Exhibit 1.01
Neogen Corporation
Conflict Minerals Report
2024
Company Overview
Neogen Corporation develops, manufactures and markets a diverse line of products and services dedicated to food and animal safety. Our Food Safety segment consists primarily of diagnostic test kits and complementary products (e.g., culture media) sold to food producers and processors to detect dangerous and/or unintended substances in human food and animal feed, such as foodborne pathogens, spoilage organisms, natural toxins, food allergens, genetic modifications, ruminant by-products, meat speciation, drug residues, pesticide residues and general sanitation concerns. Our diagnostic test kits are generally easier to use and provide quicker results than conventional diagnostic methods. The majority of the test kits are disposable, single-use, immunoassay and DNA detection products that rely on proprietary antibodies and RNA and DNA testing methodologies to produce rapid and accurate test results. Our expanding line of food safety products also includes genomics-based diagnostic technology, and advanced software systems that help testers to objectively analyze and store their results and perform analysis on the results from multiple locations over extended periods.
Neogen’s Animal Safety segment is engaged in the development, manufacture, marketing and distribution of veterinary instruments, pharmaceuticals, vaccines, topicals, parasiticides, diagnostic products, rodent control products, cleaners, disinfectants, insect control products and genomics testing services for the worldwide animal safety market. The majority of these consumable products are marketed through veterinarians, retailers, livestock producers and animal health product distributors. Our line of drug detection products is sold worldwide for the detection of abused and therapeutic drugs in animals and animal products, and has expanded into the workplace and human forensic markets.
Neogen has determined that 3TG is necessary to the functionality of certain Neogen products, and Neogen must rely on third party suppliers to provide these components. As a result, Neogen has conducted certain reasonable country of origin inquires ("RCOI"), as described below.
Description of Neogen’s Reasonable Country of Origin Inquiry and Due Diligence
Neogen's RCOI was reasonably designed and performed in good faith to determine whether the 3TGs contained in our products originated in the covered countries or were from recycled or scrap sources.
The Company's purchasing and procurement department used technical expertise, component specifications, and previously gathered data to determine the likely presence of 3TGs in components and materials contained in our products.
All suppliers of components or materials containing or possibly containing 3TGs were considered in-scope for our supplier outreach ("relevant suppliers"). The relevant suppliers were asked to electronically report to the Company using the Responsible Minerals Initiative ("RMI") Conflict Minerals Reporting Template ("CMRT"). Neogen requested that relevant suppliers increase their focus on providing complete and accurate smelter and refiner information, and conduct outreach and further due diligence when applicable in accord with the Organization for Economic Co-operation and Development ("OECD") Guidance. Responses to the RCOI provided by relevant suppliers were reviewed for smelter information, completeness, and reasonableness. Based on the results of our RCOI, we were required to conduct due diligence. The design of our due diligence program and activities are described below.
Neogen has designed and implemented a conflict minerals compliance plan. Neogen, in accordance with guidance issued by the OECD, conducts a supply chain assessment based, where appropriate, upon OECD’s established five-step framework: