Exhibit 1.01
Newell Brands Inc.
Conflict Minerals
Report For The Year Ended December 31, 2023
This Conflict Minerals Report (the Report) of Newell Brands Inc. (the
Company) for the calendar year ended December 31, 2023 is provided in accordance with Rule 13p-1 (the Rule) under the Securities Exchange Act of 1934 (the 1934 Act),
the instructions to Form SD, and the Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule issued by the Division of Corporation Finance of the Securities and Exchange Commission (the SEC) on
April 7, 2017 (the SEC Statement) and together with the Rule, Form SD, 1934 Act Release No. 34-67716 and other guidance promulgated by the SEC (the CMR Regulations). Please
refer to the Rule, Form SD and the 1934 Act Release No. 34-67716 for definitions of the terms used in this Report, unless otherwise defined herein.
This Report outlines the steps the Company undertook in accordance with the CMR Regulations in connection with the existence of Conflict Minerals (as defined
below) in products the Company manufactured or contracted to manufacture. The Companys diligence measures were designed to adhere, in all material respects, to the internationally-recognized framework in the OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold and for tin, tantalum and tungsten (Third Edition OECD 2016) (the OECD Framework) for supply chain diligence relating
to columbite-tantalite (coltan), cassiterite, gold, and wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, Conflict Minerals).
1. Company Overview
Newell Brands Inc. (the
Company or Newell Brands) is a leading global consumer goods company with a strong portfolio of well-known brands, including Rubbermaid, Sharpie, Graco, Coleman, Rubbermaid Commercial Products, Yankee Candle, Paper Mate,
FoodSaver, Dymo, EXPO, Elmers, Oster, NUK, Spontex and Campingaz. Newell Brands is focused on delighting consumers by lighting up everyday moments. The Company sells its products in over 150 countries around the world and has operations on the
ground in over 40 of these countries, excluding third-party distributors.
Organizational Structure
The Companys three primary operating segments are as follows:
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Segment |
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Key Brands |
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Description of Primary Products |
Home and Commercial Solutions |
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Ball(1), Calphalon, Crockpot, FoodSaver, Mapa, Mr. Coffee, Oster, Rubbermaid, Rubbermaid Commercial Products, Sistema, Spontex, Sunbeam, WoodWick and Yankee Candle |
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Commercial cleaning and maintenance solutions; closet and garage organization; hygiene systems and material handling solutions; household products, including kitchen appliances, food and home storage products, fresh preserving
products, vacuum sealing products, gourmet cookware, bakeware and cutlery and home fragrance products |
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Learning and Development |
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Dymo, Elmers, EXPO, Graco, NUK, Paper Mate, Parker and Sharpie |
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Baby gear and infant care products; writing instruments, including markers and highlighters, pens and pencils; art products; activity-based products and labeling solutions |
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Outdoor and Recreation |
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Campingaz, Coleman, Contigo and Marmot |
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Active lifestyle products for outdoor and outdoor-related activities; technical apparel and on-the-go beverageware |
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and Ball® TM of Ball Corporation, used under license. |
Supply Chain
The Company
manufactures some of its products and leverages third party suppliers for some of its other products and components. In both cases, the Companys position in the supply chain is several levels removed from the actual sourcing of Conflict
Minerals. The Company does not make purchases of raw ore or unrefined Conflict Minerals from the Democratic Republic of Congo or an adjoining country as defined in Form SD (collectively, the Covered Countries), nor does the
Company source any products or components directly from the Covered Countries. As a result, the Company must rely upon its suppliers, and their multiple sub-suppliers, for information related to Conflict
Minerals that may be contained in products the Company sells.
Due to the breadth of the Companys products and global reach of its
business, the Company has a complex supply chain that includes over 1,800 direct and sourced finished good suppliers. The procurement of materials and finished goods is managed by global procurement teams consisting of over 225 employees who oversee
local and regional sourcing and supplier arrangements. Other key factors that increase the complexity of the Companys efforts to gather information from within the supply chain include the following:
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A significant portion of the Companys suppliers are located in Asia, and many of these suppliers may not
yet have management systems to address the implications of the CMR Regulations. In addition, relatively few of the Companys suppliers are registrants with the SEC. As a result, the Company provided suppliers with support in order to develop
their understanding of the CMR Regulations. |
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As noted above, due to the nature of the Companys products and manufacturing processes, the Companys
direct suppliers tend to be several levels removed from the smelters processing minerals that may be present in the products manufactured or contracted to be manufactured by the Company. This necessitates a significant portion of the Companys
suppliers to engage in their own extensive due diligence efforts in order to provide information requested by the Company. |