China Mobile (CHL) SDConflict minerals disclosure

Exhibit 1.01

EXHIBIT 1.01 – CONFLICT MINERALS REPORT

China Mobile Limited

Conflict Minerals Report

For The Year Ended December 31, 2021

This Conflict Minerals Report for China Mobile Limited (together with its consolidated subsidiaries, “China Mobile,” “we,” or “our”) 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, 2021 (the “Reporting Period”).

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the rules promulgated by the United States Securities and Exchange Commission (“SEC”) thereunder (collectively, the “Conflict Minerals Rule”) contain disclosure and due diligence requirements on SEC-reporting issuers that manufacture or contract to manufacture products that contain “conflict minerals” that are necessary to the functionality or production of those products. Conflict minerals are defined under the Conflict Minerals Rule to include tin, tantalum, tungsten and gold.

We provide full communications services in all 31 provinces, autonomous regions and directly-administered municipalities in the mainland of China as well as in Hong Kong. Based on publicly available information, we are the leading provider of telecommunications and information services in the mainland of China, and a world-class provider with the world’s largest network and customer base as of December 31, 2021. As of March 31, 2022, our total number of mobile customers reached approximately 967 million.

In its ordinary course of business, China Mobile and its subsidiaries engage in the sale of certain telecommunications equipment and terminals (“Products”). No Products are manufactured by China Mobile, but some Products are contracted by certain of our wholly-owned subsidiaries and business units (collectively, the “Device Subsidiaries”) to be manufactured by third parties. China Mobile has determined that “conflict minerals” (also referred to herein as “3TG”) are necessary to the functionality or production of certain Products that China Mobile engaged third party manufacturers to produce during the Reporting Period. See “III. Product Description.”

In accordance with the Conflict Minerals Rule, China Mobile’s compliance procedure includes a reasonable country of origin inquiry (“RCOI”) seeking to identify the location of the smelter/refiner facilities used to refine or process the 3TG used in Products. As China Mobile is a downstream supplier of finished products and does not purchase from, and has no established commercial relationships with, smelters or refiners of conflict minerals, China Mobile’s RCOI focused on its direct suppliers.

Specifically, in January 2022, China Mobile coordinated with each of its consolidated subsidiaries and requested 136 direct suppliers to complete a Conflict Minerals Reporting Template (the “CMRT”).

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Each of these direct suppliers supplied Products, some of which were manufactured by certain of these suppliers, to China Mobile during the Reporting Period. The CMRT was developed by the Responsible Minerals Initiative (“RMI”, see http://www.responsiblemineralsinitiative.org/) to assist companies in determining the smelter/refiner facilities contributing 3TG to their products and requests information regarding the supplier’s own “conflict minerals” diligence policies, in addition to the identification of smelter/refiner facilities within the supply chain, and the country of origin of the 3TG used by such facilities. Based on responses received from these direct suppliers, China Mobile identified that Products of 127 direct suppliers contained 3TG during the Reporting Period. China Mobile then further assessed such direct suppliers’ CMRT responses using data provided by RMI. While the RCOI did not reveal any Products containing conflict minerals that were originated from the Democratic Republic of the Congo (the “DRC”) or an adjoining country as defined in the instructions to Form SD (together with DRC, the “Covered Countries”) and were not from recycled or scrap sources, there remains a risk that conflict minerals used in Products supplied by other suppliers may have originated in a Covered Country and may not be from recycled or scrap sources due to, among others, the incompleteness of the direct suppliers’ CMRT responses. See “II. Due Diligence—B. Due Diligence Measures—(ii) Identify and assess risks in the supply chain”. Therefore, China Mobile conducted due diligence on the source and chain of custody of the conflict minerals contained in Products supplied to it by its direct suppliers for the Reporting Period.

In addition to China Mobile’s compliance with the due diligence required by the Conflict Minerals Rule, China Mobile has adopted a five-step framework recommended by the Organization for Economic Co-operation and Development in its Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition (2016)) (the “OECD Guidance”) as applicable for “downstream companies” (as defined in the OECD Guidance).

The OECD Guidance sets forth the following five steps for establishing a responsible supply chain: (i) establishing strong company management systems, (ii) identifying and assessing risks in the supply chain, (iii) designing and implementing a strategy to respond to identified risks, (iv) carrying out internal as well as independent third party audit of supply chain due diligence at identified points in the supply chain, and (v) reporting annually on supply chain due diligence.

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During the Reporting Period, China Mobile had nine Device Subsidiaries, namely (i) China Mobile Device, an entity engaged in the procurement and distribution of mobile telephones, tablets and other devices; (ii) MIGU, an entity established for the provision, operation and service integration of digital content products, which includes music, video, reading, games and animation businesses; (iii) China Mobile IoT, an entity that operates IoT network and OneNET, an IoT open platform, designs and develops IoT modules and chips, develops IoT solutions and featured IoT products such as Internet of vehicles, smart home devices and smart wearables; (iv) G&E, an entity mainly engaged in the sales of information technology products to, and providing end-to-end services for, corporate customers such as governmental agencies and large enterprises, and nationwide corporate product integration and promotion; (v) Hangzhou R&D, an entity that engages in developing network equipment as well as providing information technology support for mobile terminals, software and related services; (vi) Suzhou R&D, an entity engaged in

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business development, software sales, system integration and others in the fields of cloud computing, big data and IT support; (vii) OSC, an entity that mainly provides customers with digital and intelligent services; (viii) Design Institute, an entity that mainly provides telecommunications network planning design and consulting services; and (ix) Chengdu ICT, an entity that mainly provides information communication technology research and development, supporting and operation services. China Mobile requested each of the direct suppliers to such Device Subsidiaries for Products containing 3TG to respond to the supply chain survey.

After assessing the risks in its supply chain during the Reporting Period, China Mobile concluded that because suppliers of certain Products containing 3TG may have provided incomplete information regarding metal origins and conflict-free sourcing to China Mobile and the reliability of the information provided has yet to be verified, there could be risks that certain 3TG used in the manufacturing might have originated in the Covered Countries and may not have originated from recycled or scrap sources.

As a downstream supplier of finished products, China Mobile has no direct commercial relationships with smelters or refiners. China Mobile’s due diligence efforts rely on cross-industry initiatives, such as RMI, to conduct audits of the due diligence practices at identified points of the smelters and refiners in the supply chain. In addition, China Mobile’s internal audit department conducts audit review on the conflict mineral due diligence process on a yearly basis to ensure accuracy and establish closed-loop management.

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China Mobile reports annually on its supply chain due diligence by preparing this Conflict Minerals Report to disclose the description of the measures taken to determine the source and chain of custody of any of the necessary conflict minerals contained in China Mobile’s products, as well as the results of China Mobile’s due diligence. This Conflict Minerals Report is available on China Mobile’s corporate website (http://www.chinamobileltd.com/en/ir/sec.php). The information contained in such website is not a part of this Form SD.

The due diligence process discussed above is an ongoing process. At this time, China Mobile takes the following actions to improve the due diligence process and to further mitigate any risk that conflict minerals necessary to the functionality or production of Products could benefit or finance armed groups in the Covered Countries.

Based on the due diligence efforts described above, China Mobile is unable to determine the source of the conflict minerals used in the following Products:

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As part of its due diligence, China Mobile endeavors to determine the countries of origin of the necessary conflict minerals in Products with the greatest possible specificity. Based on the information provided by the suppliers, China Mobile believes that the facilities used to process the necessary conflict minerals in Products include the smelters and refiners listed in Annex I below.

Based on the due diligence efforts as described above in this report, China Mobile was not able to obtain sufficient information to conclusively determine the countries of origin of the necessary conflict minerals in its Products mentioned above or whether such necessary conflict minerals are from recycled or scrap sources. However, based on the information provided by suppliers, China Mobile believes that the countries of origin of the necessary conflict minerals contained in Products include those countries listed in Annex II below.

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