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Celanese Corporation
Conflict Minerals Report
For the Reporting Period January 1, 2024 to December 31, 2024
Introduction
This Conflict Minerals Report ("Report") of Celanese Corporation ("Celanese") is filed pursuant to Rule 13p-1 and Form SD ("Rule") promulgated under the Securities Exchange Act of 1934, as amended. This Report covers the reporting period from January 1, 2024 to December 31, 2024. The Rule requires companies that manufacture or contract to manufacture products for which specified minerals are necessary to the functionality or production of such products to conduct a good faith reasonable country of origin inquiry ("RCOI") to determine whether any of these minerals originated in certain covered countries. The specified minerals include columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives (tantalum, tin, and tungsten) and are collectively referred to as "Conflict Minerals." The "Covered Countries" include the Democratic Republic of the Congo and adjoining countries.
This Report reflects Celanese’s commitment to responsible sourcing and compliance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, ensuring transparency and ethical supply chain practices.
Product Scope
This Report addresses products manufactured or contracted to be manufactured by Celanese for which Conflict Minerals are necessary to their functionality or production.
Reasonable Country of Origin Inquiry (RCOI)
Celanese conducted a good faith RCOI to determine the origin of Conflict Minerals in its products. The inquiry included:
•Identifying product categories likely to contain Conflict Minerals based on product specifications and internal records.
•Contacting suppliers, including banks involved in raw material trading, to request Conflict Minerals Reporting Templates ("CMRTs").
•Evaluating supplier responses to assess whether the minerals originated from Covered Countries, originated from recycled or scrap sources, or were validated as conflict-free.
The RCOI confirmed the presence of all four Conflict Minerals in Celanese’s supply chain. Some of the CMRT responses Celanese received from its suppliers were made on a company-level basis and did not provide detail as to source and chain of custody for the specific quantities of Conflict Minerals that were actually supplied to Celanese. As a result, Celanese does not possess sufficient information to draw definitive conclusions as to the exact smelter, country of origin, mine location or location of origin of the tin contained in our in-scope products. For all companies downstream from such suppliers (in particular those several steps removed from the original mines or smelters), it may be difficult to know the ultimate country or location of origin of the mine from which the Conflict Minerals originated.
Due Diligence Process
Celanese followed the due diligence framework outlined by the OECD Due Diligence Guidance, which includes the following steps:
•Supplier Identification and Engagement: Celanese identified and contacted potentially applicable suppliers, requesting CMRTs to gather information on the source and chain of custody of Conflict Minerals.
•Response Assessment: Supplier submissions were reviewed to identify smelters and countries of origin, cross-referenced with the Responsible Minerals Initiative ("RMI") conformant smelter list.
•Follow-Up Actions: Suppliers providing incomplete or delayed responses were further contacted to collect comprehensive data.
Results of Due Diligence
Celanese does not directly source Conflict Minerals from mines or smelters, relying instead on its direct suppliers to uphold responsible sourcing practices. The supply chains are multi-tiered, involving numerous third parties between the original sources and Celanese’s final products, which serve various industrial applications.
Based on the 2024 CMRTs and the smelter data provided, Celanese believes that the Conflict Minerals necessary to the functionality or production of its products were:
•Sourced from countries outside the Covered Countries;
•Derived from recycled or scrap materials; or
•Certified as conflict-free by RMI through its Responsible Minerals Assurance Process ("RMAP").
Celanese directly contacted its raw material suppliers and received supplier declarations or completed CMRTs that denoted the Conflict Minerals used in Celanese products were either certified to be conflict free or sourced from smelters and refineries that had been audited and validated by RMAP. The list of smelters is included below:
| | | | | | | | |
Metal | Smelter | Country |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| | | | | | | | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | PowerX Ltd. | RWANDA |
| Tantalum | 5D Production OU | ESTONIA |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tantalum | AMG Brasil | BRAZIL |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | TANIOBIS GmbH | GERMANY |
| Tantalum | KEMET de Mexico | MEXICO |
| Tin | Minsur | PERU |
| Tin | Mineracao Taboca SA | BRAZIL |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Fenix Metals | POLAND |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Yunnan Tin Company Limited | CHINA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | MKS PAMP SA | SWITZERLAND |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | Masan High-Tech Materials | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA |
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Risk Mitigation and Future Steps
Celanese supports preventing the use of Conflict Minerals that finance armed conflict in the Covered Countries. Celanese’s Statement of Responsible Sourcing of Minerals is accessible at https://www.celanese.com/en/legal/conflict-minerals-policy-and-disclosure, and its Sustainable Procurement policy is available at https://www.celanese.com/-/media/cewebjssapp/project/documents/celanesesustainable-procurement-policy.pdf. To enhance risk management, Celanese intends to:
•Maintain its active membership in RMI; and
•Continue to enhance its supplier engagement and broader RCOI process in 2025.