OMI Owens and Minor Inc

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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.

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SECTION 1 - Conflict Minerals Disclosure

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Item 1.01 Conflict Minerals Disclosure and Report

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This Specialized Disclosure Report on Form SD by Owens & Minor, Inc. and subsidiaries (“Owens & Minor,” “Company,” “we,” and “our”) is for the period from January 1 to December 31, 2023.

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During 2023, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs, as defined below, are necessary to their functionality or production (“Covered Products”). Conflict minerals are defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (together with gold collectively referred to as “3TGs”), or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. Accordingly, we have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated in the DRC or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia), or were from recycled or scrap sources.

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A summary of our RCOI, as well as the steps taken to exercise due diligence on the source and chain of custody of any 3TGs in our Covered Products, is included in our Conflict Minerals Report (“Report”), which is filed as Exhibit 1.01 to this Form SD. In addition, our Conflict Minerals Policy Statement is publicly available on the Investor page of our Company website at: www.owens-minor.com.

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Forward-Looking Statements

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The Report contains forward-looking statements that express a belief, expectation or intention, including statements relating to our compliance efforts and expected actions. The words “expects,” “intends,” “plans,” “believes,” “anticipates” and similar expressions can indicate forward- looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Future actions or performance may differ materially from those in the forward-looking statements. Undue reliance should not be placed on these statements, which are only effective as of the date of this Report, and the Company undertakes no obligation to publicly update or revise any forward-looking statement.

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Item 1.02 Exhibits.

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We have filed our Conflict Minerals Report as Exhibit 1.01 to this Form SD.

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SECTION 2 - Resource Extraction Issuer Disclosure

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Item 2.01. Resource Extraction Issuer Disclosure and Report

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Not applicable

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SECTION 3 - Exhibits Item 3.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD.

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SIGNATURES

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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 duly authorized undersigned.

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OWENS & MINOR, INC.

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Date:May 30, 2024

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EXHIBIT INDEX

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Exhibit NumberDescription

1.01Conflict Minerals Report for the year ended December 31, 2023 as required by Items 1.01 and 1.02 of this Form.

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EXHIBIT 1.01

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Owens & Minor, Inc. Conflict Minerals Report For the Year Ended December 31, 2023

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This Conflict Minerals Report (“Report”) by Owens & Minor, Inc. and subsidiaries (“Owens & Minor,” “Company,” “we,” “us,” and “our”) is for the period from January 1, 2023 to December 31, 2023 (“Reporting Period”).

This Report is intended to comply with Rule 13p-1 of the Securities Exchange Act of 1934, as amended (“Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (“3TGs”) that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.

As described in this report, Owens & Minor has reason to believe that some of the 3TGs present in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries, and we proceeded to conduct due diligence on our supplier base. The results of our due diligence are discussed below.

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Owens & Minor, Inc. and subsidiaries, a Fortune 500 company headquartered in Richmond, Virginia, is a global healthcare solutions company that incorporates product manufacturing, distribution support and innovative technology services to deliver significant and sustained value across the breadth of the industry – from acute care to patients in their home. Our teammates serve healthcare industry customers in approximately 80 countries, by providing quality products and helping to reduce total costs across the healthcare supply chain by optimizing point-of care performance, freeing up capital and clinical resources and managing contracts to optimize financial performance.

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During the Reporting Period, Owens & Minor was organized into two operating segments: Products & Healthcare Services and Patient Direct. The principal sources of revenue in each segment are described below:

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For the Reporting Period, we conducted an analysis of our products to determine which, if any, were likely to contain 3TGs. The analysis identified that 3TGs were necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.

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We began our scoping process by developing a list of our suppliers that provide us with products that may contain one or more of the 3TGs. We then populated the list with contact information and provided it to our third party service provider (“Service Provider”). The supplier list was then uploaded to our Service Provider’s software tool that allows us to store and manage supplier requests and documentation.

From there, we removed from the list service providers, indirect materials suppliers, and other suppliers who are inactive. This helped ensure that all suppliers surveyed provided items to Owens & Minor that were used in final products in 2023.

Our Service Provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (“CMRT”), version 6.31 developed by the Responsible Business Alliance (RBA)® and The Responsible Minerals Initiative (RMI)®, the suppliers on the final supplier list were surveyed on their sourcing of the 3TGs that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, due diligence process, and supply chain, including such supply chain information as the names and locations of smelters or refiners.

As part of the supplier survey, suppliers were asked to complete the CMRT. All communications were tracked and monitored in the Service Provider’s software tool. Non-responsive suppliers were contacted a minimum of three times. Any suppliers that continued to be non-responsive were advanced to an escalation phase and further contacted on an individual basis.

The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions. All submitted CMRTs were classified as valid or invalid. All suppliers who submitted CMRTs that were classified as “invalid” were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our Service Provider’s software system. As of May 13, 2024, there were 2 invalid submissions that had not been corrected by suppliers.

Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we then conducted due diligence on our supplier base.

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We designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organization for Economic Co-operation and Development (“OECD”) in the publication OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas and the related Supplements for tin, tantalum, tungsten and gold.

Our conflict minerals due diligence process includes the five steps described in the Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third party audits, and 5) publicly reporting on our supply chain due diligence. A summary of our due diligence measures is outlined below.

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Step 1.Establishing Strong Company Management Systems

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We organized a Conflict Minerals Committee comprised of individuals in management positions across multiple departments, namely Legal, Supply Chain, and Compliance. The Committee members are the (1) Executive Vice President, General Counsel and Corporate Secretary, (2) Vice President, Manufacturing & Procurement, (3) Vice President, Associate General Counsel, Products & Healthcare Services, and (4) Vice President, Ethics, Compliance and Privacy. The Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and for overseeing the program.

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We have applicable policies and statements such as a Code of Honor that outlines expected behaviors for all Owens & Minor employees, a Supplier Social Compliance Standard that outlines expected behaviors for all Owens & Minor vendors, and a Conflict Minerals Policy Statement (“Statement”). All three items are available on our website. The Statement, in particular, can be found at https://compliance.owens-minor.com/EthicsAndCompliance.html#en-US.

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We utilized the CMRT version 6.31 and our Service Provider’s software reporting tool for collecting Conflict Minerals declarations from our supply base. Using these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests. We have also communicated with relevant suppliers our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information from them to support the chain of custody of the 3TGs identified in our products.

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We have several mechanisms that allow people to alert Company management about any concerns they may have about our compliance or ethics. Our Code of Honor sets out ways to report concerns, including a Code of Conduct Hotline and Online Reporting tool, which both allow reports, in any language, to be made confidentially and anonymously at the election of the person making the report. We also have made publicly available on our website policies for communicating with our Board of Directors and with our compliance-oversight Committees of the Board, namely the Audit Committee and the Governance & Nominating Committee. These mechanisms are available to people who may be concerned about compliance with our conflict minerals program or with any other compliance matter.

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We maintain a company-wide document retention policy. The policy extends to the documents accumulated in performing our due diligence for this Report and requires that the documents be retained for a period of ten years. In addition, our Service Provider stores all of the information and findings from this process in a database that can be audited by internal or external parties.

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Step 2.Identify and Assess Risks in the Supply Chain

Due to the complexity of our products and supply chain, it is difficult for us to identify indirect suppliers. We have relied on responses from our direct suppliers to provide us with information about the source of conflict minerals contained in the parts and components they supply to us.

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Similarly, our direct suppliers also rely on information provided to them by their suppliers. This chain of information creates a level of uncertainty and risk about the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to recognized industry best practices.

In accordance with the Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Each facility that meets the Responsible Minerals Initiative (“RMI”) definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria, namely: (1) geographic proximity to the DRC and covered countries; (2) Responsible Minerals Assurance Process (RMAP) audit status; and (3) known or plausible evidence of unethical or conflict sourcing.

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Based on these criteria, the following facilities have been identified with high risks in their supply chain:

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If any of these facilities were reported on a CMRT by one of our suppliers, our Service Provider initiated risk mitigation activities, including instructing the supplier to submit a product-specific CMRT to better identify any connection between the facilities and our products, and escalating up to requesting removal of these high-risk smelters from their supply chain.

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As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Service Provider’s online learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

Additionally, we evaluated suppliers on their conflict minerals program strength. Many companies continue to develop their programs and still provide an answer of “unknown” in response to our survey questions. We used the following criteria to evaluate the strength of their programs, with the capital letters, below, corresponding to the ones in the CMRT declaration tab:

A. Have you established a responsible minerals sourcing policy?

D. Have you implemented due diligence measures for responsible sourcing?

F. Do you review due diligence information received from your suppliers against your company's expectations?

G. Does your review process include corrective action management?

When suppliers meet or exceed those criteria (Yes to A, D, F, G), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.

Our identification and risk assessment process also involves: (1) seeking information about 3TG smelters or refiners in our supply chain by requesting that our suppliers complete the CMRT, (2) verifying those smelters or refiners with RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable. We believe that the inquiries and analysis described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products.

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Step 3.Design and Implement a Strategy to Respond to Identified Risks

Our Supplier Social Compliance Standards and Conflict Minerals Policy Statement set out our expectations for our suppliers. If these expectations are not met, the business relationship between us and the supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, we will encourage the applicable supplier to establish an alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not we can replace the supplier. We have found no instance to date where we believed it was necessary to implement such risk mitigation efforts.

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Step 4.Utilize Independent Third Party Audits

We do not have a direct relationship with smelters or refiners (“SORs”) and do not perform or direct audits of these entities. Instead, we rely on third party assurances and certifications such as from the RMI’s Responsible Minerals Assurance Process, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters or refiners that agree to participate in the program.

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Step 5.Publicly Report on Supply Chain Due Diligence

This Report, which constitutes our annual report on our due diligence efforts, is filed as Exhibit 1.01 to our Form SD which is available on our website in the Investor Relations section, under SEC Filings, at www.owens-minor.com.

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As of May 13, 2024, we received responses from 76% of our 197 surveyed suppliers. Of those, 135 suppliers claimed no 3TGs in their products, and 12 claimed that they did have 3TGs. (The numbers do not sum to 197 because not all surveyed suppliers responded.)

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As described above, we surveyed our supply chain and reviewed the responses to determine whether further engagement with them was required. The determination to further engage with them was based on criteria such as untimely responses, incomplete responses, and inconsistencies within the data reported. Suppliers who provided a CMRT were asked to submit SOR information. The results are discussed in the Smelters or Refiners section below.

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Because we do not have relationships with the smelters or refiners, we relied on requests to our suppliers that they complete the RMI template. We believe that process suffices as a good faith effort to determine the identity of the mines or the locations of origin of 3TGs in our supply chain.

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Of the suppliers we surveyed, many completed the RMI template at the company or business unit level, and they were unable to represent that 3TGs from the processing facilities they listed were in components they supplied to us. The quality of the responses we received from suppliers varied.

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Many responses provided via the CMRT included the names of facilities listed by the suppliers as SORs. The CMRT responses that did not list at least one smelter for each 3TG were considered invalid, and our Service Provider followed up on these responses, urging suppliers to resubmit the form and include the smelter information. There are still suppliers that were unable to provide SORs used for the materials supplied to us.

For all the CMRT responses that indicated a smelter, our Service Provider compared them to the list of smelters maintained by the RMI. As of May 13, 2024, we validated 354 SORs in our supply chain, and we are working to validate the additional SOR entries. Appendix A lists only the SORs that our suppliers reported as being in their supply chains and that we validated. Appendix B is a compilation of countries of origin, setting out the countries from which the reported facilities source their conflict minerals.

As our suppliers have been largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional SOR names or country of origin information at this time. We will continue to work with our suppliers to obtain smelter information at the product level.

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We are committed to complying with the provisions of the Rule and expect to continue our efforts to improve our conflict minerals program. As we further develop our program, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to, the following:

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APPENDIX A

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The table below lists, the smelters or refiners (“SORs”) identified by our direct suppliers that may have been used to process 3TGs necessary to the functionality or production of our products in 2023.

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