Exhibit 1.01
RxSight, Inc.
Conflict Minerals Report
For The Reporting Period from January 1, 2025 to December 31, 2025
Cautionary Note Concerning Forward-Looking Statements: This Conflict Minerals Report contains forward-looking statements within the meaning of federal securities laws. These forward-looking statements include statements concerning RxSight’s objectives for its conflict minerals policy and compliance initiatives and actions it intends to take relating to conflict minerals. Forward-looking statements involve substantial risks and uncertainties that could cause actual results to differ materially from currently anticipated results. When considering forward-looking statements, you should consider, among other factors, the risk factors described in the reports and other filings that RxSight, Inc. files with the United States Securities and Exchange Commission, including RxSight’s Annual Report on Form 10-K for the year ended December 31, 2025 and its subsequent Quarterly Reports on Form 10-Q. The risk factors included in these filings are not exhaustive, and risks that are not identified therein could materially affect whether RxSight realizes the results anticipated or implied by any forward-looking statements contained in this Conflict Minerals Report. Except as required by law, RxSight disclaims any obligation to update these forward-looking statements, whether as a result of new information, future events, or otherwise.
Introduction
This Conflict Minerals Report (this “Report”) for RxSight, Inc. (“RxSight” or “we” or “our”) covers the reporting period from January 1, 2025 to December 31, 2025 and is presented in accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). This Report is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD (the “Form SD”). A copy of this Report and the Form SD are publicly available on our website at http://investors.rxsight.com/. Information contained on, or that can be accessed through, our website, does not constitute part of this Report and inclusion of our website address in this Report is an inactive textual reference only.
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Section 1502 of the Act relates to conflict minerals and requires companies subject to the Act to file a Form SD annually with the United States Securities and Exchange Commission (“SEC”) to disclose whether the minerals specified in Rule 13p-1 and their derivatives, limited to tungsten, tantalum, tin, and gold (referred to as the “3TG”), used in their products benefited, directly or indirectly, armed groups in the Democratic Republic of the Congo and the nine countries with which it shares an internationally recognized border: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (collectively, the “Covered Countries”). This Report, which is an exhibit to our Form SD, describes the design and implementation of our conflict minerals due diligence measures undertaken, including a description of how these measures were designed to determine, to our knowledge, the source mines, countries of origin, and processing facilities for 3TG contained in components used in our products.
RxSight Background and Covered Products
We are a commercial-stage medical technology company dedicated to providing high-quality customized vision to patients following cataract surgery. Our proprietary RxSight® Light Adjustable Lens system (“RxSight system”) is the first and only commercially available premium cataract technology that enables doctors to customize and optimize visual acuity for patients after surgery. The RxSight system is comprised of our RxSight Light Adjustable Lens® (LAL®/LAL+®, collectively the “LAL”), RxSight Light Delivery Device™ (“LDD™”) and related accessories. The LAL is a premium intraocular lens (“IOL”) made from the proprietary silicone-based photosensitive material that undergoes controlled changes in refractive power when exposed to specific ultraviolet (“UV”) light patterns generated by the LDD.
Our commercial efforts began in 2019, and have been primarily focused in the U.S., where we are building a “razor and razor blade” business model to drive new customer adoption and ongoing LAL volume growth. Our sales efforts are concentrated on the approximately 4,000 U.S. cataract surgeons that perform approximately 60% of all premium IOL procedures. We currently manufacture, assemble, test, and ship our RxSight system in Aliso Viejo, California at our campus of five facilities which consist of an aggregate of approximately 150,000 total square feet. Our manufacturing operations require a wide variety of raw materials that we rely on third-party manufacturers to supply. Our suppliers are evaluated, qualified, and approved as part of our supplier quality program, which includes verification and monitoring procedures to ensure that our suppliers comply with FDA and ISO standards, as well as our own specifications and requirements. We inspect and verify externally sourced components under strict processes supported by internal policies and procedures. We
maintain a rigorous change control policy to assure that no product or process changes are implemented without our prior review and approval.
We have determined that one or more of the 3TG may be necessary to the functionality or production of the LDD™ we manufactured during 2025. As a result, our LDD™ are considered “covered products” for purposes of this Report.
Our supply chain with respect to the covered products is complex, and there are many third-parties in the supply chain between the original source of the 3TG and the manufacturer of the covered products. We do not purchase raw ore or unrefined 3TG directly and make no purchases in the Covered Countries. As a result, and as described more fully below, we rely on our suppliers to provide information on the origin of the conflict minerals contained in our LDD™.
RxSight Reasonable Country of Origin Inquiry
In accordance with Rule 13p-1 and Form SD, we determined that one or more of the 3TG may be necessary to the functionality or production of our LDD™ and that such 3TG are incorporated into our LDD™ during the manufacturing process. Accordingly, we undertook a reasonable country of origin inquiry (“RCOI”). This good faith RCOI was reasonably designed to determine whether any of the 3TG incorporated into our LDD™ originated in the Covered Countries.
Our RCOI consisted principally of submitting the conflict minerals reporting template (the “RMI Template”) prepared by the Responsible Minerals Initiative (“RMI”), an initiative of the Responsible Business Alliance, to suppliers of components for our LDD™ that are considered necessary to the functionality or production of our LDD™ and for which any 3TG or their derivatives may be included (“first-tier suppliers”). We reviewed all responses for completeness, reasonableness, and consistency, and we followed up for corrections and clarifications as we determined appropriate.
RxSight’s Due Diligence Process
Our due diligence measures were designed to conform, in all material respects, with the framework in the Organisation 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”). The objectives of our diligence initiative were to determine, to the best of our ability, whether one or more of the 3TG is incorporated into our LDD™; whether any such 3TG incorporated into our LDD™ was necessary for the functionality and/or production of our LDD™; the source and chain of custody of the 3TG necessary for the functionality and/or production of our LDD™; and whether any such 3TG originated in the Covered Countries. In the event that 3TG from the Covered Countries which benefit armed groups are found in our supply chain, we will take appropriate actions in a timely manner to resolve the situation.
Due diligence measures that we implemented included, but were not limited, to the following:
1. Establishment of Internal Management Systems
a.Internal Management to Support Supply Chain Due Diligence. The RxSight finance department has been charged with the management of our conflict minerals program, working in collaboration with members from our legal and operations team.
b.Controls and Transparency. As described above, we undertook a RCOI with respect to conflict minerals in our supply chain by providing the RMI Template to our first-tier suppliers to gather information about their use of 3TG, the smelters and refiners in their supply chain that are included in our LDD™, and the countries of origin for 3TG used in our LDD™. We reviewed all responses for completeness, reasonableness, and consistency. We followed up for corrections and clarifications as we determined appropriate.
c.Supplier Engagement. We continue to engage actively with our first-tier suppliers to strengthen our relationship with them. We have communicated to our suppliers our commitment to source conflict minerals in a manner that does not, directly or indirectly, benefit armed groups in the Covered Countries. We will consider alternative arrangements for our supply needs if our suppliers are unable to cooperate in our due diligence efforts.
d.Grievance Mechanism. Our Code of Business Conduct and Ethics includes procedures for reporting violations of our policies, and we provide mechanisms for anonymous reporting of violations or concerns about the conduct of our business.
2. Identification and Assessment of Risks in the Supply Chain
As discussed above, we identified our first-tier suppliers and relied on them to provide the necessary information about the use of 3TG in the products we purchase and incorporate into the manufacturing process of our RxSight system, and the source of such 3TG. Similarly, our first-tier suppliers rely on information provided by their suppliers to provide information regarding the country of origin of 3TG included in our LDD™.
3. Designing and Implementing a Strategy to Respond to Identified Risks
We will review circumstances in which certain suppliers are unable to provide us with complete or reliable responses to the RMI Template including, without limitation, considering whether to continue such contract or relationship or find a replacement supplier.
4. Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with any smelters or refiners in our supply chain. As a result, we do not and cannot conduct any audits directly. Instead, we have supported the development and implementation of independent third-party audits of smelters such as the Responsible Minerals Assurance Program (“RMAP”) by encouraging our suppliers to purchase materials from audited, conflict-free smelters and determining whether the smelters that were used to process these minerals were validated as conflict-free by the RMAP.
5. Reporting on Supply Chain Due Diligence
We publicly filed the Form SD and this Report with the SEC. A copy of this Report and the Form SD are publicly available at http://investors.rxsight.com/. This Report includes information about the RCOI methodology utilized by the Company, the design of our due diligence process in conformance with the OECD Framework, the list of known smelters and refiners utilized in our supply chain identified in our due diligence process, and a description of our LDD™ that incorporate 3TG necessary to the functionality or production of such products.
Smelters and Refiners in RxSight’s Supply Chain
Based on the information that was provided by our suppliers and otherwise obtained through the due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the 3TG contained in the covered products included the smelters and refiners listed in Annex A attached hereto. This table includes only facilities that are listed in the RMI Smelter Reference List as of May 29, 2026. An indication of “Conformant” in the far-right column of the table indicates that the smelter or refinery has successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment or is presently undergoing a re-audit to maintain its “conflict free” designation. An indication of “Active” in the far-right column of the table indicates that the smelter or refinery has not yet received a “conflict free” designation but is undergoing an audit process that will determine such status. An indication of “Unknown” in the far-right column of the table indicates that the smelter or refinery was not included in the RMI “Conformant” or “Active” lists and thus the facility’s designation is undeterminable.
Because the RMI Smelter Reference List generally did not indicate individual countries of origin of the conflict minerals processed by smelters and refiners, we were not able to determine the countries of origin of the 3TG processed by the listed smelters and refiners with greater specificity. Furthermore, as stated earlier, submission of these smelters by our first-tier suppliers does not guarantee that these smelters or refiners are present in the Company’s supply chain as our first-tier suppliers were generally only able to provide company-level RMI Templates and not able to provide product-level RMI Templates directly linking those smelters or refiners to the covered products. Therefore, based on our due diligence efforts,
we do not have sufficient information to conclusively determine the countries of origin of the 3TG contained in the covered products.
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by RxSight. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our 3TG status. These factors include, but are not limited to, gaps in supplier data; gaps in smelter data; errors or omissions by suppliers; errors or omissions by smelters; smelter classifications; all instances of 3TG necessary to the functionality or manufacturing of our LDD™ not yet having been identified; gaps in supplier education and knowledge; timeliness of data; public information not discovered during a reasonable search; errors in public data; language barriers and translation; supplier and smelter unfamiliarity with the protocols for identifying and sourcing potential 3TG; oversight or errors in conflict free smelter audits; Covered Countries sourced materials being declared secondary materials; companies going out of business; certification programs being not equally advanced for all industry segments and metals; and smuggling of 3TG from the Covered Countries to other countries.
Future Steps
We have communicated our expectations to our first-tier suppliers regarding our commitment to sourcing minerals for our LDD™ in a manner that does not, directly, or indirectly, finance or benefit armed groups in the Democratic Republic of the Congo or adjoining countries. We expect to continue our engagement with our relevant suppliers over the next year to build their knowledge and capacity, so they are able to provide us with more complete and accurate information on the source and chain of custody of the 3TG included in components and parts purchased by us and incorporated into our LDD™ .
Annex A
RxSight, Inc.
2025 Facility and Country List
|
|
|
|
Metal |
Smelter Name |
Country |
Compliance Status |
Gold |
8853 S.p.A. |
Italy |
Unknown |
Gold |
ABC Refinery Pty Ltd. |
Australia |
Unknown |
Gold |
Abington Reldan Metals, LLC |
United States of America |
Conformant |
Gold |
Advanced Chemical Company |
United States of America |
Conformant |
Gold |
African Gold Refinery |
Uganda |
Unknown |
Gold |
Agosi AG |
Germany |
Conformant |
Gold |
Aida Chemical Industries Co., Ltd. |
Japan |
Conformant |
Gold |
Al Etihad Gold Refinery DMCC |
United Arab Emirates |
Unknown |
Gold |
Al Ghaith Gold |
United Arab Emirates |
Unknown |
Gold |
Albino Mountinho Lda. |
Portugal |
Unknown |
Gold |
Alexy Metals |
United States of America |
Unknown |
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
Uzbekistan |
Conformant |
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
Brazil |
Conformant |
Gold |
Argor-Heraeus S.A. |
Switzerland |
Conformant |
Gold |
ARY Aurum Plus |
United Arab Emirates |
Unknown |
Gold |
Asahi Pretec Corp. |
Japan |
Conformant |
Gold |
Asahi Refining Canada Ltd. |
Canada |
Conformant |
Gold |
Asahi Refining USA Inc. |
United States of America |
Conformant |
Gold |
Asaka Riken Co., Ltd. |
Japan |
Conformant |
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Turkey |
Unknown |
Gold |
AU Traders and Refiners |
South Africa |
Unknown |
Gold |
Augmont Enterprises Private Limited |
India |
Unknown |
Gold |
Aurubis AG |
Germany |
Conformant |
Gold |
Bangalore Refinery |
India |
Conformant |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
Conformant |
Gold |
Boliden AB |
Sweden |
Conformant |
Gold |
Boliden Ronnskar |
Sweden |
Conformant |
Gold |
C. Hafner GmbH + Co. KG |
Germany |
Conformant |
Gold |
C.I Metales Procesados Industriales SAS |
Colombia |
Unknown |
Gold |
Caridad |
Mexico |
Unknown |
Gold |
CCR Refinery - Glencore Canada Corporation |
Canada |
Conformant |
Gold |
Cendres + Metaux S.A. |
Switzerland |
Unknown |
Gold |
CGR Metalloys Pvt Ltd. |
India |
Unknown |
Gold |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
China |
Unknown |
Gold |
Chimet S.p.A. |
Italy |
Conformant |
Gold |
Chugai Mining |
Japan |
Conformant |
Gold |
Coimpa Industrial LTDA |
Brazil |
Conformant |
Gold |
Daejin Indus Co., Ltd. |
Republic of Korea |
Unknown |
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
China |
Unknown |
Gold |
Degussa Sonne / Mond Goldhandel GmbH |
Germany |
Unknown |
Gold |
Dijllah Gold Refinery FZC |
United Arab Emirates |
Unknown |
Gold |
DODUCO Contacts and Refining GmbH |
Germany |
Unknown |
Gold |
Dongwu Gold Group |
China |
Unknown |
Gold |
Dowa |
Japan |
Conformant |
Gold |
DSC (Do Sung Corporation) |
Republic of Korea |
Conformant |
Gold |
Eco-System Recycling Co., Ltd. East Plant |
Japan |
Conformant |
Gold |
Eco-System Recycling Co., Ltd. North Plant |
Japan |
Conformant |
Gold |
Eco-System Recycling Co., Ltd. West Plant |
Japan |
Conformant |
Gold |
Elemetal Refining, LLC |
United States of America |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 1) |
India |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 2) |
India |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 3) |
India |
Unknown |
Gold |
Emerald Jewel Industry India Limited (Unit 4) |
India |
Unknown |
Gold |
Emirates Gold DMCC |
United Arab Emirates |
Unknown |
Gold |
Fidelity Printers and Refiners Ltd. |
Zimbabwe |
Unknown |
Gold |
Fujairah Gold FZC |
United Arab Emirates |
Unknown |
Gold |
Geib Refining Corporation |
United States of America |
Unknown |
Gold |
GG Refinery Ltd. |
United Republic of Tanzania |
Conformant |
Gold |
GGC Gujrat Gold Centre Pvt. Ltd. |
India |
Unknown |
Gold |
Global Tungsten & Powders LLC |
United States of America |
Unknown |
Gold |
Gold by Gold Colombia |
Colombia |
Conformant |
Gold |
Gold Coast Refinery |
Ghana |
Unknown |
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
China |
Conformant |
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
China |
Unknown |