Exhibit 1.01
NOV Inc.
Conflict Minerals Report
For the reporting period from January 1, 2024 to December 31, 2024
This Conflict Minerals Report of NOV Inc. (the “Company,” “NOV,” “we,” “us,” or “our”) for the calendar year ended December 31, 2024 is presented pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on issuers whose manufactured products include cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (the “Designated Minerals”), where such Designated Minerals are necessary to the functionality or production of such products. If any Designated Minerals necessary to functionality or production of such products originated from the Democratic Republic of the Congo or an adjoining country that shares an internationally recognized border with the Democratic Republic of the Congo (the “Conflict Region”) and are not from recycled or scrap sources, the Rule imposes certain additional due diligence and reporting obligations.
Product Description
This Conflict Minerals Report covers all products manufactured by NOV or contracted to be manufactured for NOV. Those products include, but are not limited to, those listed in Attachment A to this Conflict Minerals Report.
Conflict Minerals Policy
NOV’s policy is to develop a “conflict-free” supply chain – one that does not use Designated Minerals sourced from mines or smelters that have directly or indirectly aided armed groups in the Conflict Region.
A copy of our policy can be found at: http://investors.nov.com/phoenix.zhtml?c=97690&p=irol-govconduct.
Reasonable Country of Origin Inquiry
Our conflict minerals compliance program includes an annual review of our product portfolio and periodic reviews by our engineers of the raw materials and/or purchased subcomponents used in our products to determine which items contain Designated Minerals that are necessary to a product’s functionality or production.
NOV internally developed a computerized Conflict Minerals Management System (the “CMM System”) that provides a platform for conflict minerals compliance by all NOV business units impacted by conflict minerals. The CMM System compares the list of materials and subcomponents identified by our engineers as containing Designated Minerals against purchase order items received by NOV during the calendar year. The CMM System identifies suppliers that delivered items containing Designated Minerals. The identified suppliers are directed to complete an online Reasonable Country of Origin Inquiry (“RCOI”). The purpose of our CMM System is to determine which suppliers should complete an RCOI, and further to identify suppliers requiring additional Due Diligence (see “Due Diligence” below) based on the RCOI responses.
For the 2024 calendar year, we asked 37 suppliers to complete an online RCOI through our CMM System. The survey response rate was 46%. Of the suppliers who responded, no supplier reported having sourced from the Conflict Region in a manner which benefited armed groups in the region.
Due Diligence
Our due diligence process is designed in accordance with Annex I of the Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”). All steps taken by NOV in preparing this Conflict Minerals Report are in accordance with the OECD Framework.
Our due diligence activities generally included follow-up questions with the relevant suppliers or their sub-suppliers within the supply chain, a review of any mine or smelter certifications, a review of materials spec sheets, and similar