Exhibit 1.01 - OMGroup-2014CMR

This Conflict Minerals Report (“Report”) for the year ended December 31, 2014 is presented to comply with Conflict Minerals Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Conflict Minerals Rule” or “Rule”). The Conflict Minerals Rule was adopted by the Securities and Exchange Commission (“SEC”) related to minerals currently defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (collectively, “conflict minerals” or “3TG”) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). The Conflict Minerals Rule imposes certain reporting and disclosure obligations on SEC registrants whose manufactured or contracted for manufacture products contain 3TG which are necessary to the functionality or production of their products.

If a registrant can establish that its necessary 3TG originated from sources other than the Democratic Republic of the Congo or an adjoining country (“covered countries”), or are from recycled and scrap sources, it must submit a Form SD which describes its reasonable country of origin inquiry (“RCOI”). If a registrant has reason to believe that any of its necessary 3TG may have originated in the covered countries and that they may not be from recycled or scrap sources, then the registrant must exercise due diligence on the 3TG source and chain of custody. As long as it is covered by the Rule, the registrant must annually submit a report to the SEC that includes a description of its RCOI and, if applicable, its due diligence measures.

This Report has been prepared by OM Group, Inc. (herein referred to as “OM Group,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries and entities that we are required to consolidate for financial statement purposes. It does not include the activities of entities that we are not required to consolidate. We conducted an analysis to determine if our products contained necessary 3TG for the period reported. Our data supported the conclusion that certain products contained necessary 3TG for the period ending December 31, 2014.

OM Group purchases raw materials in the form of unprocessed, non-engineered powders and liquids that we use to manufacture our products, and components in the form of subassemblies that are combined with other items to manufacture our products. The Company has determined that the products of two of its business units (Advanced Organics and Electronic Chemicals) are not subject to the Conflict Minerals Rule because it purchases compounds and catalysts that contain 3TG and does not purchase 3TG otherwise. Certain SEC comments in the SEC Release No. 34-67716 issued on August 22, 2012, language from SEC reply briefs in the ongoing legal challenge to the Rule, and the posting by the SEC of a letter drafted by counsel to certain industry groups memorializing a conversation with the SEC on this topic suggest that these organic compounds and catalysts, which are chemically distinct from 3TGs, are not within the scope of the conflict minerals rule. We do not purchase directly from mines or smelters. We rely on our direct suppliers to provide information on the origin of the 3TG contained in raw materials and components supplied to us - including sources of 3TG that are supplied to them from upstream suppliers.

Our approach was to conduct a survey of the suppliers who sell us raw materials or components containing 3TG. We were unable to determine the country of origin of all the 3TG in our products. For that reason, we performed due diligence measures to determine the source and chain of custody of those 3TG and submitted this Report as an Exhibit to our Form SD. Because of the diversity of our products, the complexity of our products, and the depth, breadth, and intricacy of our supply chain, it is difficult to

In accordance with the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2^nd edition) and the related OECD Supplement on Tin, Tantalum and Tungsten as well as the OECD Supplement on Gold (collectively, the “OECD Guidance”) and the Conflict Minerals Rule, this Report is made publicly available on our website www.omgi.com under “Investor Relations/Corporate Governance/Conflict Minerals.” The content of any website referred to in this Report is not incorporated by reference in this Report.

We adopted a Conflict Minerals Policy (“Policy”) in 2013. The Policy communicates OM Group’s commitment to sourcing raw materials and components from companies that share our values around human rights, ethics and environmental responsibility. The Policy also communicates OM Group’s commitments to meeting the goals and objectives of the Conflict Minerals Rule. For additional information about our commitment to responsible sourcing and other human rights, see our Code of Conduct and Ethics, our Human Rights Policy and our Conflict Minerals Policy on our website at: www.omgi.com under “Investor Relations/Corporate Governance.”

We made inquiries of our suppliers of our necessary conflict minerals (individually a “3TG Supplier” and collectively “3TG Suppliers”) by using a standardized survey template developed by the Conflict-Free Sourcing Initiative (“CFSI”), known as the Conflict Minerals Reporting Template (“CFSI Template”) to gather data about the 3TG Suppliers’ source of 3TG. We sent a CFSI Template to our 3TG Suppliers together with information about the Conflict Minerals Rule and referred them to further guidance on the Electronic Industry Citizenship Coalition (“EICC”) and CFSI websites. Responses from the 3TG Suppliers came to us in the form of completed CFSI Templates and correspondence.

We reviewed and analyzed survey responses for accuracy and completeness. Initial survey results indicated that OM Group purchased 3TG from at least one smelter which may source 3TG from the covered countries. Since we have reason to believe that some of our 3TG may come from the covered countries, we are required to perform due diligence on the source and chain of custody of such conflict minerals.

Our due diligence measures were designed to conform, in all material respects, to the framework in the OECD Guidance. The OECD Guidance provides a framework for us to analyze our 3TG supply chain by engaging directly with our 3TG Suppliers, asking specific questions relating to the source and chain of custody of their 3TG, thoughtfully reviewing supplier responses, and specifically identifying red flags that could require additional follow up with the 3TG Suppliers.

We have a conflict minerals team at the corporate office and at each business segment to address our use of conflict minerals (the “Conflict Minerals Team”). At the corporate office, the Conflict Minerals Team included members of internal audit, finance and the legal department. At our business segments, the

Conflict Minerals Team included on-site legal, purchasing, quality control and environmental, health and safety personnel. The business segment members of the Conflict Minerals Team were responsible for implementing our conflict minerals compliance and were led by senior managers at each business segment.

As we do not have direct relationships with 3TG smelters, we rely upon the following industry-wide initiatives to gather information on upstream 3TG Suppliers in our supply chain: the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative’s (EICC-GeSI) Conflict-Free Sourcing Initiative (CFSI), the ITRI Tin Supply Chain Initiative (iTSCi) and the Public-Private Alliance for Responsible Minerals Trade (PPA) (the “Industry-Wide Initiatives”).

Our Code of Conduct and Ethics outlines several ways to report non-compliance with all company policies, and it is published on our website at www.omgi.com. Reports of compliance shortfall can be directed to our Lead Director, whose contact information is set forth in the Code of Conduct and Ethics. Employees can also use our company-wide anonymous reporting tool which is communicated in local languages to employees, posted on our internal website and referenced in the Code of Conduct and Ethics. We encourage a culture of compliance by publicly providing the high-level mechanism for non-employees to reach our leaders and by making the anonymous reporting tool available to our employees.

We have record retention requirements in place for all compliance programs, and we have communicated these retention requirements to our Conflict Minerals Team. Our record retention schedule is also posted on our internal website available to all employees. We will retain conflict minerals related records for at least five (5) years in accordance with the OECD Guidance.

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify suppliers upstream from our direct suppliers. We rely on the Industry-Wide Initiatives to help us do so. We sent a CFSI Template to our 3TG Suppliers, provided detailed information about the Conflict Minerals Rule and referred them to compliance guidance on the EICC and CFSI websites.

In 2013, the Conflict Minerals Team identified specific red flags set forth in the OECD Guidance that we believed were relevant to our business segments, and then created a document to guide our business personnel when reviewing 3TG Supplier responses. Members of the Conflict Minerals Team at each business segment examined each survey submitted by a 3TG Supplier, scrutinized it for inaccuracies, inconsistencies and the red flags set forth in our written guidance. Reviewers then followed up on

inconsistencies and red flags. Executive management was briefed about the results of our compliance efforts on a regular basis. We used the review process to identify which 3TG Suppliers needed to provide additional information, and then worked directly with those suppliers to obtain more detailed responses.

The business segment members of the Conflict Minerals Team compiled a smelter list from the information they received from our 3TG Suppliers. The CFSI sponsors a Conflict-Free Smelter Program (“CFSP”) which maintains list of smelters that have systems in place to assure sourcing of only conflict-free materials. The Conflict Minerals Team cross-referenced their smelter list against the CFSP list published on the CFSI website, specifically concentrating on those 3TG Suppliers who may have purchased 3TG from covered countries.

In response to our risk assessment described in Section 3.2(b) above, we continued the implementation of a risk management plan, through which the Conflict Minerals compliance program was designed, and is managed and monitored. Updates on the compliance program were provided quarterly to executive management.

We also relied on the Industry-Wide Initiatives by using the CFSI Template to gather data from our 3TG Suppliers, by referring suppliers to the EICC and CFSI websites for compliance guidance, FAQs and educational materials, and by using the CFSP to help us determine which of our smelters source conflict-free 3TG.

As part of our risk management plan, we have taken steps to ensure that our Company, our suppliers and our customers understand the Conflict Minerals Rule, reporting obligations under the Rule and our expectations regarding OM Group’s 3TG supply chain. Members of the Conflict Minerals Team have attended multiple training sessions in order to become familiar with the requirements of the Conflict Minerals Rule. We have consulted with professional advisors about, and we have undertaken independent research of, our requirements to comply with the Rule and we receive regular legal and regulatory updates concerning the Rule from our professional advisors. We have delivered guidance and training on the Conflicts Minerals Rule to the business segment members of our Conflicts Mineral Team. Executive management and our Board of Directors have been provided with regular updates on the structure and progress of our compliance program.

Our expectations under our risk management plan have been conveyed to our suppliers and we have educated them on the requirements of the Conflict Minerals Rule, by circulating the CFSI Template, by providing them access to additional resources available on the EICC and CFSI websites, and by disseminating our Policy. Our Policy is publicly available on our external website at www.omgi.com under “Investor Relations/Corporate Governance/Conflict Minerals.” As described in our Policy, we encourage our 3TG Suppliers who supply us with conflict minerals to establish a source of 3TG that does not support conflict and we encourage our suppliers to extend the policy to their suppliers.

We do not typically have a direct relationship with 3TG smelters, and we do not perform or direct audits of these entities within our supply chain. We support audits conducted by third parties by urging our 3TG Suppliers to gather information from their suppliers in order to accurately complete the CFSI Template.

Based on supplier responses to our CFSI Template, the 3TG Suppliers that responded on a product or user defined level were not able to identify a specific smelter or refiner that processed the necessary 3TG in our products. Accordingly, despite our due diligence efforts and engagement with our 3TG Suppliers, we do not have sufficient information to identify the facilities used to process the necessary 3TG in our products.

Of those 3TG Suppliers that responded on a product or user defined level, they did not trace the necessary 3TG in our products to a particular country of origin. Accordingly, despite our due diligence efforts and engagement with our 3TG Suppliers, we do not have sufficient information to identify the countries of origin used to process the necessary 3TG in our products

We have determined that seeking information about 3TG smelters from our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain. We have asked our 3TG Suppliers to provide us the information we need to make this assessment. We have requested that they ask their suppliers to do the same. We look to the OECD Guidance and the CFSP program to help us structure these efforts.

Certain statements contained in this Report, including those made under the “Steps Taken and Being Taken to Mitigate Risk” section, reflect the Company’s expectations with respect to future performance and constitute “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. Forward-looking statements include, among other things, statements of the plans and objectives of management for future operations. These statements are subject to a variety of uncertainties, unknown risks and other factors concerning the Company’s operations and business environment, which are difficult to predict and are beyond the control of the Company. Factors that could adversely affect our future performance include (1) those described under the heading “Risk Factors” in Item 1A of Part I of our Annual Report on Form 10-K for the year ended December 31, 2014, (2) the outcome of the current legal challenge to the Rule, (3) the responsible sourcing of conflict minerals in our supply chain by our direct and indirect suppliers and (4) the effectiveness of traceability systems used by our direct and indirect suppliers to determine the source and chain of custody of conflict minerals contained in our supply chain.


•	We expect to continue supplier communications to help them understand the requirements of the Conflict Minerals Rule and to explain our compliance program.


•	Provide our 3TG Suppliers with additional educational and training resources to increase the response rate and improve the quality of the responses, as needed.


(a)	Establish Strong Company Management Systems


i)	Internal Teams


ii)	Control systems


iii)	Supplier Engagement