The Clorox Company Announces Compliance with Rule 13p‑1 and Updates on Conflict‑Mineral Sourcing

On June 1 2026, The Clorox Company filed a specialized disclosure report (SD form) summarizing its compliance with Rule 13p‑1 of the Securities Exchange Act. The filing, covering the calendar year ending December 31 2025, presents an updated conflict‑mineral report that addresses the company’s use of the critical minerals coltan, cassiterite, gold, and wolframite—collectively referred to as 3TG.

Key Findings

  • Limited 3TG Exposure – The report confirms that the majority of Clorox’s product lines do not rely on 3TG minerals. Only a small subset of the company’s water‑filtration, laundry‑additive, personal‑care, and cleaning products incorporate these minerals.
  • Supplier‑Based Due Diligence – Clorox’s due‑diligence framework is anchored in supplier information. Each direct supplier must adhere to a business‑partner code of conduct that requires transparent sourcing and conflict‑free practices.
  • Responsible Minerals Initiative Survey – Suppliers were surveyed using a standard template from the Responsible Minerals Initiative (RMI). The survey identified whether their materials contained 3TG minerals and, if so, whether those minerals originated from the Democratic Republic of the Congo (DRC) or neighbouring countries.
  • Third‑Party Verification – The company cross‑checked supplier claims against a recognised third‑party audit database to confirm that smelters and refiners complied with responsible‑minerals standards.
  • Recycled or Scrapped Sources – Of the suppliers that reported the presence of 3TG, Clorox was able to confirm that the minerals originated from recycled or scrap sources in most cases.
  • Compliance‑Certified Smelters – The report identifies 21 smelters that have achieved compliance status.
  • Uncertified Origins – In a handful of instances, the company could not ascertain the precise country of origin for the minerals.

Strategic Implications

Clorox’s disclosure underscores a broader industry trend: manufacturers in consumer goods are increasingly integrating detailed supply‑chain transparency into their corporate governance. By committing to annual compliance with Rule 13p‑1, the company aligns itself with regulatory expectations while mitigating reputational risk associated with conflict minerals.

The emphasis on recycled or scrap sources reflects a growing shift toward circular economy principles, which can reduce dependency on conflict‑prone regions and lower environmental impact. Additionally, the identification of compliant smelters provides a clearer pathway for the company to secure ethically sourced raw materials, potentially strengthening its competitive positioning in markets where sustainability credentials drive consumer choice.

Future Directions

Clorox has outlined a series of initiatives to refine its supply‑chain monitoring:

  1. Enhanced Supplier Engagement – Continued dialogue with suppliers to secure up‑to‑date information on material sourcing.
  2. Reassessment of Due‑Diligence Procedures – Ongoing evaluation of internal processes to ensure they remain robust against evolving regulatory and market demands.
  3. Increased Transparency – Commitment to publishing more detailed data on conflict‑mineral sourcing to satisfy stakeholders and regulators.

The company’s disclosure is publicly available on its website, providing an open channel for investors, analysts, and consumers to review its compliance status.

By integrating rigorous analytical methods and adaptive strategies, Clorox demonstrates how a mature consumer‑goods company can navigate the complex terrain of responsible sourcing while maintaining a focus on core business principles and broader economic trends.