EX-1.01

EX-1.01 2 d406693dex101.htm EX-1.01 EX-1.01

Exhibit 1.01

Neogen Corporation

Conflict Mineral Report

2016

Company Overview

Neogen Corporation develops and markets products dedicated to food and animal safety. The company’s Food Safety Division markets dehydrated culture media and diagnostic test kits to detect foodborne bacteria, natural toxins, food allergens, drug residues, plant diseases and sanitation concerns. Neogen’s Animal Safety Division is a leader in the development of animal genomics along with the manufacturing and distribution of a variety of animal healthcare products, including diagnostics, pharmaceuticals, veterinary instruments, wound care and disinfectants. Neogen has expanded its Global footprint with marketed products in the United Kingdom, Mexico, Brazil, China, and India.

Description of Neogen’s Reasonable Country of Origin Inquiry and Due Diligence

Neogen has designed and implemented a conflict minerals compliance plan that is intended to comply with Rule 13p-1. Neogen, in accordance with the Organization for Economic Co-operation and Development (“OECD”), has established a five-step framework:

Establish strong company management systems.

Build a conflict minerals team to maintain Neogen’s policy, reporting requirements, and a sustainable process for the future.

Identify and assess risk in the supply chain.

Conduct a Supplier Questionnaire to identify any conflict minerals in the supply chain.

Survey those suppliers that have been identified by submitting the Conflict-Free Sourcing Initiative (“CFSI”) Conflict Minerals Reporting Template (“CMRT”).

Design and implement a strategy to respond to identified risks.

Conduct a Reasonable Country of Origin Inquiry for suppliers who submit a CMRT.

Maintain a conflict minerals risk management plan to alleviate supplier risk.

Carry out independent third-party audit of supply chain due diligence.

The Company does not have sufficient information to determine whether its products are “DRC conflict free”. Therefore, an independent private sector audit is not required at this time.

Report annually on supply chain due diligence.

Neogen files a Form SD and Conflict Minerals Report with the SEC annually.

Using our supply chain due diligence processes, the Company hopes to further develop transparency into our supply chain.

Results of Neogen’s RCOI and Due Diligence

After reviewing the submitted ‘Conflict Minerals Reporting Template’ from the surveyed suppliers, a review of Neogen’s products was performed. Through database driven reports of Neogen’s end products and the information provided by suppliers, we identified one conflict mineral utilized during the 2016 calendar year. The company identified three suppliers who fell within the scope of our RCOI, supplying gold, which is used in the company’s diagnostic products.

Despite having conducted a good faith reasonable country of origin inquiry and due diligence, Neogen was unable to determine the origin of the conflict mineral due to insufficient information from its suppliers. Therefore, Neogen’s 2016 calendar year has concluded as “DRC Conflict Undeterminable”. Neogen cannot exclude that 3TG are necessary to the functionality of certain products and must rely on third party suppliers to provide these components in our end products. Neogen has added a clause to our Supplier Quality Assurance Questionnaire that aids the transparency in our supply chain by requiring vendors to supply materials to Neogen that are “DRC conflict free”, and to report any changes of the sourcing of conflict minerals.

Independent Private Sector Audit

The Company does not have sufficient information to determine whether its products are “DRC conflict free.” As such, an independent private sector audit is not required at this time.

Forward Looking Statements

This Conflict Minerals Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our goals for future improvements to our reasonable country of origin process and to mitigate the risk about the sourcing of our conflict minerals. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include: lack of progress in carrying out these plans in a timely manner or at all; lack of cooperation or progress by our employees and suppliers, and our suppliers’ respective suppliers and smelters; or these plans may not be effective. In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC. Except as required by law, we disclaim any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.