Exhibit 1.01
DONNELLEY FINANCIAL SOLUTIONS
Conflict Minerals Report
For the reporting period from January 1, 2024 to December 31, 2024
This Conflict Minerals Report (the “Report”) of Donnelley Financial Solutions, Inc. (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934 for the reporting period January 1, 2024 to December 31, 2024.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. For the purpose of this report, tin, tungsten, tantalum and gold will be collectively referred to as the 3TGs. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products for which 3TGs are necessary to the functionality or production of those products.
Description of the Company’s Products Covered by this Report
This Report relates to products: (i) for which 3TGs may be necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2024.
These products, which are referred to in this Report collectively as the “Covered Products” are press and binding consumables and packaging and mailing supplies used in the production of such documents as annual reports, prospectuses, and notice and proxies.
The Company’s RCOI and Due Diligence Process
The Company has conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding Conflict Minerals. This good faith RCOI was reasonably designed to determine whether any of the 3TGs originated in the Covered Countries and whether any of the 3TGs may be from recycled or scrap sources. The Company also exercised due diligence on the source and chain of custody of 3TGs that may have originated in Covered Countries. The Company’s due diligence measures have been designed to conform to the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”).
The Company’s supply chain with respect to its products is complex, and there are many third parties in the supply chain between the ultimate manufacture of Company products and the original sources of these minerals. In this regard, the Company does not purchase minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of the 3TGs that are included in its products.
The Company’s primary means of determining country of origin of 3TGs contained in the Covered Products was by conducting a supply chain survey with direct suppliers using the EICC-GeSI Conflict Minerals Reporting Template (“CMRT”) version 6.4 or higher. This supply chain survey and RCOI program was developed and implemented with assistance from a third-party service provider, Assent Compliance (“Assent”). To determine the list of suppliers that would be surveyed, we assessed our active suppliers of Covered Products to determine if they supplied the Company with parts or products that may contain one or more of the 3TGs. We periodically reviewed this list to ensure any irrelevant or “out of scope” suppliers were removed from the survey process. Suppliers that were removed included service providers, indirect material suppliers, and suppliers that did not supply the Company with products in 2024.
Non-responsive suppliers were contacted a minimum of three times by Assent. After which non-responsiveness, suppliers were then contacted via email by Company procurement team members to encourage their response to the survey. As part of the survey communications, suppliers were offered training relating to the proper completion of the CMRT and education relating to the Conflict Minerals reporting regulations.
Due Diligence Efforts Performed
Structured a team led by senior staff members, including the (i) Group Executive President (ii) Chief Operations and Production Officer (iii) Chief Legal and Compliance Officer (iv) Senior Vice President, Operations Strategy & Global Procurement, to support and oversee supply chain due diligence.
Our third-party service provider, Assent Compliance, also assists us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence measures where necessary.
Assent’s process also included automated data validation on all submitted CMRTs, which is designed to increase the accuracy of submissions and identify any contradictory answers in the CMRT. Suppliers are contacted in regard to invalid forms and are encouraged to resubmit a valid form. As of May 18, 2025, there were no invalid supplier submissions that could not be corrected.