Chain Management, one of whom is our designated member of senior management, Legal, Product Compliance, Finance and Internal Audit departments. Periodic reports are made to the audit committee of the board of directors with respect to our due diligence process and compliance obligations.

We have been an active member of the Responsible Materials Initiative (RMI), formerly known as the Conflict-Free Sourcing Initiative (CFSI), since 2015. Through the RMI, we participate in the monthly RMI Plenary Call.

External Communications and Supply Chain Engagement
Our customers can access our conflict minerals statement on our public website,
https://www.nordson.com/en/our-company/ethics-and-compliance/conflict-minerals. Our conflict minerals statement informs customers of where we are in our Rule compliance efforts. Customer inquiries are handled on a case by case basis, utilizing the conflict minerals statement or customized responses using the conflict mineral reporting template (CMRT) developed by the RMI, as appropriate.

Because we are an industrial equipment supplier, many of our products are not incorporated into our customers’ products and, therefore, do not fall within the scope of the Rule as applied to our customers.

In addition to our conflict minerals statement, our Conflict Minerals Policy, adopted on May 6, 2014, is available on our website, https://www.nordson.com/en/our-company/ethics-and-compliance/conflict-minerals. In conjunction with the adoption of the Conflict Minerals Policy, we revised our Supplier Code of Ethics, which outlines the ethical standards with which we expect our suppliers to comply, to reflect our expectations that our suppliers procure materials from sources that do not directly or indirectly support non-state armed groups. The Conflict Minerals Policy and Supplier Code of Ethics have been distributed to our suppliers.

Reasonable Country of Origin Survey Process
We evaluated our products and determined that certain products manufactured during calendar year 2021 were manufactured with materials or components that contain, or likely contain, conflict minerals, i.e., tin, tantalum, tungsten and gold, that are necessary to the functionality or production of those products. The areas of conflict mineral usage within our supply chain were identified based on the results of previous surveys. Future surveys will focus efforts on these areas.

We identified in-scope suppliers that we believed provided materials or components containing conflict minerals. Based on commodity analysis, responses from prior years, and a focus on the highest spend suppliers, 29% of our total direct material spend was classified as in-scope. Given the size and complexity of our supply chain, we focused on our largest suppliers, ranked by the amount that we paid to each supplier.

We surveyed our suppliers utilizing the CMRT and our supplier portal, Nordson’s Supply Chain Central (SCC). The SCC software was used by the majority of product lines to automate surveying our suppliers, and to collect and analyze the survey data. Suppliers were provided training materials on the SCC website regarding conflict minerals and the CMRT.

As part of our grievance mechanism, we rely on RMI to provide us with information regarding grievances shared among group members, and we encourage our suppliers to send inquiries or other information concerning conflict minerals to productcompliance@nordson.com.

For the period covered by this Report, we prioritized collection of responses from in-scope suppliers representing approximately 29% of our total direct material spend. For this group of suppliers, we had about an 90% response rate. Based on the information obtained pursuant to the reasonable country of inquiry process described above, we do not have sufficient information to determine the country of origin of all of the conflict minerals in our supply chain. We continue to work to improve our reasonable country of origin process as described in more detail below.







OECD Step 2 – Identify and assess risk in the supply chain
An escalation process was initiated with those surveyed suppliers who continued to be nonresponsive after the above contacts were made, or whose initial (or subsequent) response was not complete or otherwise warranted clarification or confirmation. We evaluated responses from the surveyed suppliers for plausibility, consistency, and gaps both in terms of which materials or components were stated to contain or not contain conflict minerals and the origin of such conflict minerals. We will be engaging certain surveyed suppliers, holding discussions and reviewing the results of their internal due diligence efforts, to ensure that our inquiries regarding conflict minerals were understood and complied with.

III. Due Diligence Framework
Our due diligence process has been designed to conform, in all material respects relevant to the disclosure requirements under the Rule, with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

IV. Due Diligence Undertaken
OECD Step 3 – Design and implement a strategy to respond to identified risks
We supported audits of conflict mineral smelters and refiners conducted by third parties through our participation in the RMI. Suppliers were evaluated based on their smelter and refiner information obtained from CMRT declarations. If supplier information indicated that they used conflict minerals from the Democratic Republic of the Congo, including Angola, Burundi, Central African Republic, the Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (collectively, the “Covered Countries”), then we used the flagship program of the RMI, the Responsible Minerals Assurance Process (RMAP) and general public information to determine a smelter or refiner’s conflict minerals program status.

If, through our smelters lists, we discover that certain of our products contain conflict minerals that finance or benefit armed groups in the Covered Countries, or we cannot definitively deem a product to be free of conflict minerals that finance or benefit armed groups in the Covered Countries, we will analyze the adverse impact of this determination pursuant to the standards set forth in our Conflict Minerals Policy and Supplier Code of Ethics.
Findings regarding the compiled supply chain information through the processes described above will be reported to our executive officer committee. Identified areas of risk in our supply chain will be subject to a risk management plan developed pursuant to our Supplier Code of Ethics and Conflict Minerals Policy. Such risk management plan may include continuing trade throughout the course of measurable risk mitigation efforts, temporarily suspending trade while pursuing ongoing measurable risk mitigation, or disengaging with a supplier after failed attempts at mitigation or where we deem risk mitigation not feasible or unacceptable.

Once our risk management plan is implemented, we will track performance of our risk mitigation efforts and report the results back to our executive officer committee. For risks requiring additional mitigation, or after a change of circumstances, we will undertake additional fact and risk assessments.

V.Results of Due Diligence Undertaken
OECD Step 4 – Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
We will rely on third party assurances and certifications. For example, if a supplier provides the name of a smelter or source mine, we would compare that reply to the listing of smelters from the RMI thereby relying on the program’s processes.

OECD Step 5 – Report on supply chain due diligence
We have taken the information gathered through the above-described due diligence process and compiled this Report. In the future, we will take such information and compile it in a Report or in our specialized disclosure report as required by the Rule, whichever is applicable.

We have not identified any occurrence where our conflict mineral sourcing has directly or indirectly financed or benefited armed groups in the Covered Countries.

VI.Smelter and Refiner Disclosures
Schedule 1 lists the RMI verified smelters and refiners identified by collection of supplier conflict mineral reporting templates where sourcing is unknown. Please note these reported smelters and refiners have not been verified as contributing to components or parts that are in our products.

Schedule 2 lists the countries of the direct and indirect sourcing for conformant smelters reported by the RMI.

VII.Future Improvements
We intend to undertake the following steps during the next compliance period:
Continue to collect conflict minerals information from all suppliers included in our conflict mineral survey process.
Strive to improve the response rate from our suppliers.
Continue to engage with relevant trade associations to define and improve best practices.
Continue to support the RMI through our membership and participation in monthly meetings.
Direct suppliers to the RMI organization for information.





Schedule 1

IDMetalReferenceCountry
CID000103GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEY
CID000180GoldCaridadMEXICO
CID000197GoldYunnan Copper Industry Co., Ltd.CHINA
CID000281TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINA
CID000309TinPT Aries Kencana SejahteraINDONESIA
CID000343GoldDaye Non-Ferrous Metals Mining Ltd.CHINA
CID000493GoldJSC Novosibirsk RefineryRUSSIAN FEDERATION
CID000522GoldRefinery of Seemine Gold Co., Ltd.CHINA
CID000651GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINA
CID000671GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINA
CID000767GoldHunan Chenzhou Mining Co., Ltd.CHINA
CID000773GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINA
CID000778GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OF
CID000927GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATION
CID000929GoldJSC UralelectromedRUSSIAN FEDERATION
CID000942TinGejiu Kai Meng Industry and Trade LLCCHINA
CID000956GoldKazakhmys Smelting LLCKAZAKHSTAN
CID001029GoldKyrgyzaltyn JSCKYRGYZSTAN
CID001032GoldL'azurde Company For JewelrySAUDI ARABIA
CID001056GoldLingbao Gold Co., Ltd.CHINA
CID001058GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINA
CID001093GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINA
CID001204GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATION
CID001305TinNovosibirsk Tin CombineRUSSIAN FEDERATION
CID001326GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATION
CID001362GoldPenglai Penggang Gold Industry Co., Ltd.CHINA
CID001386GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATION
CID001421TinPT Belitung Industri SejahteraINDONESIA
CID001428TinPT Bukit TimahINDONESIA
CID001457TinPT Panca Mega PersadaINDONESIA
CID001486TinPT Timah NusantaraINDONESIA
CID001493TinPT Tommy UtamaINDONESIA
CID001546GoldSabin Metal Corp.UNITED STATES OF AMERICA
CID001562GoldSamwon Metals Corp.KOREA, REPUBLIC OF
CID001619GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINA
CID001756GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATION
CID001810GoldSuper Dragon Technology Co., Ltd.TAIWAN, PROVINCE OF CHINA
CID001909GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINA
CID001947GoldTongling Nonferrous Metals Group Co., Ltd.CHINA
CID002015TinVQB Mineral and Trading Group JSCVIET NAM
CID002180TinTin Smelting Branch of Yunnan Tin Co., Ltd.CHINA
CID002282GoldMorris and WatsonNEW ZEALAND
CID002312GoldGuangdong Jinding Gold LimitedCHINA
CID002313TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINA
CID002455TinCV Venus Inti PerkasaINDONESIA
CID002478TinPT Tirus Putra MandiriINDONESIA
CID002515GoldFidelity Printers and Refiners Ltd.ZIMBABWE



CID002525GoldShandong Humon Smelting Co., Ltd.CHINA
CID002527GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINA
CID002562GoldInternational Precious Metal RefinersUNITED ARAB EMIRATES
CID002563GoldKaloti Precious MetalsUNITED ARAB EMIRATES
CID002567GoldSudan Gold RefinerySUDAN
CID002570TinCV Ayi JayaINDONESIA
CID002572TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAM
CID002573TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAM
CID002574TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAM
CID002584GoldFujairah Gold FZCUNITED ARAB EMIRATES
CID002587GoldIndustrial Refining CompanyBELGIUM
CID002588GoldShirpur Gold Refinery Ltd.INDIA
CID002703TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAM
CID002708GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICA
CID002756TinSuper LigasBRAZIL
CID002816TinPT Sukses Inti MakmurINDONESIA
CID002850GoldAU Traders and RefinersSOUTH AFRICA
CID002852GoldGGC Gujrat Gold Centre Pvt. Ltd.INDIA
CID002853GoldSai RefineryINDIA
CID002857GoldModeltech Sdn BhdMALAYSIA
CID002858TinModeltech Sdn BhdMALAYSIA
CID002865GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATION
CID002867GoldDegussa Sonne / Mond Goldhandel GmbHGERMANY
CID002872GoldPease & CurrenUNITED STATES OF AMERICA
CID002893GoldJALAN & CompanyINDIA
CID003153GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIA
CID003185GoldAfrican Gold RefineryUGANDA
CID003186GoldGold Coast RefineryGHANA
CID003208TinPongpipat Company LimitedMYANMAR
CID003324GoldQG Refining, LLCUNITED STATES OF AMERICA
CID003348GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATES
CID003356TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINA
CID003382GoldCGR Metalloys Pvt Ltd.INDIA
CID003383GoldSovereign MetalsINDIA
CID003397TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINA
CID003409TinPrecious Minerals and Smelting LimitedINDIA
CID003410TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINA
CID003416TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATION
CID003421GoldC.I Metales Procesados Industriales SASCOLOMBIA
CID003427TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZIL
CID003449TinPT Mitra Sukses GlobalindoINDONESIA
CID003461GoldAugmont Enterprises Private LimitedINDIA
CID003463GoldKundan Care Products Ltd.INDIA
CID003486TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZIL
CID003487GoldEmerald Jewel Industry India Limited (Unit 1)INDIA
CID003488GoldEmerald Jewel Industry India Limited (Unit 2)INDIA
CID003489GoldEmerald Jewel Industry India Limited (Unit 3)INDIA
CID003490GoldEmerald Jewel Industry India Limited (Unit 4)INDIA
CID003497GoldK.A. RasmussenNORWAY



CID003500GoldAlexy MetalsUNITED STATES OF AMERICA
CID003529GoldSancus ZFS (L’Orfebre, SA)COLOMBIA
CID003540GoldSellem Industries Ltd.MAURITANIA
CID003548GoldMD OverseasINDIA
CID003553TungstenArtek LLCRUSSIAN FEDERATION
CID003557GoldMetallix Refining Inc.UNITED STATES OF AMERICA
CID003612TungstenOOO “Technolom” 2RUSSIAN FEDERATION
CID003614TungstenOOO “Technolom” 1RUSSIAN FEDERATION
CID003615GoldWEEEREFININGFRANCE
CID003617GoldValue TradingBELGIUM


Schedule 2

Andorra, Angola, Antigua and Barbuda, Argentina, Australia, Austria, Bahamas, Bangladesh, Barbados, Belarus, Belgium, Benin, Bolivia, Brazil, Bulgaria, Burundi, Canada, Cayman Islands, Chile, China, Colombia, Croatia, Cuba, Curacao, Cyprus, Czechia, Democratic Republic of the Congo , Denmark, Dominica, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Finland, France, Gabon, Germany, Ghana, Grenada, Greece, Guatemala, Guernsey, Guinea, Guyana, Honduras, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Laos, Latvia, Lebanon, Libya, Lithuania, Luxembourg, Madagascar, Malaysia, Malta, Mexico, Monaco, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Norway, Pakistan, Panama, Peru, Philippines, Poland, Portugal, Puerto Rico, Qatar, Romania, Russia, Russian Federation, Rwanda, Saint Kitts and Nevis, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Sint Maarten, Slovakia, Slovenia, South Africa, South Korea, Spain, St Vincent and Grenadines, Sudan, Swaziland, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Turks and Caicos, Uganda, Ukraine, United Arab Emirates, United Kingdom, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Virgin Islands, Yemen, Zimbabwe