Specialized Disclosure Report (Form SD)

Energizer Holdings, Inc.

Conflict Minerals Report

For the Reporting Period from January 1, 2025 to December 31, 2025

This Conflict Minerals Report for the year ended December 31, 2025 is provided by Energizer Holdings, Inc. ("Energizer", "Company", "we", "us" and "our") pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). Under the Rule, we are required to make certain disclosures regarding our manufactured products that contain conflict minerals, provided those conflict minerals are necessary to the functionality or production of those products. As defined by the Rule, and for purposes of this report, the conflict minerals are cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten ("Conflict Minerals"; tin, tantalum, tungsten and gold collectively are referred to as "3TG").

As detailed below, based on our reasonable country of origin inquiry, Energizer has no reason to believe that the 3TG in any of our products is funding armed conflict in the Democratic Republic of Congo ("DRC") or an adjoining country (collectively, the "Covered Countries"). However, it remains challenging for many companies and their suppliers (including us and our suppliers) to gather complete and reliable data. Consequently, we exercised due diligence on the Conflict Minerals' origin and chain of custody, and we are providing this Conflict Minerals Report to describe our due diligence processes and results.

Company Overview

Energizer Holdings, Inc. (NYSE: ENR), headquartered in St. Louis, Missouri, is one of the world's largest manufacturers and distributors of primary batteries, portable lights, and auto care appearance, performance, refrigerant, and fragrance products. Our portfolio of globally recognized brands include Energizer®, Armor All®, Eveready®, Rayovac®, STP®, A/C Pro®, Refresh Your Car!®, California Scents®, Driven®, Bahama & Co.®, LEXOL®, Eagle One®, Nu Finish®, Son of a Gun®, Scratch Doctor®, Tuff Stuff®, NEVR-DULL®, Carnu®, Grand Prix®, Kit®, Tempo® and Centralsul®. As a global branded consumer products company, Energizer's mission is to lead the charge to deliver value to our customers and consumers better than anyone else. Visit www.energizerholdings.com for more details.

The Company identified Conflict Minerals contained in products: (i) for which Conflict Minerals are necessary to the functionality or production of those products; (ii) that were manufactured by, or contracted to be manufactured for, us; (iii) for which the manufacture was completed during calendar year 2025; and (iv) with respect to Conflict Minerals in such products, for which we were unable to reasonably determine that all of the Conflict Minerals contained therein did not originate in the Covered Countries (or did not come from recycled or scrap sources) (collectively, the "Covered Products"). We believe that Conflict Minerals are present in the following products: round cell alkaline batteries, round cell carbon zinc batteries, lighting, and chargers.

Conflict Minerals Policy

We have adopted a conflict minerals policy which expresses Energizer's goal to ensure all 3TG used in our products is "DRC conflict-free". Our policy is publicly available on our website at https://www.energizerholdings.com/company/partners-suppliers/overview. The website and information accessible through it are not incorporated into this document.

Supply Chain

A number of Energizer's products contain advanced components and compounds manufactured by our suppliers. These suppliers may manufacture the components themselves or source some or all of the production to their suppliers. These suppliers may do the same with lower tier suppliers. We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us - including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for three to five years or more, and we cannot unilaterally impose new contract terms or flow-down requirements. As we enter into new contracts, or our contracts renew, we have sought to include a clause under which our suppliers undertake that no 3TG that originated in the Covered Countries are incorporated in, or necessary to, the functionality or production of any product delivered to us, including in any component manufactured of such product by a third party.

Under the terms of these contracts, it will take a number of years to ensure that all of our supplier contracts contain appropriate clauses. In the meantime, as described below, we are working with our suppliers to obtain 3TG sourcing information.

Due to the size of our supply base, it is not practicable to conduct a survey of all of our suppliers and we determined a reasonable approach was to conduct a survey of the suppliers who provided raw materials for products containing 3TG in relevant product supply chains as well as sourced product suppliers in 2025. We assessed our industry as well as others and concluded that the risk-based approach was consistent with how many peer companies approached the Rule. We also implemented software designed to facilitate and track our supplier surveys.

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it was difficult to identify actors upstream from our direct suppliers. As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our sector and other sectors. Accordingly, we participate in a number of industry-wide initiatives, including the Responsible Minerals Initiative (RMI), an industry-wide initiative supporting upstream actors in the supply chain, through our supply chain data management service provider, Assent Compliance.

Reasonable Country of Origin Inquiry (RCOI) Results

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Energizer retained a third-party supply chain data management service provider, Assent Inc. ("Assent"), to assist us with reviewing the supply chain and identifying risks. The Company provided Assent with a list of suppliers and parts associated with the in-scope products. To trace materials, and demonstrate transparency procured by the supply chain, Energizer utilized the Conflict Minerals Reporting Template ("CMRT") Version 6.5 or higher to conduct a survey of all in-scope suppliers.

During the supplier survey, Assent contacted suppliers utilizing a software-as-a-service (SaaS) platform that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The platform also provides functionality that meets the OECD Guidance (defined below) process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier's declaration of process engagement.

Through Assent, Energizer requested that all in-scope suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the platform for future reporting and transparency. Energizer directly contacted suppliers that were unresponsive to communications during the diligence process and requested these suppliers complete the CMRT.

Our program continues to include automated data validation on all submitted CMRTs. The results of this data validation contribute to the program's health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

Design of Due Diligence Framework

Our due diligence framework was designed to conform, in material respects, with the framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance") and the related Supplements for 3TG.

Due Diligence Measures Performed

Due diligence measures we performed included, but were not limited to:

- Establishing strong management and controls systems and communicating our policy on conflict minerals to direct suppliers;

- Communicating the commitments and requirements expected of our direct suppliers, supported by training and resources, and email and phone dialogues;

- Designing and implementing a strategy to respond to risks and determining whether 3TG smelter and refiner names were included on the Responsible Minerals Initiative's Conformant Smelter Report ("CSR"). The CSR is generally understood to contain the names of smelters and the associated risk level of their mineral sourcing;

- Carrying out independent third-party audit of supply chain due diligence at identified points in the supply chain; and

- Reporting annually on supply chain due diligence.

Due Diligence Results

Through requesting our suppliers to complete the CMRT, we determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or

locations of origin of the 3TG in our supply chain. We identified approximately 126 3TG smelters and refiners included in our suppliers' supply chains. Nonetheless, most of our supplier responses were provided at a company level. Many suppliers did not provide verifiable smelter or processing information or responded at a company-wide level which did not allow us to conclude that the Conflict Minerals were processed by any one particular facility. Based on the information provided by our suppliers, we could not identify how many of these smelters produced materials specifically used in the Covered Products. Therefore, it is possible that none of the materials from these smelters actually entered our supply chain. The list of 3TG smelters and refiners and the identified countries of origin are included as Appendix A. Accordingly, Energizer believes it is reasonable to conclude that the Covered Products are "DRC conflict undeterminable," as defined in the Rule.

Steps to be taken to mitigate risk

We intend to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary Conflict Minerals in our Products could benefit armed groups in the DRC or adjoining countries:

- Continue to incorporate a Conflict Minerals flow-down clause in new or renewed supplier contracts;

- Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses;

- Engage any of our suppliers found to be supplying us with 3TG from sources that support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict; and

- Work with relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.

Appendix A - List of 3TG Smelters/Refiners and Identified Countries of Origin

Based on the information that was provided by the in-scope suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed below. We are unable to definitively link the identified 3TG smelters and refiners to only those products and materials in our supply chain; therefore our 3TG smelter and refiner list likely contains more processing facilities than are actually in our supply chain and used to manufacture the Covered Products.

Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information to conclusively determine the country of origin of all of the Conflict Minerals in the Covered Products. At the same time, we received no information from our in-scope suppliers indicating that the 3TG in our Covered Products directly or indirectly financed or benefited armed groups in the Covered Countries. Also, due to the manner in which our in-scope suppliers disclosed country of origin information, we do not believe that all of the countries named are actually in our supply chain or Covered Products. However, based on the information that has been obtained, the Company has reasonably determined that the Conflict Minerals may have originated from the countries listed in the table below.

Based on the information obtained pursuant to the due diligence process, the Company believes there is a risk that the Covered Products may contain Conflict Minerals from the Covered Countries. The Company's due diligence into the supply chain was unable to determine whether any of the Covered Products did or did not contain any Conflict Minerals from any Covered Country, as defined in the Rule.

Appendix A: Smelter List

Metal			Smelter Name			Smelter Facility Location
Tin			PT Timah Tbk Mentok			Indonesia
Tin			Tin Smelting Branch of Yunnan Tin Co., Ltd.			China
Tin			Thaisarco			Thailand
Tin			Malaysia Smelting Corporation Berhad (Port Klang)			Malaysia
Tin			Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.			China
Gold			Aida Chemical Industries Co., Ltd.			Japan
Gold			Asahi Pretec Corp.			Japan
Gold			Ishifuku Metal Industry Co., Ltd.			Japan
Gold			JX Nippon Mining & Metals Co., Ltd.			Japan
Gold			Kojima Chemicals Co., Ltd.			Japan
Gold			Matsuda Sangyo Co., Ltd.			Japan
Gold			Mitsubishi Materials Corporation			Japan
Gold			Nihon Material Co., Ltd.			Japan
Gold			Sumitomo Metal Mining Co., Ltd.			Japan
Gold			Tanaka Kikinzoku Kogyo K.K.			Japan
Gold			Tokuriki Honten Co., Ltd.			Japan
Tin			Dowa			Japan
Tin			Mineracao Taboca S.A.			Brazil
Tin			Minsur			Peru
Tin			Mitsubishi Materials Corporation			Japan
Tin			PT Timah Tbk Kundur			Indonesia
Tin			Rui Da Hung			Taiwan, Province Of China
Tin			Operaciones Metalurgicas S.A.			Bolivia (Plurinational State Of)
Tin			Yunnan Chengfeng Non-ferrous Metals Co., Ltd.			China
Tin			Aurubis Beerse			Belgium

Tin			Aurubis Berango			Spain
Tin			China Tin Group Co., Ltd.			China
Tungsten			A.L.M.T. Corp.			Japan
Gold			Agosi AG			Germany
Gold			AngloGold Ashanti Corrego do Sitio Mineracao			Brazil
Gold			Argor-Heraeus S.A.			Switzerland
Gold			Asaka Riken Co., Ltd.			Japan
Tungsten			Kennametal Huntsville			United States Of America
Gold			Aurubis AG			Germany
Gold			Boliden Ronnskar			Sweden
Gold			C. Hafner GmbH + Co. KG			Germany
Gold			Chimet S.p.A.			Italy
Tungsten			Chongyi Zhangyuan Tungsten Co., Ltd.			China
Gold			Dowa			Japan
Gold			Eco-System Recycling Co., Ltd. East Plant			Japan
Tin			EM Vinto			Bolivia (Plurinational State Of)
Tantalum			F&X Electro-Materials Ltd.			China
Tin			Fenix Metals			Poland
Tin			Gejiu Non-Ferrous Metal Processing Co., Ltd.			China
Tungsten			Global Tungsten & Powders LLC			United States Of America
Tantalum			XIMEI RESOURCES (GUANGDONG) LIMITED			China
Gold			Heimerle + Meule GmbH			Germany
Gold			Heraeus Metals Hong Kong Ltd.			China
Gold			Heraeus Germany GmbH Co. KG			Germany
Gold			Istanbul Gold Refinery			Turkey
Tungsten			Japan New Metals Co., Ltd.			Japan
Tantalum			JiuJiang JinXin Nonferrous Metals Co., Ltd.			China
Tantalum			Jiujiang Tanbre Co., Ltd.			China
Gold			Asahi Refining USA Inc.			United States Of America
Gold			Asahi Refining Canada Ltd.			Canada
Gold			LS MnM Inc.			Korea, Republic Of
Gold			Materion			United States Of America
Tin			Metallic Resources, Inc.			United States Of America
Gold			Metalor Technologies (Suzhou) Ltd.			China
Gold			Metalor Technologies (Hong Kong) Ltd.			China
Gold			Metalor Technologies (Singapore) Pte., Ltd.			Singapore
Gold			Metalor Technologies S.A.			Switzerland
Gold			Metalor USA Refining Corporation			United States Of America
Gold			Metalurgica Met-Mex Penoles S.A. De C.V.			Mexico
Tantalum			Metallurgical Products India Pvt., Ltd.			India
Tantalum			Mitsui Mining and Smelting Co., Ltd.			Japan
Gold			Mitsui Mining and Smelting Co., Ltd.			Japan
Tantalum			Ningxia Orient Tantalum Industry Co., Ltd.			China
Tin			O.M. Manufacturing (Thailand) Co., Ltd.			Thailand
Gold			Ohura Precious Metal Industry Co., Ltd.			Japan

Gold			MKS PAMP SA			Switzerland
Tin			PT Mitra Stania Prima			Indonesia
Gold			Royal Canadian Mint			Canada
Gold			Solar Applied Materials Technology Corp.			Taiwan, Province Of China
Tantalum			Taki Chemical Co., Ltd.			Japan
Tantalum			Ulba Metallurgical Plant JSC			Kazakhstan
Gold			Umicore S.A. Business Unit Precious Metals Refining			Belgium
Gold			United Precious Metal Refining, Inc.			United States Of America
Gold			Western Australian Mint (T/a The Perth Mint)			Australia
Tungsten			Wolfram Bergbau und Hutten AG			Austria
Tungsten			Xiamen Tungsten Co., Ltd.			China
Tungsten			Ganzhou Jiangwu Ferrotungsten Co., Ltd.			China
Tungsten			Jiangxi Yaosheng Tungsten Co., Ltd.			China
Tungsten			Jiangxi Xinsheng Tungsten Industry Co., Ltd.			China
Tungsten			Ganzhou Seadragon W & Mo Co., Ltd.			China
Tantalum			D Block Metals, LLC			United States Of America
Tantalum			FIR Metals & Resource Ltd.			China
Tin			O.M. Manufacturing Philippines, Inc.			Philippines
Tungsten			H.C. Starck Tungsten GmbH			Germany
Tungsten			Masan High-Tech Materials			Viet Nam
Tantalum			TANIOBIS Co., Ltd.			Thailand
Tantalum			TANIOBIS GmbH			Germany
Tantalum			Materion Newton Inc.			United States Of America
Tantalum			TANIOBIS Japan Co., Ltd.			Japan
Tantalum			TANIOBIS Smelting GmbH & Co. KG			Germany
Tungsten			Jiangwu H.C. Starck Tungsten Products Co., Ltd.			China
Tantalum			Global Advanced Metals Boyertown			United States Of America
Tantalum			Global Advanced Metals Aizu			Japan
Tungsten			Niagara Refining LLC			United States Of America
Gold			WIELAND Edelmetalle GmbH			Germany
Tin			Guangdong Hanhe Non-Ferrous Metal Co., Ltd.			China
Tin			Chifeng Dajingzi Tin Industry Co., Ltd.			China
Tin			Tin Technology & Refining			United States Of America
Tin			PT Mitra Sukses Globalindo			Indonesia
Gold			CCR Refinery - Glencore Canada Corporation			Canada
Tin			Alpha Assembly Solutions Inc			United States Of America
Gold			Kennecott Utah Copper LLC			United States Of America
Tin			PT Prima Timah Utama			Indonesia
Gold			Rand Refinery (Pty) Ltd.			South Africa
Gold			SEMPSA Joyeria Plateria S.A.			Spain
Gold			Valcambi S.A.			Switzerland
Tin			White Solder Metalurgia e Mineracao Ltda.			Brazil
Gold			Zhongyuan Gold Smelter of Zhongjin Gold Corporation			China
Tungsten			Jiangxi Gan Bei Tungsten Co., Ltd.			China
Tin			PT ATD Makmur Mandiri Jaya			Indonesia

Tungsten			Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch			China
Tin			PT Cipta Persada Mulia			Indonesia
Tin			Luna Smelter, Ltd.			Rwanda
Gold			Shandong Zhaojin Gold & Silver Refinery Co., Ltd.			China
Gold			Jiangxi Copper Co., Ltd.			China
Gold			Shandong Gold Smelting Co., Ltd.			China
Tungsten			Xiamen Tungsten (H.C.) Co., Ltd.			China
Tin			Magnu's Minerais Metais e Ligas Ltda.			Brazil
Tin			PT Rajehan Ariq			Indonesia
Tin			Mining Minerals Resources SARL			Congo, Democratic Republic Of The
Gold			Japan Mint			Japan