Exhibit 1.01
The Sherwin-Williams Company
Conflict Minerals Report
For Reporting Period from January 1, 2023 to December 31, 2023
This is the Conflict Minerals Report (this Report) of
The Sherwin-Williams Company (Sherwin-Williams, we, our, us, or the Company) for the reporting period from January 1, 2023 to December 31, 2023
(Reporting Period) that is being filed as an exhibit to the Companys Form SD in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (Rule 13p-1). Please refer to Rule 13p-1, Form SD and the 1934 Act
Release No. 34-67716 for definitions to the terms used in this Report, unless otherwise defined herein.
Based on the existing guidance from the Securities and Exchange Commission (the SEC), this Report has not been audited, nor is an independent
private sector audit required for this Report. The content on or connected to any website referred to in this Report is not incorporated by reference into this Report.
Executive Summary
Sherwin-Williams is dedicated to
ethical sourcing and takes seriously the humanitarian concerns that led to the enactment of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act pursuant to which the SEC adopted
Rule 13p-1. During calendar year 2023, we continued to investigate the sourcing of any gold, columbite-tantalite (coltan), cassiterite, and wolframite, or their derivatives, which are currently
limited to tin, tantalum and tungsten necessary to the functionality or production of our products (the subject minerals).
As a global
manufacturer and seller of a large variety of paint, specialty coatings and related products for a broad range of customers, we analyzed our products for their potential of containing even small quantities of subject minerals that are necessary to
the functionality or production of our products. Based on our analysis, we determined that paint cans, paint brushes and other associated application tools that we manufacture or contract to manufacture are in the scope of Rule 13p-1. Upon such determination, we investigated suppliers of the metal components necessary to the functionality or production of such paint cans, paint brushes and application tools. This Report focuses on the
processes and the results of the investigation.
Sherwin-Williams does not directly source from mines the subject minerals that may be contained in our
products. Our supply chain is large and complex and materials often pass through several commercial intermediaries before being purchased by Sherwin-Williams. More specifically, the subject minerals in their raw material form are processed by
smelters or refiners (SORs). After the subject minerals are processed or refined, they are sent to different types of facilities where they are processed and/or manufactured into components
or sub-components. Following this multi-step process, Sherwin-Williams purchases components from suppliers. As a result, we rely on the responses of our suppliers for information about the subject
minerals in their products, and they, in turn, rely on their own suppliers for information.
Conflict Minerals Disclosure
Reasonable Country of Origin Inquiry (RCOI)
We conducted
a reasonable country of origin inquiry (RCOI), in good faith, relating to the subject minerals in accordance with Rule 13p-1. After identifying the suppliers as described above, we sent
each of these suppliers a data inquiry in the form of an e-mail via a third-party software system. The data inquiry requested that the suppliers complete a Conflict Minerals Reporting Template
(CMRT) revision 6.10 or higher, developed by the Responsible Minerals Initiative (RMI). Suppliers were provided with two options for providing the data, namely via the MS Excel-based document (the CMRT itself), or completing
a response through our third-party software providers online platform. The CMRT included an inquiry regarding the country of origin for any subject minerals that were contained in the products we purchased from such supplier. In addition to
the initial data inquiry, we followed up with e-mails and telephone calls, where needed, to obtain the necessary information from our suppliers, and in those follow up communications we further
educated suppliers on Rule 13p-1 and how to accurately complete the CMRT. We received responses from 100% of the suppliers from which we requested a response.
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