Section 1 Conflict Minerals Disclosure
Item 1.01
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Conflict Minerals Disclosure and Report
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Conflict Minerals Disclosure
This Form SD of PQ Group
Holdings Inc. (the Company) is filed pursuant to Rule 13p-1 (the Rule) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1,
2019 to December 31, 2019 (the Reporting Period). The Rule implements reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of
2010 (Dodd-Frank Act). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are currently limited to tantalum, tin, and tungsten (the Conflict
Minerals). The Rule imposes certain reporting obligations on SEC registrants that manufacture or contract to manufacture products for which Conflict Minerals are necessary to the functionality or production of those products and contained in
the finished products. The Rule requires that SEC registrants conduct in good faith a reasonable country of origin inquiry designed to determine whether any such necessary Conflict Minerals originated in the Democratic Republic of the Congo or
adjoining countries (as defined by the SEC) (collectively, the Covered Countries) or are from recycled or scrap sources.
The
Company reviewed the finished products that it and its subsidiaries manufactures either internally or pursuant to arrangements with third-party manufacturers during the Reporting Period (the Product Review). The objective of the Product
Review was to identify finished products that the Company and its subsidiaries manufactures or contracts to manufacture that may contain one or more Conflict Minerals. In this effort, the Manager of Product Stewardship of the Company routinely
evaluated and verified the source and use of raw materials purchased and used by the Company and its subsidiaries globally to determine whether any Conflict Minerals used in the Companys and its subsidiaries products are sourced from
Covered Countries or are from recycled or scrap sources. The Company has determined that Conflict Minerals are contained in, and are necessary to the functionality or production of, certain finished products containing silicotungstic acid, a
tungsten compound. The Companys Zeolyst joint venture purchased a limited amount of such tungsten compound (in the aggregate an amount less than 0.01% of the Zeolyst joint ventures overall raw material spend), which is used as a raw
material to manufacture, and is contained in, a certain catalyst product (the Covered Product).
As a result of such determination, and in
accordance with the Dodd-Frank Act and the Rule, the Company conducted in good faith a reasonable country of origin inquiry as to the tungsten compound contained in the Covered Product by seeking a certification from the joint ventures direct,
exclusive supplier of the tungsten compound (the Covered Supplier). The Covered Supplier has provided the Company with a signed certification of the name and location of each smelter from which the Covered Supplier sources the tungsten
used in producing the tungsten compound contained in the Covered Product (the Supplier Certification). According to the Supplier Certification, none of the tungsten contained in the Covered Product was sourced from smelters in any
Covered Country.
Based on the results of its reasonable country of origin inquiry, and its review of the information and the Supplier Certification, the
Company has no reason to believe that the tungsten contained in the Covered Product may have originated in any of the Covered Countries or may not be from recycled or scrap sources.
This conflict minerals disclosure is publicly available on the Companys website at
http://investor.pqcorp.com/corporate-governance/2019-conflict-minerals-form-sd.
Not Applicable.
Section 2 Exhibits
Not applicable.