UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549 
 

FORM SD
 Specialized Disclosure Report
 

enrformsd2019withcasea.jpg
Energizer Holdings, Inc.
(Exact Name of Registrant as Specified in Charter) 
 

  
Missouri
001-36837
36-4802442
(State or Other Jurisdiction
of Incorporation)
(Commission
File Number)
(I.R.S. Employer
Identification No.)

533 Maryville University Drive
St. Louis, Missouri 63141
(Address of Principal Executive Offices, and Zip Code)


John J. Drabik
Executive Vice President, Chief Financial Officer

(314) 985-2000
(Name and telephone number, including area code, of the person to contact in connection with
this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
_X___ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.




Section 1 - Conflict Minerals Disclosure

Item 1.01 - Conflict Minerals Disclosure and Report

This Form SD of Energizer Holdings, Inc. (the “Registrant”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act, as amended, for the reporting period January 1, 2023 to December 31, 2023.

A copy of the Registrant’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and incorporated by reference herein and is publicly available at https://www.energizerholdings.com/company/partners-suppliers/overview. The website and information accessible through it are not incorporated into this document.

Item 1.02 - Exhibit

The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
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Section 2 - Exhibits
Item 2.01 - Exhibits
Exhibit No.Description
1.01



SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.




ENERGIZER HOLDINGS, INC.


By: /s/ John J. Drabik
John J. Drabik

Executive Vice President and Chief Financial Officer

Dated: May 22, 2024
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Exhibit                           1.01

Energizer Holdings, Inc.
Conflict Minerals Report
For the Reporting Period from January 1, 2023 to December 31, 2023

This Conflict Minerals Report for the year ended December 31, 2023 is provided by Energizer Holdings, Inc. (“Energizer”, “Company”, “we”, “us” and “our”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Under the Rule, we are required to make certain disclosures regarding our manufactured products that contain conflict minerals, provided those conflict minerals are necessary to the functionality or production of those products. As defined by the Rule, and for purposes of this report, the conflict minerals are cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“Conflict Minerals”; tin, tantalum, tungsten and gold collectively are referred to as “3TG”).

As detailed below, based on our reasonable country of origin inquiry, Energizer has no reason to believe that the 3TG in any of our products is funding armed conflict in the Democratic Republic of Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”). However, it remains challenging for many companies and their suppliers (including us and our suppliers) to gather complete and reliable data. Consequently, we exercised due diligence on the Conflict Minerals’ origin and chain of custody, and we are providing this Conflict Minerals Report to describe our due diligence processes and results.


Company Overview

Energizer Holdings, Inc. (NYSE: ENR), headquartered in St. Louis, Missouri, is one of the world’s largest manufacturers and distributors of primary batteries, portable lights, and auto care appearance, performance, refrigerant, and fragrance products. Our portfolio of globally recognized brands include Energizer®, Armor All®, Eveready®, Rayovac®, STP®, Varta®, A/C Pro®, Refresh Your Car!®, California Scents®, Driven®, Bahama & Co.®, LEXOL®, Eagle One®, Nu Finish®, Scratch Doctor®, and Tuff Stuff®. As a global branded consumer products company, Energizer’s mission is to lead the charge to deliver value to our customers and consumers better than anyone else.

The Company identified Conflict Minerals contained in products: (i) for which Conflict Minerals are necessary to the functionality or production of those products; (ii) that were manufactured by, or contracted to be manufactured for, us; (iii) for which the manufacture was completed during calendar year 2023; and (iv) with respect to Conflict Minerals in such products, for which we were unable to reasonably determine that all of the Conflict Minerals contained therein did not originate in the Covered Countries (or did not come from recycled or scrap sources) (collectively, the “Covered Products”). We believe that Conflict Minerals are present in the following products: round cell alkaline batteries, round cell carbon zinc batteries, lighting, and chargers.

Conflict Minerals Policy

We have adopted a conflict minerals policy which expresses Energizer’s goal to ensure all 3TG used in our products is “DRC conflict-free”. Our policy is publicly available on our website at https://www.energizerholdings.com/company/partners-suppliers/overview. The website and information accessible through it are not incorporated into this document.

Supply Chain

A number of Energizer’s products contain advanced components and compounds manufactured by our suppliers. These suppliers may manufacture the components themselves or source some or all of the production to their suppliers. These suppliers may do the same with lower tier suppliers. We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us—including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three to five years or more, and we cannot unilaterally impose new contract terms or flow-down requirements. As we enter into new contracts, or our contracts renew, we have sought to include a clause under which our suppliers undertake that no 3TG that originated in the Covered Countries are incorporated in, or necessary to, the functionality or production of any product delivered to us, including in any component manufactured of such product by a third party.




Under the terms of these contracts, it will take a number of years to ensure that all of our supplier contracts contain appropriate clauses. In the meantime, as described below, we are working with our suppliers to obtain 3TG sourcing information.

Due to the size of our supply base, it is not practicable to conduct a survey of all of our suppliers and we determined a reasonable approach was to conduct a survey of the suppliers who provided raw materials for products containing 3TG in relevant product supply chains as well as sourced product suppliers in 2023. We assessed our industry as well as others and concluded that the risk-based approach was consistent with how many peer companies approached the Rule. We also implemented software designed to facilitate and track our supplier surveys.

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it was difficult to identify actors upstream from our direct suppliers. As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our sector and other sectors. Accordingly, we participate in a number of industry-wide initiatives, including the Responsible Minerals Initiative (RMI), an industry-wide initiative supporting upstream actors in the supply chain, through our supply chain data management service provider, Assent Compliance.

Reasonable Country of Origin Inquiry (RCOI) Results

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Energizer retained a third-party supply chain data management service provider, Assent Compliance (“Assent”), to assist us with reviewing the supply chain and identifying risks. The Company provided Assent with a list of suppliers and parts associated with the in-scope products. To trace materials, and demonstrate transparency procured by the supply chain, Energizer utilized the Conflict Minerals Reporting Template (“CMRT”) Version 6.31 or higher to conduct a survey of all in-scope suppliers. 
During the supplier survey, Assent contacted suppliers utilizing a software-as-a-service (SaaS) platform that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The platform also provides functionality that meets the OECD Guidance (defined below) process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement.
Through Assent, Energizer requested that all in-scope suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the platform for future reporting and transparency. Energizer directly contacted suppliers that were unresponsive to communications during the diligence process and requested these suppliers complete the CMRT.
Our program continues to include automated data validation on all submitted CMRTs. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.


Design of Due Diligence Framework

Our due diligence framework was designed to conform, in material respects, with the framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”) and the related Supplements for 3TG.

Due Diligence Measures Performed

Due diligence measures we performed included, but were not limited to:
Establishing strong management and controls systems and communicating our policy on conflict minerals to direct suppliers;
Communicating the commitments and requirements expected of our direct suppliers, supported by training and resources, and email and phone dialogues;



Designing and implementing a strategy to respond to risks and determining whether 3TG smelter and refiner names were included on the Responsible Minerals Initiative’s Conformant Smelter Report (“CSR”). The CSR is generally understood to contain the names of smelters and the associated risk level of their mineral sourcing;
Carrying out independent third-party audit of supply chain due diligence at identified points in the supply chain; and
Reporting annually on supply chain due diligence.


Due Diligence Results

Through requesting our suppliers to complete the CMRT, we determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain. We identified approximately 144 3TG smelters and refiners included in our suppliers’ supply chains. Nonetheless, most of our supplier responses were provided at a company level. Many suppliers did not provide verifiable smelter or processing information or responded at a company-wide level which did not allow us to conclude that the Conflict Minerals were processed by any one particular facility. Based on the information provided by our suppliers, we could not identify how many of these smelters produced materials specifically used in the Covered Products. Therefore, it is possible that none of the materials from these smelters actually entered our supply chain. The list of 3TG smelters and refiners and the identified countries of origin are included as Appendix A. Accordingly, Energizer believes it is reasonable to conclude that the Covered Products are “DRC conflict undeterminable,” as defined in the Rule.

Steps to be taken to mitigate risk
We intend to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary Conflict Minerals in our Products could benefit armed groups in the DRC or adjoining countries:
Continue to incorporate a Conflict Minerals flow-down clause in new or renewed supplier contracts;
Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses;
Engage any of our suppliers found to be supplying us with 3TG from sources that support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict; and
Work with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.






Appendix A - List of 3TG Smelters/Refiners and Identified Countries of Origin

Based on the information that was provided by the in-scope suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed below. We are unable to definitively link the identified 3TG smelters and refiners to only those products and materials in our supply chain; therefore our 3TG smelter and refiner list likely contains more processing facilities than are actually in our supply chain and used to manufacture the Covered Products.

Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information to conclusively determine the country of origin of all of the Conflict Minerals in the Covered Products. At the same time, we received no information from our in-scope suppliers indicating that the 3TG in our Covered Products directly or indirectly financed or benefited armed groups in the Covered Countries. Also, due to the manner in which our in-scope suppliers disclosed country of origin information, we do not believe that all of the countries named are actually in our supply chain or Covered Products. However, based on the information that has been obtained, the Company has reasonably determined that the Conflict Minerals may have originated from the countries listed in the table below.

Based on the information obtained pursuant to the due diligence process, the Company believes there is a risk that the Covered
Products may contain Conflict Minerals from the Covered Countries. The Company’s due diligence into the supply chain was
unable to determine whether any of the Covered Products did or did not contain any Conflict Minerals from any Covered Country, as defined in the Rule.









Appendix A: Smelter List


MetalSmelter NameSmelter Facility Location
GoldMetalor USA Refining CorporationUnited States of America
GoldAida Chemical Industries Co., Ltd.Japan
GoldArgor-Heraeus S.A.Switzerland
GoldAsahi Pretec Corp.Japan
GoldAsaka Riken Co., Ltd.Japan
GoldDowaJapan
GoldEco-System Recycling Co., Ltd. East PlantJapan
GoldHeraeus Metals Hong Kong Ltd.China
GoldIshifuku Metal Industry Co., Ltd.Japan
GoldAsahi Refining USA Inc.United States of America
GoldJX Nippon Mining & Metals Co., Ltd.Japan
GoldKojima Chemicals Co., Ltd.Japan
GoldLS-NIKKO Copper Inc.Korea, Republic of
GoldMatsuda Sangyo Co., Ltd.Japan
GoldMetalor Technologies (Singapore) Pte., Ltd.Singapore
GoldMetalor Technologies S.A.Switzerland
GoldMitsubishi Materials CorporationJapan
GoldMitsui Mining and Smelting Co., Ltd.Japan
GoldNihon Material Co., Ltd.Japan
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.China
GoldSolar Applied Materials Technology Corp.Taiwan, Province of China
GoldSumitomo Metal Mining Co., Ltd.Japan
GoldTanaka Kikinzoku Kogyo K.K.Japan
GoldShandong Gold Smelting Co., Ltd.China
GoldTokuriki Honten Co., Ltd.Japan
GoldUnited Precious Metal Refining, Inc.United States of America
GoldWestern Australian Mint (T/a The Perth Mint)Australia
GoldEmirates Gold DMCCUnited Arab Emirates
GoldL'Orfebre S.A.Andorra
GoldAgosi AGGermany
GoldAngloGold Ashanti Corrego do Sitio MineracaoBrazil
GoldAurubis AGGermany
GoldBoliden ABSweden
GoldC. Hafner GmbH + Co. KGGermany
GoldCCR Refinery - Glencore Canada CorporationCanada
GoldChimet S.p.A.Italy
GoldHeimerle + Meule GmbHGermany
GoldHeraeus Germany GmbH Co. KGGermany
GoldIstanbul Gold RefineryTurkey



GoldAsahi Refining Canada Ltd.Canada
GoldKennecott Utah Copper LLCUnited States of America
GoldMaterionUnited States of America
GoldMetalor Technologies (Suzhou) Ltd.China
GoldMetalor Technologies (Hong Kong) Ltd.China
GoldMetalurgica Met-Mex Penoles S.A. De C.V.Mexico
GoldOhura Precious Metal Industry Co., Ltd.Japan
GoldMKS PAMP SASwitzerland
GoldRand Refinery (Pty) Ltd.South Africa
GoldRoyal Canadian MintCanada
GoldSEMPSA Joyeria Plateria S.A.Spain
GoldUmicore S.A. Business Unit Precious Metals RefiningBelgium
GoldValcambi S.A.Switzerland
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChina
GoldWIELAND Edelmetalle GmbHGermany
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAustria
TantalumF&X Electro-Materials Ltd.China
TantalumJiujiang Tanbre Co., Ltd.China
TantalumMitsui Mining and Smelting Co., Ltd.Japan
TantalumNingxia Orient Tantalum Industry Co., Ltd.China
TantalumTaki Chemical Co., Ltd.Japan
TantalumTANIOBIS GmbHGermany
TantalumMaterion Newton Inc.United States of America
TantalumGlobal Advanced Metals BoyertownUnited States of America
TantalumGlobal Advanced Metals AizuJapan
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChina
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.China
TantalumNPM Silmet ASEstonia
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.China
TantalumTelex MetalsUnited States of America
TantalumUlba Metallurgical Plant JSCKazakhstan
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.China
TantalumD Block Metals, LLCUnited States of America
TantalumFIR Metals & Resource Ltd.China
TantalumKEMET de MexicoMexico
TantalumTANIOBIS Co., Ltd.Thailand
TantalumJiangxi Tuohong New Raw MaterialChina
TantalumTANIOBIS Smelting GmbH & Co. KGGermany
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.China
TinEM VintoBolivia (Plurinational State Of)
TinMalaysia Smelting Corporation (MSC)Malaysia
TinMineracao Taboca S.A.Brazil
TinMinsurPeru
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)



TinPT Refined Bangka TinIndonesia
TinPT Timah Tbk KundurIndonesia
TinPT Timah Tbk MentokIndonesia
TinThaisarcoThailand
TinWhite Solder Metalurgia e Mineracao Ltda.Brazil
TinTin Smelting Branch of Yunnan Tin Co., Ltd.China
TinAurubis BeerseBelgium
TinLuna Smelter, Ltd.Rwanda
TinFabrica Auricchio Industria e Comercio Ltda.Brazil
TinTin Technology & RefiningUnited States of America
TinDowaJapan
TinMitsubishi Materials CorporationJapan
TinPT Artha Cipta LanggengIndonesia
TinRui Da HungTaiwan, Province of China
TinPT Bangka SerumpunIndonesia
TinChina Tin Group Co., Ltd.China
TinAurubis BerangoSpain
TinPT Aries Kencana SejahteraIndonesia
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.China
TinAlphaUnited States of America
TinGejiu Non-Ferrous Metal Processing Co., Ltd.China
TinO.M. Manufacturing (Thailand) Co., Ltd.Thailand
TinMetallic Resources, Inc.United States of America
TinJiangxi New Nanshan Technology Ltd.China
TinPT Babel Inti PerkasaIndonesia
TinPT Babel Surya Alam LestariIndonesia
TinPT Bukit TimahIndonesia
TinPT Mitra Stania PrimaIndonesia
TinPT Prima Timah UtamaIndonesia
TinPT Sariwiguna BinasentosaIndonesia
TinPT Stanindo Inti PerkasaIndonesia
TinPT ATD Makmur Mandiri JayaIndonesia
TinO.M. Manufacturing Philippines, Inc.Philippines
TinPT Cipta Persada MuliaIndonesia
TinPT Menara Cipta MuliaIndonesia
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.China
TinChifeng Dajingzi Tin Industry Co., Ltd.China
TinPT Rajawali Rimba PerkasaIndonesia
TinCRM SynergiesSpain
TungstenA.L.M.T. Corp.Japan
TungstenKennametal HuntsvilleUnited States Of America
TungstenChongyi Zhangyuan Tungsten Co., Ltd.China
TungstenGlobal Tungsten & Powders LLCUnited States Of America
TungstenJapan New Metals Co., Ltd.Japan
TungstenXiamen Tungsten Co., Ltd.China



TungstenHunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products BranchChina
TungstenH.C. Starck Tungsten GmbHGermany
TungstenHunan Chenzhou Mining Co., Ltd.China
TungstenWolfram Bergbau und Hutten AGAustria
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.China
TungstenJiangxi Yaosheng Tungsten Co., Ltd.China
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.China
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.China
TungstenXiamen Tungsten (H.C.) Co., Ltd.China
TungstenJiangxi Gan Bei Tungsten Co., Ltd.China
TungstenGanzhou Seadragon W & Mo Co., Ltd.China
TungstenTANIOBIS Smelting GmbH & Co. KGGermany
TungstenMasan High-Tech MaterialsViet Nam
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.China
TungstenNiagara Refining LLCUnited States of America
TungstenChina Molybdenum Tungsten Co., Ltd.China











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