Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Section 13(p) of the Securities Exchange Act of 1934 and Rule 13p-1 thereunder (collectively, the “conflict mineral
rules”) require certain disclosures concerning supply sources for conflict minerals – consisting of gold, tin, tungsten, or
tantalum – that may be necessary to the manufacture or functionality of a company’s products. Terms and phrases used
but not defined in this disclosure have the meanings given under the conflict mineral rules.
No conflict mineral is intentionally added to, or serves as a functional component of, products sold by Exxon Mobil
Corporation (“ExxonMobil”). However, the manufacturing process for certain of ExxonMobil’s refined petroleum and
petrochemical products utilizes catalysts which include tin, tungsten, or gold compounds as active ingredients. Depending
on the type of catalysis process used, trace amounts of such minerals may exist in some of our finished products.
We understand the staff of the U.S. Securities and Exchange Commission (“SEC”) has previously issued oral guidance
that conflict mineral compounds are not subject to reporting under the conflict mineral rules. However, in the absence of
affirmative written SEC guidance on this point, ExxonMobil has conducted in good faith a reasonable country of origin
inquiry regarding the conflict minerals described above for 2025. Such inquiry is reasonably designed to determine
whether any of these minerals originated in the Democratic Republic of the Congo or an adjoining country (the “covered
countries") or are from recycled or scrap sources.
The tin, tungsten, or gold catalysts used by ExxonMobil in 2025 were purchased from third party suppliers. ExxonMobil’s
country of origin inquiry includes obtaining from each of these suppliers for catalysts containing tin, tungsten, or gold
compounds an annual written declaration in the form of the Conflict Minerals Reporting Template (“CMRT”)
promulgated by the Responsible Minerals Initiative (“RMI”) or similar conflict mineral statement. Our contracts with
each of these catalyst suppliers also require the suppliers to have and maintain procedures reasonably designed to ensure
that all conflict minerals necessary to the functionality of products manufactured by the supplier or contracted by the
supplier to be manufactured that are sold to ExxonMobil will be conflict free.
With respect to products we manufactured or contracted to manufacture in 2025, we have obtained completed declarations
from each of our eight third-party suppliers of catalysts containing tin, tungsten, or gold compounds.
Five out of eight suppliers certified that the tin, tungsten, or gold used in their catalysts did not originate in the covered
countries. Based on these inquiries, we conclude that, with respect to catalysts containing tin, tungsten, or gold
compounds from these suppliers which were used in the manufacture of products by ExxonMobil in 2025, such minerals
did not originate in the covered countries.
The three remaining suppliers indicated in their CMRT declarations that some of the smelters in their respective supply
chains source tin, tungsten, and/or gold from the covered countries (the “covered country declarations”). All three of the
covered country declarations were provided on a company basis rather than a product basis so it is not known with
certainty that minerals from the covered countries were actually used to produce catalysts sold to ExxonMobil. Covered
country declarations represented that any covered country smelters or refiners used in the supplier’s supply chain in 2025
were “conformant” within the meaning of the RMI standards. Under RMI definitions, “conformant” means smelters and
refiners that have successfully completed an assessment against the applicable Responsible Minerals Assurance Process
(“RMAP”) or an equivalent cross-recognized assessment. RMAP includes Supply Chain Transparency Audit Protocols
for tin, tungsten, or gold, as applicable, under which a “conformant” smelter must have completed a RMAP conformance
audit conducted by an independent third-party auditor.
Based on the representations made in the covered country declarations regarding the supply chains upstream of
ExxonMobil’s direct catalyst suppliers, together with information provided in further discussions with certain of these
suppliers and information available on the RMI website, we do not believe further diligence regarding these supply chains
is necessary on ExxonMobil’s part.
This Conflict Minerals Disclosure and accompanying Conflict Minerals Report are available on ExxonMobil’s website at:
https://corporate.exxonmobil.com/who-we-are/policy/conflict-minerals