Exhibit 1.01
Conflict Minerals Report
For the Year Ended December 31, 2024
Introduction
This is the Conflict Minerals Report of Iridex Corporation (the “Company”, “Iridex”, “we” or “our”), filed with the United States Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2024 to December 31, 2024. Rule 13p-1 was adopted by the SEC to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. For the purposes of this Report, “conflict minerals” means cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold.
Supply Chain and Product Overview
We are a leading worldwide provider of therapeutic-based laser systems, delivery devices and consumable instrumentation used to treat sight-threatening eye diseases in ophthalmology.
We rely on third parties to manufacture substantially all of the components used in our products. We assemble critical subassemblies and substantially all of our final products at our facility in Mountain View, California. Materials, components and subassemblies provided by our suppliers and external manufacturers and included in our products are sourced from a global supply base, over which we exercise little, if any, control. We do not directly engage in any mining operations, nor do we purchase raw ore or unrefined conflict minerals. Given its position in the supply chain, we rely on the responses of its suppliers, who in turn rely on the responses of their respective suppliers to identify the mines, smelters and refiners that source the Conflict Minerals. We purchase no components that are integrated directly into or used in the manufacture of our products from any covered country. “Covered countries” means the Democratic Republic of Congo and its adjoining countries, including the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Our senior management consulted with our procurement department to determine, based on, among other things, product lists and documentation provided by suppliers, which of our products would reasonably be expected to contain conflict minerals that are necessary to the functionality or production of those products. Based upon the results of this internal inquiry, we determined that the fabricated anodized or coated metal components, electronic circuit boards, electronic cables, probes or optical lenses in our Glaucoma, Medical Retina and Surgical Retina products (collectively, the “Covered Products”) may contain conflict minerals and that those components are necessary to the functionality or production of those products.
Due Diligence Program
Our due diligence processes and efforts have been developed in conjunction with the second edition of the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains for Minerals from Conflict-Affected and High-Risk Areas and the related Supplements on gold, tin, tantalum and tungsten (the “Framework”). We designed our due diligence process to conform in all material respects with these OECD guidelines.
1.Establishment of Strong Company Management Systems
Our due diligence process was conducted by a cross-functional team comprised of senior executives and supply-chain personnel. The cross-functional team was required to be familiar with our policy with respect to the sourcing of conflict minerals which can be found on the Corporate Governance page of our Web site at www.iridex.com. (The content of any website referred to in this report is included for general information only and is not incorporated by reference in this Report.)
2.Identification and Assessment of Risks in the Supply Chain
We performed in good faith a reasonable country of origin inquiry (“RCOI”) on conflict minerals that were in our supply chain after January 1, 2024, which inquiry was reasonably designed to determine whether suppliers of components of our Covered Products containing conflict minerals sourced them from any covered country or from recycled or scrap sources.
In order to make the RCOI determination, we solicited information from our suppliers regarding the source of the conflict minerals supplied to us during the year ended December 31, 2024, using the template developed jointly by the companies of Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GeSI”), known as the CFSI Reporting Template (the “Template”). The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and the smelters the company and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Alternatively, we requested that suppliers provide a Smelter/Refiner Certification certifying that (1) conflict minerals produced by the supplier for us were obtained from a conflict-free area, (2) the supplier has processes in place to trace materials and products to ensure that conflict minerals contained in products were not mined in conditions of armed conflict and human rights abuses and (3) the supplier maintains a Conflict Minerals Statement/Policy, and a copy of such policy.
We determined that 29 of our suppliers were within the scope of our external RCOI and due diligence inquiry because the parts or components that they supply to us potentially contain conflict minerals. We sent the Template to each of these suppliers, and received responses from 29 of the 29 suppliers
contacted. Our suppliers’ responses to the Template indicated that no conflict minerals that were necessary to the functionality or production of our Covered Products had originated in a covered country. As part of our assessment to determine the source of the conflict minerals that our suppliers supply to us, we sought to identify the smelters from which conflict minerals were obtained by such suppliers and to compare those smelters against the list of smelter facilities that have been identified as “conflict free” by the EICC-GeSI Conflict Free Sourcing (“CFS”) program. The CFS program is a voluntary program whereby an independent third party evaluates smelter procurement activities to determine whether a smelter has sufficiently demonstrated that all materials processed by that smelter originated from sources that do not directly or indirectly finance or benefit armed groups in a covered country. The results of this inquiry are presented below in the Section titled – “Smelters and Refiners”.
3.Designing and implementing a strategy to respond to identified risks
We have taken or intend to take the following steps to improve the due diligence process and to gather additional information which will assist us to determine whether the conflict minerals we utilize benefit armed groups contributing to human rights violations:
oconduct and report annually on supply chain due diligence for the applicable conflict minerals;
oexamine the possibility of establishing new terms and conditions in supplier contracts that stipulate responses to conflict mineral related inquires; and
oattempt to validate supplier responses using information collected via independent conflict free smelter validation programs such as the CFS program.
•Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct business relationship with any smelters or refiners in our supply chain and, as a result, we do not directly conduct or request audits. Instead, we supported the development and implementation of independent third party audits of smelters such as the CFSI by encouraging our suppliers to purchase materials from audited, conflict-free smelters and determine whether the smelters that were used to process these minerals were validated as conflict-free as part of the CFSI. We monitor smelters or refiners certification status with CFSI.
5.Reporting on Supply Chain Due Diligence
In 2025, we publicly filed the Form SD along with this Report with the SEC, and a copy of this Report and the Form SD are publicly available on the Corporate Governance page of our Web site at www.iridex.com.
Smelters and Refiners
Based on the responses in the Templates we determined that we had a total of 431 facilities and smelters that were used by our suppliers to fulfill our demands for conflict minerals. Of these 431 facilities and smelters, we have identified 238 facilities or smelters that are deemed CFSP Compliant, indicating that these smelters or refiners are compliant with the Conflict Free Smelter Program assessment protocols. There are 6 more smelters or refiners that are deemed CFSP Active - Smelters and Refiners on the Active list that have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 187 facilities or smelters listed have not yet been confirmed as Conflict-Free. We base this assessment exclusively on the fact that we could not find these smelters on the CFSI lists for compliant or active smelters. We have assessed these 187 facilities and determined that most of these are of low risk due to their geographic location. There are seventeen smelters or refiners that may be considered at greater risk, since they are geographically located in Africa.
Some of our suppliers provided information at a part number level and we were able to specifically identify the smelters from which their necessary conflict minerals were procured. The remainder of our suppliers provided their complete list of smelters, but we were unable to identify the specific smelters from which the conflict minerals used for our products were procured. As many of the reports we received are company-wide and not product specific, we believe these reports may include smelters and refiners that do not provide the necessary conflict minerals that are used in our products. Due to the many company-wide reports and the multiple levels of suppliers in our supply chain we are unable to determine with certainty at this time a complete list of smelters and refiners listed in the reports that actually provide the specific necessary conflict minerals used in our products.
However, based upon our suppliers’ responses to the Template, we believe that most of the facilities that were used to process the conflict minerals contained in our Covered Products include the smelters and refiners listed in the table below. The table below includes only facilities that are listed in the EICC-GeSI template as “known smelters or refineries.” An indication of “Compliant” in the far-right column of the table indicates that the smelter or refinery has received a “conflict free” designation from an independent third party audit program as of May 15, 2025. An indication of “Active” in the far-right column of the table indicated that the smelter or refinery has committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. An indication of “Indeterminable” in the far-right column of the table indicates that the smelter or refinery was not included in the CFSI compliant or active lists and thus, the facility’s designation is indeterminable.
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Metal |
Smelter Name |
Smelter Country |
Smelter
Identification |
Compliant,
Active or
Indeterminable |
|
|
|
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|
Tungsten |
Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
CHINA |
CID004430 |
Compliant |
Tungsten |
Lianyou Resources Co., Ltd. |
TAIWAN, PROVINCE OF CHINA |
CID004397 |
Compliant |
Tungsten |
Kenee Mining Corporation Vietnam |
VIETNAM |
CID004619 |
Compliant |
Tungsten |
JSC "Kirovgrad Hard Alloys Plant" |
RUSSIAN FEDERATION |
CID003408 |
Indeterminable |
Tungsten |
Unecha Refractory metals plant |
RUSSIAN FEDERATION |
CID002724 |
Indeterminable |
Tungsten |
Smelter Not Listed |
RUSSIAN FEDERATION |
CID003553 |
Indeterminable |
Tungsten |
Woltech Korea Co., Ltd. |
KOREA, REPUBLIC OF |
CID002843 |
Indeterminable |
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CHINA |
CID000499 |
Indeterminable |
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
VIETNAM |
CID001889 |
Indeterminable |
Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. |
VIETNAM |
CID002011 |
Indeterminable |
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CHINA |
CID002095 |
Indeterminable |
Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CHINA |
CID002579 |
Indeterminable |
Tungsten |
Jiangxi Xianglu Tungsten Co., Ltd. |
CHINA |
CID002647 |
Indeterminable |
Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City |
CHINA |
CID002815 |
Indeterminable |
Tungsten |
Hunan Litian Tungsten Industry Co., Ltd. |
CHINA |
CID003182 |
Indeterminable |
Tungsten |
OOO “Technolom” 2 |
RUSSIAN FEDERATION |
CID003612 |
Indeterminable |
Tungsten |
OOO “Technolom” 1 |
RUSSIAN FEDERATION |
CID003614 |
Indeterminable |
Tungsten |
Philippine Bonway Manufacturing Industrial Corporation |
PHILIPPINES |
CID004797 |
Compliant |
Tungsten |
LLC Vostok |
RUSSIAN FEDERATION |
CID003643 |
Indeterminable |
Tungsten |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
CID001801 |
Indeterminable |
Tungsten |
MALAMET SMELTING SDN. BHD. |
MALAYSIA |
CID004056 |
Indeterminable |
Tungsten |
Philippine Carreytech Metal Corp. |
PHILIPPINES |
CID004438 |
Active |
Forward-Looking Statements
Statements relating to further risk mitigation are forward-looking in nature and are based on our current expectations or beliefs. These forward-looking statements are not a guarantee of performance and are subject to a number of uncertainties and other factors that may be outside of our control and which could cause actual events to differ materially from those expressed or implied by the statements made herein.