Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of Ecovyst Inc. (the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2022 to December 31, 2022 (the “Reporting Period”). The Rule implements reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). Conflict minerals are defined by the United States Securities and Exchange Commission (the “SEC”) as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are currently limited to tantalum, tin, and tungsten (the “Conflict Minerals”). The Rule imposes certain reporting obligations on SEC registrants that manufacture or contract to manufacture products for which Conflict Minerals are necessary to the functionality or production of those products and contained in the finished products. The Rule requires that SEC registrants conduct in good faith a reasonable country of origin inquiry designed to determine whether any such necessary Conflict Minerals originated in the Democratic Republic of the Congo or “adjoining countries” (as defined by the SEC) (collectively, the “Covered Countries”) or are from recycled or scrap sources.
The Company reviewed the finished products that it and its subsidiaries manufactures either internally or pursuant to arrangements with third-party manufacturers during the Reporting Period (the “Product Review”). The objective of the Product Review was to identify finished products that the Company and its subsidiaries manufactures or contracts to manufacture that may contain one or more Conflict Minerals. In this effort, the Director of Product Stewardship of the Company routinely evaluated and verified the source and use of raw materials purchased and used by the Company and its subsidiaries globally to determine whether any Conflict Minerals used in the Company’s and its subsidiaries’ products are sourced from Covered Countries or are from recycled or scrap sources. The Company has determined that Conflict Minerals are contained in, and are necessary to the functionality or production of, certain finished products that contain silicotungstic acid, which is a tungsten compound, and tantalum chloride, which is a tantalum compound. The Company’s Catalyst Technologies division purchased limited amounts of such tungsten and tantalum compounds (in the aggregate an amount less than 0.01% of their respective overall raw material spend), which are used as raw materials to manufacture, and are contained in, certain catalyst products (the “Covered Products”).
As a result of such determination, and in accordance with the Dodd-Frank Act and the Rule, the Company conducted in good faith a reasonable country of origin inquiry as to the tungsten and tantalum compounds contained in the Covered Products by seeking a certification from the direct, exclusive suppliers of such compounds (the “Covered Suppliers”). The Covered Suppliers have provided the Company with signed certifications of the name and location of each smelter from which the Covered Suppliers source the tungsten used in producing the tungsten compound and the tantalum used in producing the tantalum compound that are contained in the Covered Products (the “Supplier Certifications”). According to the Supplier Certifications, none of the tungsten or tantalum contained in the Covered Products were sourced from smelters in any Covered Country.
Based on the results of its reasonable country of origin inquiry, and its review of the information and the Supplier Certifications, the Company has no reason to believe that the tungsten and tantalum contained in the Covered Products may have originated in any of the Covered Countries or may not be from recycled or scrap sources.
This conflict minerals disclosure is publicly available on the Company’s website at https://investor.ecovyst.com/management-governance/governance-documents.
Item 1.02 Exhibit
Not applicable.
Section 2 – Exhibits
Item 2.01 Exhibits
Not applicable.
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