MDU Resources (MDU) SDConflict minerals disclosure

MDU Resources Group, Inc.

Conflict Minerals Report

For The Year Ended December 31, 2021

Introduction

This Conflict Minerals Report (the “Report”) has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), for the reporting period from January 1 to December 31, 2021.

The Report relates to the process undertaken by MDU Resources Group, Inc. (herein referred to as “MDU Resources,” the “Company,” “we,” “us,” or “our”) with respect to products that were manufactured, or contracted to be manufactured, during calendar year 2021 and that contain cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten for purposes of this Report (collectively, the “Conflict Minerals”).

Third-party products that we sell but do not manufacture or contract to manufacture are outside the scope of this Report.

Company and Products Overview

The Company, through its wholly owned subsidiary MDU Construction Services Group, Inc. (“MDU Construction Services”), provides inside and outside specialty contracting services. MDU Construction Services, through its wholly owned subsidiary Wagner-Smith Equipment Co., manufactures construction equipment consisting of electric transmission line pullers, tensioners, reel stands, reel carriers, and electric transmission pole and material trailers (the “Construction Equipment”).

Based upon our internal assessment, certain of the Construction Equipment products that are either manufactured or contracted to be manufactured by MDU Construction Services contain Conflict Minerals that may be necessary to the functionality of the product.

Conflict Minerals Program

Our Conflict Minerals program has been developed in conformity with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition), and related Supplement on Tin, Tantalum, and Tungsten, and Supplement on Gold (collectively, the “OECD Guidance”), specifically as it relates to our position in the minerals supply chain as a “downstream” purchaser.

Reasonable Country of Origin Inquiry

We have conducted a reasonable country of origin inquiry (an “RCOI”) regarding the Conflict Minerals purchased by the Company that was reasonably designed to determine whether any such Conflict Minerals originated in the Democratic Republic of the Congo or adjoining countries (collectively, the “Covered Countries”) or were from recycled or scrap sources. We identified 86 suppliers that provided components or engaged in manufacturing activities for use in our Construction Equipment products that may contain Conflict Minerals during calendar year 2021. In January 2022, we contacted these suppliers and provided them with a copy of our Conflict Minerals Policy, the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (the “Template”), and an instructional letter to assist them in completing their responses. The Template includes questions regarding a supplier’s applicable policy, engagement with its direct suppliers, and a listing of the smelters and refiners the supplier and its suppliers use. In addition, the Template contains questions about the origin of Conflict Minerals included in the supplier’s products, as well as the supplier’s due diligence processes. We requested responses by April 1, 2022 and conducted multiple follow-ups by email and telephone with the suppliers that did not respond to the initial request.

Design of Due Diligence

Our Conflict Minerals due diligence measures have been designed to conform to the due diligence-related steps of the OECD Guidance, as applicable for a “downstream” purchaser.

Due Diligence Measures Performed

Below is a description of the measures we performed to exercise due diligence on the source and chain of custody of the necessary Conflict Minerals contained in our Construction Equipment.

Due Diligence Results

For reporting year 2021, we surveyed 86 suppliers of materials for our Construction Equipment using the Template. Of the suppliers surveyed, 63 percent (54 suppliers) responded to our request for information. We have relied on these suppliers' responses to provide us with information about the source of Conflict Minerals contained in the components supplied to us. Our direct suppliers’ responses are similarly reliant upon information provided by their suppliers.

We requested mine or location of origin information for the necessary Conflict Minerals from each of our suppliers using the Template. Many of our suppliers were unable to obtain reliable mine or location-of-origin data for their necessary Conflict Minerals.

Two smelters, Luna Smelter, Ltd in Rwanda and African Gold Refinery in Uganda, were identified by some of our suppliers as having its location in a Covered Country. Luna Smelter, Ltd. is listed as a conformant smelter by the RMI, while African Gold Refinery is not currently listed as a conformant or active facility by the RMI.

Determination

Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals in our Construction Equipment or whether the Conflict Minerals are from recycled or scrap sources. On the basis of the due diligence measures described in this Report, we are unable to rule out that some of the Conflict Minerals used in our Construction Equipment products may have originated in the Covered Countries and are not from recycled or scrap sources, but we have not identified any instances in which our sourcing of necessary Conflict Minerals directly or indirectly financed or benefited armed groups in the Covered Countries.

We have provided information as of the date of this Report. Subsequent events may affect our future determinations under the Rule.

Future Due Diligence Measures

As we continue to enhance our due diligence program, we intend to take the following steps, among others, to continue to mitigate the risk that the necessary Conflict Minerals in our Construction Equipment could benefit armed groups in the Covered Countries: