Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Section 13(p) of the Securities Exchange Act of 1934 and Rule 13p-1 thereunder (collectively,
the conflict mineral rules) require certain disclosures concerning supply sources for conflict minerals consisting of gold, tin, tungsten, or tantalum that may be necessary to the manufacture or functionality of a
companys products. Terms and phrases used but not defined in this disclosure have the meanings given under the conflict mineral rules.
No conflict mineral is intentionally added to, or serves as a functional component of, products sold by Imperial. However, the manufacturing
process for certain of Imperials refined petroleum and petrochemical products utilizes catalysts which include tin, tungsten, or gold compounds as active ingredients. Depending on the type of catalysis process used, trace amounts of such
minerals may exist in some of our finished products.
We understand staff of the U.S. Securities and Exchange Commission
(SEC) has previously issued oral guidance that conflict mineral compounds are not subject to reporting under the conflict mineral rules. However, in the absence of affirmative written SEC guidance on this point Imperial has conducted in
good faith a reasonable country of origin inquiry regarding the conflict minerals described above for 2021. Such inquiry is reasonably designed to determine whether any of these minerals originated in the Democratic Republic of the Congo or an
adjoining country (the covered countries), or are from recycled or scrap sources.
The tin, tungsten, or gold catalysts used
by Imperial in 2021 were purchased from third party suppliers. Imperials country of origin inquiry includes obtaining from each of these suppliers for catalysts containing tin, tungsten, or gold compounds an annual written declaration in the
form of the Conflict Minerals Reporting Template (CMRT) promulgated by the Responsible Minerals Initiative (RMI). Our contracts with each of these catalyst suppliers also require the suppliers to have and maintain procedures
reasonably designed to ensure that all conflict minerals necessary to the functionality of products manufactured by the supplier or contracted by the supplier to be manufactured that are sold to Imperial will be conflict free.
With respect to products we manufactured or contracted to manufacture in 2021, we have obtained completed CMRT declarations from each of our
five third party suppliers of catalysts containing tin, tungsten, or gold compounds.
All applicable suppliers certified that the gold
used in their catalysts did not originate in the covered countries. Based on these inquiries, we conclude that, with respect to catalysts containing gold compounds which were used in the manufacture of products by Imperial in 2021, such minerals did
not originate in the covered countries.
Four of the five suppliers certified that the tin or tungsten used in their catalysts did not
originate in the covered countries. Based on these inquiries, we conclude that, with respect to catalysts containing tin or tungsten compounds from these suppliers which were used in the manufacture of products by Imperial in 2021, such minerals did
not originate in the covered countries.
One supplier indicated in their CMRT declaration that some of the smelters in their respective
supply chains source tin and/or tungsten from the covered countries (the covered country declarations). This suppliers covered country declaration represented that any covered country smelters or refiners used in the
suppliers supply chain in 2021 were conformant within the meaning of the RMI standards. Under RMI definitions, conformant means smelters and refiners that have successfully completed an assessment against the applicable
Responsible Minerals Assurance Process (RMAP) or an equivalent
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