Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Introduction
This Form SD is filed pursuant to
Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Rule”) for the reporting period January 1, 2023 to December 31, 2023 (the “Reporting Period”).
Stevanato Group S.p.A. (NYSE: STVN) (the “Company” or “us”) is a leading global provider of drug containment, drug delivery and
diagnostic solutions as well as engineering solutions to the pharmaceutical, biotechnology and life sciences industries. Stevanato Group delivers an integrated,
end-to-end portfolio of products, processes and services that address customer needs across the entire drug life cycle from development to clinical and commercial
stages. Stevanato Group’s core capabilities in scientific research and development, its commitment to technical innovation and its engineering excellence are central to its ability to offer value added solutions to clients.
Conflict Mineral Disclosure
The Company operates across
the healthcare industry and serves some of its fastest growing segments, including biologics (such as GLP1s, monoclonal antibodies, and mRNA applications), biosimilars, vaccines and molecular diagnostics. The Company operates its business in two
segments: (i) Biopharmaceutical and Diagnostic Solutions, which includes all the products, processes and services developed and provided for the containment and delivery of pharmaceutical and biotechnology drugs and reagents, as well as the
production of diagnostic consumables; and (ii) Engineering, which includes all of the equipment and technologies developed and provided to support the end-to-end
pharmaceutical, biotechnology and diagnostic manufacturing processes (assembly, visual inspection, packaging and serialization and glass converting).
The
Rule requires registrants filing reports with the U.S. Securities and Exchange Commission (the “Commission”) under Sections 13(a) or 15(d) of the Securities Exchange Act of 1934 having conflict minerals that are necessary to the
functionality or production of a product manufactured or contracted by that registrant to be manufactured to file a report on Form SD within the period specified in the Form SD, disclosing the information required by the applicable items of the Form
SD as specified in therein. As defined in Form SD, the term “Conflict Mineral” means columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten.
The Company has reason to believe that certain materials provided by third-party suppliers used in the production of some of its products during the Reporting
Period, including certain syringe products (the “Subject Products”), may contain some Conflict Minerals that are necessary to their functionality or production.
Reasonable Country of Origin Inquiry
The Company does
not directly purchase Conflict Minerals, nor does the Company have any direct relationship with any mines or smelters that process Conflict Minerals. Thus, any Conflict Minerals that are potentially present in the Subject Products would have
originated solely from Company purchases from third parties.
The Company conducted a reasonable country of origin inquiry in good faith that is
reasonably designed to determine whether any Conflict Minerals contained in the Subject Products originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) or are from recycled or scrap sources.
The Company conducted a survey only on those suppliers which it reasonably believed could make use of Conflict Minerals (the “In-Scope Suppliers”). The Company used the Responsible Minerals Initiative Conflict Minerals Reporting Template (“CMRT”) to conduct a survey of the
In-Scope Suppliers. The In-Scope Suppliers were requested to provide specified information regarding the inclusion of Conflict Minerals in the products supplied to the
Company and the country of origin thereof. Each CMRT was evaluated for consistency, completeness and accuracy.