Section 1 - Conflict Minerals Disclosure
Items 1.01 Conflict Minerals Disclosure and Report
In
accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (Rule 13p-1), Nine Energy Service, Inc. has filed this Specialized
Disclosure Report on Form SD (this Form SD) for the reporting period from January 1, 2019 to December 31, 2019.
Conflict
Minerals Disclosure
Rule 13p-1 requires disclosure of certain information when a company manufactures or
contracts to manufacture products for which specified minerals are necessary to the functionality or production of those products. The specified minerals (3TG minerals) are gold, columbite-tantalite (coltan), cassiterite and wolframite,
including their derivatives, which are limited to tantalum, tin and tungsten. The Rule 13p-1 reporting and public disclosure requirements apply to registrants whatever the geographic origin of the utilized 3TG
minerals and whether or not the utilized 3TG minerals were sourced in a manner to fund armed conflict.
Nine Energy Service, Inc. (Nine,
we, us or our; and together with its subsidiaries as of December 31, 2019, the Company) is a leading completion services provider that targets unconventional oil and gas resource development
across all North American basins and abroad. We partner with our exploration and production customers to design and deploy downhole solutions and technology to prepare horizontal, multistage wells for production, and we offer a variety of completion
applications and technologies to match customer needs across the broadest addressable completions market. Our comprehensive well solutions range from cementing the well at the initial stages of the completion, preparing the well for stimulation,
isolating all the stages of an extended reach lateral, and the drilling out of isolation tools. To provide our services, we purchase a wide variety of raw materials, parts and components (the Products) that are manufactured and supplied
for our operations from various suppliers.
We have conducted an analysis of the Products and found that, although the Company does not (i) directly
purchase 3TG minerals from mines, smelters or refiners or (ii) make direct purchases of any 3TG minerals in the Democratic Republic of Congo, the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania,
Zambia or Angola (the Covered Countries), the Company did purchase certain Products that contain 3TG minerals that were necessary to the functionality or production of those Products. Therefore, the Company is subject to the reporting
obligations of Rule 13p-1.
Nine is committed to a culture of compliance with the laws of each of the countries in
which we operate. Nine is also committed to sourcing materials and components from companies that share our values and commitment to human rights, ethics and environmental responsibility. As part of this commitment, we have adopted a Conflict
Minerals Mission Statement, a copy of which is available on Nines website at https://investor.nineenergyservice.com/corporate-governance/governance-documents.
As stated above, Nine does not purchase raw ore or unrefined 3TG minerals directly from mines, smelters or refiners and makes no direct purchases of any 3TG
minerals in the Covered Countries. The Companys supply chain with respect to the Products is complex, with intermediaries and third parties in the supply chain between the manufacture of the Products containing 3TG and the original sources of
such 3TG. The Company must therefore rely on its suppliers to provide information on the origin and chain of custody of the 3TG contained in the Products supplied to the Company, including, in some cases, the sources of 3TG that are supplied to the
Companys suppliers by their own suppliers.
To complete the reasonable country of origin inquiry (RCOI) required by the Rule 13p-1, we identified those suppliers from which the Company purchased Products that contain (or may contain) 3TG minerals (the At-Risk Suppliers). Next, we sent
each At-Risk Supplier a communication that requested it provide information regarding the sourcing of its materials with the ultimate goal of identifying the 3TG minerals smelters or refiners
(SORs) and associated mine countries of origin. At-Risk Suppliers who had already performed an RCOI through the use of the Conflict-Free Sourcing Initiatives Conflict Minerals Reporting
Template (CMRT) were asked to upload this document or provide this information. The CMRT requires a supplier to make representations regarding (i) the country of origin for the 3TG mineral contained in the Products the supplier
provided to the Company, (ii) all of the
1