SEC Form SD filed by Minerals Technologies Inc.

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

SECTION 1 – CONFLICT MINERALS DISCLOSURE

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure – Reasonable Country of Origin Inquiry

(a)  Minerals Technologies Inc. (together with its subsidiaries, “MTI”) is a leading, technology-driven specialty minerals company that develops, produces, and markets a broad range of mineral and mineral-based products, related systems and services.  MTI serves globally a wide range of consumer and industrial markets, including household and personal care, paper and packaging, food and pharmaceutical, automotive, construction, steel and foundry, environmental, and infrastructure.  This Form SD is filed by MTI pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the period from January 1, 2024 to December 31, 2024 (the “Reporting Period”).

Under Rule 13p-1, MTI is required to determine whether any conflict minerals are necessary to the functionality or production of a product it manufactures or contracts to manufacture and, if so, to conduct, in good faith, a “reasonable country of origin inquiry” that is reasonably designed to determine whether any of those conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) or is from recycled or scrap sources.  The Securities and Exchange Commission defines conflict minerals as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, and any other mineral or its derivative determined by the U.S. Secretary of State to be financing conflict in a Covered Country (“Conflict Minerals”).

MTI conducted an evaluation of its product lines sold during the Reporting Period and determined that (i) its Pyroid® HT thermal management material product (“Pyroid Product”) contains small amounts of gold that is necessary to the functionality of the Pyroid Product, and (ii) its CETSEAL® and HYDROFIX® products (“Environmental and Building Material Products”) contain small amounts of tin that is necessary to the functionality of the Environmental and Building Material Products.  Other than the foregoing, MTI does not believe any of its other products manufactured (or contracted by MTI to be manufactured) and sold in the Reporting Period contained any Conflict Minerals.

(b)  MTI determined that the gold used in its Pyroid Product was purchased from two suppliers during the Reporting Period.  MTI conducted in good faith a reasonable country of origin inquiry that was reasonably designed to determine whether the gold used in the Pyroid Product originated in a Covered Country or is from recycled or scrap sources.  This inquiry included communications with MTI’s suppliers of gold.  As a result, MTI received and reviewed a completed Responsible Minerals Initiative Conflict Minerals Reporting Template (“RMI CMRT”) and certification from both suppliers that none of the gold supplied originates in a conflict region.

In addition, MTI determined that the tin used in its Environmental and Building Materials Products was purchased from two suppliers during the Reporting Period.  MTI conducted in good faith a reasonable country of origin inquiry that was reasonably designed to determine whether the tin used in the Environmental and Building Materials Products originated in a Covered Country or is from recycled or scrap sources.  This inquiry included communications with MTI’s suppliers of the product containing tin.  One supplier provided MTI with a completed RMI CMRT, which MTI reviewed.  Such RMI CMRT certified that its supplier has provided a Conflict-free declaration.  The other supplier provided a statement from its raw material provider that all tin containing products are entirely manufactured from raw material that is classified as DRC Conflict Free.

This Specialized Disclosure Form is being posted to the publicly available Internet site (https://investors.mineralstech.com/sec-filings) upon the filing of this Form SD.