Philip Morris International Inc.

05/22/2026 | Press release | Distributed by Public on 05/22/2026 04:03

Specialized Disclosure Report (Form SD)


Exhibit 1.01
CONFLICT MINERALS REPORT OF PHILIP MORRIS INTERNATIONAL INC. FOR THE YEAR ENDED DECEMBER 31, 20251

INTRODUCTION
Philip Morris International Inc., a Virginia holding company, was incorporated in 1987. Our subsidiaries and affiliates and their licensees are engaged in the manufacture and sale of cigarettes and smoke-free products.2 We operate in markets primarily outside of the United States of America, with manufacturing and sales facilities in various locations around the world.
This Conflict Minerals Report (the "Report") is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Rule 13p-1"), for the reporting period from January 1 to December 31, 2025.
Conflict Minerals are defined by the Securities and Exchange Commission (the "SEC") as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the "3TGs"). During the reporting period, we contracted to manufacture the following products within the meaning of Rule 13p-1:
•Heat-Not-Burn Products, which use precisely controlled heating devices which use our various patented technologies, into which specially designed and proprietary tobacco units are inserted in a holder and heated to generate an aerosol. This category also includes related accessories and parts; and
•E-Vapor products. which are battery powered devices that produce an aerosol by vaporizing a tobacco-free liquid solution.
In this report, we refer to these products as "Covered Products."
In 2025, we sourced our Covered Products from eight direct suppliers (the "Direct Suppliers"). The electronic components of the Covered Products contain one or more 3TGs. The 3TGs used in the Covered Products are necessary for the functionality or production of the Covered Products.
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1 In this report, "PMI," "Company," "we," "us," and "our" refers to Philip Morris International Inc. and its subsidiaries.
2 Smoke-free products ("SFPs") is the term PMI uses to refer to all of its products that provide nicotine without combusting tobacco, such as heat-not-burn, e-vapor, and oral smokeless, and that therefore generate far lower levels of harmful chemicals. As such, these products have the potential to present less risk of harm versus continued smoking.



We have implemented policies, procedures and due diligence processes to determine whether any of the 3TGs contained in the Covered Products are sourced from the Democratic Republic of the Congo ("DRC") or any of its adjoining countries ("Covered Countries") and contribute to the financing of armed conflict in the region. In order to support the economic activity in the region, we have communicated to our Direct Suppliers that we do not discourage them from sourcing 3TGs from the Covered Countries under our Conflict Minerals Policy, (also referred to in this report as the "Policy"), so long as they are sourced in accordance with our Responsible Sourcing Principles ("RSPs") and the Organization for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Guidance").
We are far removed from the sources of ores from which the 3TGs contained in the Covered Products are procured, as well as from the smelters and refiners that process those ores ("SORs"). Consequently, our efforts to identify the countries of origin for 3TGs that may be used in the Covered Products reflect both (i) our downstream position in the supply chain3; and
(ii) the applicable OECD Guidance (as defined below).

DUE DILIGENCE MEASURES
A.Design of Our Due Diligence Measures

In 2025, our Conflict Minerals due diligence processes were performed in line with the internationally recognized due diligence framework provided by the OECD Guidance, as applicable for 3TGs and downstream companies (as the term "downstream companies" is defined in the OECD Guidance).4 As described below, in 2025 our due diligence measures in relation to Covered Products included:
1.Identifying, assessing and prioritizing Conflict Minerals risks in our supply chain, including through enhanced data collection and review processes;
2.Engaging with our Direct Suppliers mandating their compliance to our RSPs and urging them to take a proactive role by inviting their value chain partners to join the Responsible Minerals Initiative (the "RMI");
3.Enhancing current strategies and strengthening deployment to address identified Conflict Minerals risks;
4.Requiring that, in relation to the Covered Products, our Direct Suppliers source only from SORs that have been validated as "RMAP-Compliant" by the RMI's Responsible Minerals Assurance Process ("RMAP"), the London Bullion Market Association ("LBMA"), the Responsible Jewelry Council, or a comparable program, and to undertake reasonable due diligence in their respective supply chains to ensure the same; and
5.Reporting annually on metrics relevant to PMI supply chain due diligence.

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3 As a result of our downstream position in the supply chain, our due diligence processes involve PMI seeking data from our Direct Suppliers and those suppliers seeking similar information in their respective supply chains to identify the original sources of the applicable Conflict Minerals. We also rely, to a large extent, on information collected and provided by third-party validation programs. Because our diligence processes rely on information provided by third parties, they may yield inaccurate or incomplete information.
4 "Downstream companies" include metal traders and exchanges, component manufacturers, product manufacturers, original equipment manufacturers and retailers.



B.Due Diligence Program Elements

1.Processes Implemented by Company Management

Conflict Minerals Policy

We have a Conflict Minerals Policy which is communicated to our Direct Suppliers to help achieve responsible sourcing of 3TGs in our supply chain. We are committed to operating with integrity and are focused on the responsible sourcing of 3TGs. In 2025, we further expanded the Policy to better align it with the evolving regulatory landscape outside of the U.S. The Policy is publicly available on our website at: http://www.pmi.com/our-views-and-standards/standards/transparency and it is also attached to this Report as Appendix A.

Internal Team

Under the oversight of our Chief Global Operations Officer, our conflict minerals team - expanded in 2025 into a broader Critical Raw Materials Working Group (the "Working Group") - is comprised of representatives from our operations, finance and legal functions.
This cross-functional Working Group has the overall responsibility for developing and implementing our Conflict Minerals compliance strategy, as well as for reviewing the ongoing progress and effectiveness of the Conflict Minerals reporting. In addition, when needed the Working Group engages with specialists in other functions throughout PMI to review and analyze the information relevant to PMI's Conflict Minerals due diligence processes and reporting, and to update our due diligence process in order to improve our Direct Suppliers' performance, where necessary. Beginning in 2024 and continuing through the first half of 2025, we conducted a sustainability impact assessment (analysis of social, environmental and supply chain risks) of PMI critical raw materials, including Conflict Minerals. This research will contribute to further improve our conflict minerals due diligence strategy.
As part of our 2025 organizational framework, our Product Regulatory Compliance Team, which was part of the Life Sciences Department reporting to our Chief Life Sciences Officer, also verified ingredients and materials used in the direct materials for our Covered Products. Any Conflict Minerals reporting and compliance matters that arose during this verification process were analyzed and addressed by the Working Group.

Our senior management and our Board of Directors are informed of the results of our due diligence efforts, supply chain integrity and relationships with our Direct Suppliers in regards to Conflict Minerals.



Supply Chain Transparency Framework

To support PMI's Conflict Minerals compliance and due diligence program, PMI's supply chain transparency framework combines internal activities, collaboration with our Direct Suppliers and reliance on the information published by industry programs such as the Responsible Minerals Initiative (the "RMI"). The RMI is a global, non-governmental organization that was founded in 2008 by members of the Responsible Business Alliance (the "RBA") and the Global e-Sustainability Initiative. It is comprised of over 500 companies and associations from a range of industries. The RMI focuses on the responsible sourcing of minerals and develops best practices and services to support responsible minerals sourcing. PMI joined the RBA and its Responsible Minerals Initiative in January of 2021.

As part of our Conflict Minerals due diligence processes, we require our Direct Suppliers to use RMI's Conflict Minerals Reporting Template ("CMRT") to collect and retain the necessary information on the chain of custody of the 3TGs contained in the parts of the Covered Products that they respectively supplied to us, including information about the SORs from which those 3TGs were sourced. We have agreed with all of our Direct Suppliers to increase the CMRT data collection frequency to twice a year. As such, for our Conflict Minerals Report for the year ended December 31, 2025, we used a biannual CMRT collection process. This increased frequency enables earlier identification of potential risks within the supply chains of our Covered Products and allows us to implement corrective measures even more promptly than under the previous approach. The CMRT is generally regarded as the most widely used standard to collect information about Conflict Minerals through the supply chain.

In addition to the CMRTs, we ask each of our Direct Suppliers to sign declarations on an annual basis certifying that to the best of their knowledge, the information provided to us in their CMRTs is accurate and complete, and that each Direct Supplier's certification is based upon that supplier's due diligence review and the reasonable country of origin inquiry with respect to any 3TGs in the Covered Products.

Furthermore, in an effort to further enhance our know-your-supplier processes and in close cooperation between our Procurement, Business Practice Compliance, and Legal teams, we have implemented and continue to employ a weekly sanctions screening process on the SORs identified in our supply chain.

Supplier Engagement and Other Compliance Efforts

Our Direct Supplier arrangements also include Conflict Minerals-related provisions that: (i) are consistent with our Conflict Minerals Policy, (ii) require our Direct Suppliers to comply with our due diligence requests; and (iii) encourage our Direct Suppliers to participate in industry-wide or material-specific supply chain mapping initiatives.
In addition, and consistent with our efforts as described in the Conflict Minerals report for the period ended December 31, 2024, in 2025, we continued to undertake the following efforts to further improve due diligence and supplier engagement:


•Supplier capability building through dedicated sessions focused on understanding compliance requirements for sourcing of conflict minerals, including the underlying SEC regulations.
•Further engagements with our Direct Suppliers to exercise reasonable due diligence on the source and chain of custody of minerals from conflict-affected and high risk areas, as described in our Policy and our Responsible Sourcing Principles. Our Direct Suppliers were further encouraged to actively engage in third party audit programs such as the RMAP and to participate in trainings provided by RMI with regards to Conflict Minerals sourcing, review their supply chain due diligence processes related to Conflict Minerals sourcing in terms of accuracy and timeliness of responses, and continue to improve compliance.
•Expanding our due diligence efforts to better align with the evolving regulatory landscape outside of the U.S. and amending our Conflict Minerals Policy accordingly.

As a result of our continuous improvement efforts, in 2025, we saw satisfactory levels of both timeliness and completeness of the information submitted to us by our Direct Suppliers. Specifically in 2025:

•We continued to deploy the RBA due diligence process to manage our supply chain - this program includes self-assessment questionnaires and a validated assurance program (that includes on-site audits) to monitor the sourcing of conflict minerals from our Direct Suppliers;
•We engaged with Direct Suppliers to ensure their understanding of our requirements relating to the responsible sourcing of minerals;
•We used our supplier due diligence program to assess our Direct Suppliers' compliance with our Responsible Sourcing Principles, which also cover the responsible sourcing of the 3TGs;
•We communicated to our Direct Suppliers our expectation that they use SORs certified as compliant with the Responsible Minerals Assurance Process ("Compliant SORs")5 for the manufacture of the Covered Products, and have held online conferences with our Direct Suppliers to reinforce this expectation. Please see "Section C" below for additional information;
•We continued to mandate conflict minerals due diligence based on the OECD Guidance and training as a prerequisite to engagement with any new direct suppliers of electronics;
•We continued to support our due diligence efforts with appropriate record retention practices; and
•We continued to regularly monitor and assess potential risks within our value chain, including those linked to sourcing of minerals.

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5 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process ("RMAP") and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of the audit, such SORs are then designated as RMAP-Compliant SORs.


Grievance Mechanism

We have a grievance mechanism called the PMI Ethics & Compliance Help Line that allows our employees, our business partners and stakeholders to report any suspected violation of PMI´s principles and practices to the senior management or the Ethics & Compliance Department. Reports can be made through face-to-face discussions or via email if the employee prefers to remain anonymous. We maintain both a dedicated email address: [email protected], and an independently operated and confidential Compliance Helpline, that operates a phone line and a webline. Concerns can also be reported by our employees confidentially or anonymously. Any such reports related to Conflict Minerals are to be forwarded to the Working Group that will review them and help design appropriate response measures. In addition, we encourage our suppliers to establish their own grievance mechanisms.

2.Identify and Assess Risk in the Supply Chain

We reviewed the answers to the CMRT received from our Direct Suppliers and assessed their completeness, clarity and consistency. We worked with our Direct Suppliers to understand their due diligence process, ensuring their understanding of our Conflict Minerals policy and requirements, as well as obtaining a list of SORs in their respective supply chains for the Covered Products.

Our Direct Suppliers confirmed that some of the SORs in their supply chain may source 3TGs from the Covered Countries and that the 3TGs may not be from recycled or scrap sources. As part of our risk assessment, we checked whether these SORs were Compliant SORs by comparing the facilities identified by our Direct Suppliers against the list provided by the RMI and its Responsible Minerals Assurance Process ("RMAP"), as well as the list provided by the London Bullion Market Association ("LBMA"). We also followed up with additional information requests to obtain the necessary details to better assess the reliability of the responses and the risks in our supply chain in instances where the responses received were not clear or where the SORs were not certified as RMAP-Compliant.
Please also see Section B.1 for the discussion of our efforts in 2025 to help identify and assess risk in our supply chain related to 3TG sourcing.

3.Design and Implement a Strategy to Respond to Risks in the Supply Chain

We designed a strategy to respond to risks related to Conflict Minerals in our supply chain. When the members of the Working Group become aware that the due diligence of our direct or indirect suppliers needs improvement, they provide feedback, ask clarifying questions and demand corrective actions where necessary. The members of the Working Group provide information and training to our Direct Suppliers and determine appropriate follow-up actions, if any, to mitigate any identified risks. Follow-up actions may include, but are not limited to, finding alternate sources of supply or terminating existing supplier relationships, as appropriate. We have communicated to our Direct Suppliers that they should further implement,



and communicate to their suppliers to implement, the due diligence standards that reflect the OECD Guidance. Steps to improve the accuracy of the due diligence process are described in Sections B.1 above and D below.

4.Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We rely on the RMI's Responsible Minerals Assurance Process for the performance of third-party audits of SORs. To the extent possible, we review whether any 3TGs sourced from the Covered Countries are "DRC conflict-free" based on the information provided by our Direct Suppliers and the information available on the RMI's website. We encourage our suppliers to join the RBA and the RMI. In addition, as described above, we have communicated to our Direct Suppliers our expectation that they use Compliant SORs for the manufacture of our Covered Products.

5.Report on Supply Chain Due Diligence
This Report will be filed with the SEC and will also be publicly available at http://www.pmi.com/our-views-and-standards/standards/transparency.

C.Reasonable Country of Origin Inquiry ("RCOI") and Due Diligence on the Source and Chain of Custody
We asked our Direct Suppliers to provide answers to the CMRT to ascertain whether any 3TGs contained in the Covered Products originated from Covered Countries. Based on the evaluation of our Direct Suppliers' responses to their CMRTs, we had reason to believe that some of the 3TGs in the Covered Products manufactured in 2025 may have originated in the Covered Countries and were not entirely from recycled or scrap sources.

With respect to the Covered Products, based on information received from our Direct Suppliers, for 2025: (i) 100% of their suppliers provided responses to via CMRTs; (ii) 3TGs contained in some Covered Products may have originated from the Covered Countries; and (iii) no 3TGs contained in the Covered Products come from recycled or scrap resources. On an aggregate basis, our Direct Suppliers have identified 284 SORs supplying 3TGs in our supply chain that were found to be eligible for the Reasonable Minerals Assurance Process. Of these SORs:

•229 (approximately 81%) were confirmed to be RMAP-Compliant or RMAP-Active,6 effectively confirming that they are already engaged in the Reasonable Minerals Assurance Process.

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6 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of such an audit, such SORs would become Compliant SORs.


•8 (approximately 3%) of the SORs in our supply chain were confirmed to be undergoing initial screening by RMAP. Our Working Group will continue tracking these SORs' progress in obtaining an RMAP-Compliant or RMAP-Active status by monitoring their engagement with RMI, and will engage with these SORs (either directly or through RMI) going forward in order to ensure that they are on track to be covered by RMAP.
•35 (approximately 12%) of the SORs in our supply chain were confirmed to be non-conformant. Our Conflict Minerals Team, directly or through RMI, will continue to engage with these SORs in order to encourage them to obtain RMAP certification and, if they are not responsive or not interested, we will ask our Direct Suppliers to disengage them from our supply chain for the Covered Products going forward.
•An additional 12 (approximately 4%) of the SORs in our supply chain were confirmed to be non-conformant and were identified to be unwilling or unresponsive in regards to obtaining RMAP certification. Our Working Group has requested the relevant Direct Suppliers to remove these 12 SORs from our supply chain for our Covered Products.
•Of these 284 SORs, 5 SORs were identified to be located in in 4 Covered Countries: 2 SORs in Rwanda, 1 SOR in the DRC, 1 SOR in Tanzania and 1 SOR in Uganda.
•All these 5 SORs were confirmed to be RMAP-Compliant.

D.Steps to Further Improve Due Diligence

As part of PMI's membership in RMI, in 2025 we continued our active participation in its projects and initiatives and further embedded RMI tools and guidance into our Conflict Minerals due diligence processes. Building on actions taken in prior years, our efforts in 2025 focused on strengthening the consistency, quality and effectiveness of due diligence implementation across our supply chain.

In particular, during 2025, we continued to:

•Engage with our Direct Suppliers under our Responsible Sourcing Principles framework to clarify and reinforce expectations related to the responsible sourcing of 3TGs for Covered Products from SORs;
•Encourage Direct Suppliers to further strengthen their due diligence measures in line with the OECD Guidance, with the objective of improving the quality, completeness and reliability of supply chain information available to PMI;
•Raise awareness and provide training to current and prospective Direct Suppliers on our Conflict Minerals Policy, grievance mechanisms and compliance expectations, including by encouraging participation in e-learning courses made available through the RBA eLearning Academy;
•Encourage Direct Suppliers to enforce their respective Conflict Minerals policies throughout their own value chains;
•Enhance collaboration with the RMI to support the effective use of RMI due diligence tools within relevant supply chains;
•Monitor developments related to conflict-affected and high-risk areas, including the Democratic Republic of the Congo and adjoining countries, and leverage RMI guidance and updates in this regard;



•Provide ongoing training to PMI employees involved in the procurement of materials in scope of Conflict Minerals due diligence to strengthen internal processes and improve data reliability;
•Further enhance the CMRT data review and assurance process with Direct Suppliers; and
•Following the positive outcome of the 2024 initiative to increase CMRT data collection frequency to a biannual basis, we continued applying this enhanced cadence throughout 2025 to increase transparency and support an improved due diligence performance for Covered Products.

In addition, PMI continued to engage with Direct Suppliers regarding non-conformant SORs to encourage progress toward RMAP or equivalent certification and, where such efforts were unsuccessful, to work with relevant Direct Suppliers to disengage such SORs from the supply chain for Covered Products, as appropriate.

Looking ahead, and consistent with the evolution of PMI's broader critical raw materials due diligence approach, in 2026 PMI expects to further strengthen its Conflict Minerals due diligence, through enhanced integration with broader risk-based due diligence activities, continued supplier engagement and training, the refinement of internal data review and escalation mechanisms, and the digitalization of data collection, risk assessment and mitigation. These efforts are intended to support the continuous improvement of PMI's Conflict Minerals due diligence program and its alignment with internationally recognized standards.

E.Independent Private Sector Audit
An independent private sector audit is not required for this Report.


Forward-Looking and Cautionary Statements
This Conflict Minerals Report contains projections of future results and goals and other
Philip Morris International Inc. published this content on May 22, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 22, 2026 at 10:04 UTC. If you believe the information included in the content is inaccurate or outdated and requires editing or removal, please contact us at [email protected]