Conflict Minerals Report

Overview

Merit’s Business

Merit is a leading manufacturer and marketer of proprietary medical devices used in interventional, diagnostic, and therapeutic procedures, particularly in cardiology, radiology, oncology, critical care, and endoscopy.

Our world headquarters is located in South Jordan, Utah, with our principal office for European operations located in Galway, Ireland and our principal office for Asian distribution located in Beijing, China. We also support our European operations from a distribution and customer service facility located in Maastricht, The Netherlands. In addition, we lease commercial space in India, Hong Kong, Italy, Dubai, Australia, Canada, Brazil, Malaysia, South Korea, Japan, South Africa, Singapore, Great Britain, Vietnam, Taiwan, New Zealand, Indonesia, and France, as well as in California and Texas. Our principal manufacturing and packaging facilities are located in Utah, Virginia, Texas, Florida, Ireland, Brazil, Singapore, Mexico, France, and The Netherlands. Our research and development activities are conducted principally at facilities located in Utah, California, Texas, Ireland, and France.

We design, develop, market, and manufacture, through our own operations and contract manufacturers, medical products that offer a high level of quality, value, and safety to our customers, as well as the patients they serve. Our products are used in the following clinical areas: radiology; diagnostic and interventional cardiology; interventional radiology; neurointerventional radiology; vascular, general and thoracic surgery; electrophysiology; cardiac rhythm management; interventional pulmonology; interventional nephrology; orthopedic spine surgery; interventional oncology; pain management; breast cancer surgery, outpatient access centers; intensive care; imaging; and interventional gastroenterology. These products are collectively referred to as “Covered Products.”

Reasonable Country of Origin Inquiry

We have reviewed internal product information and conducted a survey of suppliers of metal parts for the Covered Products. Based on inquiries to suppliers of components and subassemblies within the Covered Products, we have determined that 3TG are necessary to the functionality or production of the Covered Products manufactured or contracted to manufacturing during calendar year 2025. Accordingly, the Company conducted in good faith a reasonable country of origin inquiry (the “RCOI”) to determine whether any 3TG contained in the Covered Products originated in the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and/or Angola (together the “Covered Countries”).

The elements of the RCOI were identification of the relevant suppliers; data collection; and assessment to determine whether further due diligence was required.

• Identification of the suppliers: We identified 36 suppliers that may have provided 3TG used in the Covered Products (the “Supplier Group”) and received completed CMRT responses from 30 of the 36 identified suppliers (approximately 83%).
• Data Collection: We distributed information to the Supplier Group about the Rule and requested information regarding the source of 3TG contained in the components and subassemblies supplied to manufacture the Covered Products. We sent the Supplier Group the Conflict Minerals Reporting Template (the “CMRT”) developed by the Responsible Minerals Initiative (“RMI”). The CMRT is designed to obtain sourcing information on the 3TG contained in materials manufactured or supplied by the Supplier Group used in the Covered Products, or as a company-level declaration, including information on the type of 3TG involved, the source and country of origin of the 3TG, as well as the smelters and refiners of those 3TG. We reviewed responses to the CMRT for plausibility, consistency, and completeness. We also reviewed smelters or refiners reported on responses to the CMRT against the Responsible Minerals Assurance Process (“RMAP”)-Active database that contains all the smelters or refiners that are under the RMI RMAP-Active Program. For smelters or refiners that could not be identified against the RMAP-Active database, we checked the smelter against the Covered Countries list. Of the 36 entities identified in the Supplier Group, we received complete CMRT responses from more than 83% of the entities. A significant portion of the smelters identified against the RMAP-Active database were listed as conformant or active under the RMAP, while others were either not participating or could not be verified. The Company continues to engage suppliers to encourage use of conformant smelters.
• Assessment: Based on the RCOI, the Company has reason to believe that some 3TG may have originated in the Covered Countries. Accordingly, we conducted further due diligence on the source and chain of custody of 3TG contained in components and subassemblies provided by the Supplier Group.

Due Diligence Process

Design of Due Diligence Measures

Our due diligence measures are designed to align, in all material respects, with the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This work is integrated with the Company’s broader trade compliance and supplier governance processes.

Due Diligence Performed

Step 1: Establish Strong Company Management Systems

The Company has established a management system to determine the source and chain of custody of 3TG in our supply chain, including the following key components:

Conflict Minerals Policy. We have adopted a Conflict Minerals Policy that outlines to suppliers and customers our commitment to responsible sourcing of 3TG throughout our supply chain and to compliance with the Rule. The Conflict Minerals Policy is publicly available on our website at: https://www.merit.com/compliance/conflict-minerals-policy/

Internal Team. Our management system includes oversight of our RCOI and due diligence processes by a team made up of representatives from various departments within the Company, such as Operations (which includes members from our manufacturing and procurement functions), Environment, Social and Governance, and Legal. The team is responsible for assessing any risks that may exist in our supply chain. Our Vice President, Environment, Social and Governance (“ESG”), oversees the work of our 3TG compliance team.

Control Systems. We utilize the CMRT sent to the Supplier Group to gather information on the chain of custody of 3TG included in the Covered Products.

Supplier Engagement. Our Vice President, Global Strategic Sourcing, has communicated to the Supplier Group our obligations under the Rule by distributing to them the CMRT and providing them with information on compliance with the Rule.

Grievance Mechanism. We have a company level grievance mechanism as part of our Code of Conduct for Suppliers and Code of Conduct for Employees, as well as an ethics hotline hosted by a third party that provides both internal and external stakeholders with a mechanism to report violations of our policies or other concerns. We have procedures in place for follow-up in the event any conflict minerals issues are raised through our grievance mechanism.

Record retention. We have a record retention policy applicable to conflict minerals-related documentation.

Step 2: Identify and Assess Risk in the Supply Chain

Distribution of CMRT to Supplier Group. In 2025, Our Vice President, Global Strategic Sourcing, distributed the CMRT to the Supplier Group to gather information on our supply chain, including (i) whether any of the minerals which could potentially be classified as 3TG are contained in materials the Supplier Group supplied to Merit or its contract manufacturers and (ii) whether those minerals originated from the Covered Countries.

Assessment of Supplier Group Responses. Of the relevant entities comprising the Supplier Group, we received complete CMRT responses from more than 83% of the group. We reviewed each response to assess the adequacy of such response. Suppliers that initially failed to respond to the CMRT or that did not provide responses to all applicable questions in the CMRT received follow-up communications from the Company requesting additional information. If supplier responses indicated that 3TG contained in components and subassemblies for the Covered Products may have originated from the Covered Countries and are not conformant to the RMI RMAP (or a cross-recognized program), then such responses were reviewed by the Company and reported to our Strategic Global Sourcing department for further review and determination of follow-up actions.

Step 3: Design and Implement a Strategy to Respond to Identified Risks

We work to implement a risk management plan to address concerns that a supplier may be providing 3TG sourced from the Covered Countries for the production of the Covered Products. If a supplier indicates that its products may contain 3TG sourced from the Covered Countries, we follow-up with the supplier to gather more information, including the basis for the information provided and other information regarding the sourcing country and smelter or refiner. Identified risks are reported to the Vice President, Environment, Social and Governance, who determines appropriate follow-up actions, if any, to mitigate risks.

Step 4: Report on Supply Chain Due Diligence

This report will be filed with the SEC and be publicly available at: https://www.merit.com/compliance/conflict-minerals-report/. The reference to the Company’s website is provided for convenience only, and its contents are neither incorporated by reference into this report nor deemed filed with the SEC.

Due Diligence Results

Based on completed CMRT responses, we identified 368 unique smelters or refiners that may have processed 3TG used in the Covered Products. A list of those smelters and the smelter country is attached as Appendix 1. Because many supplier responses are provided at the company level rather than the product level, the reported smelters and refiners may include facilities that do not supply materials used in our Covered Products. Some reported facilities are located in jurisdictions that may present heightened geopolitical, trade, or ESG-related risks; however, because the data is not product-specific, we cannot determine whether materials from those facilities are contained in the Covered Products. We expect suppliers to comply with applicable trade laws and continue to evaluate risk mitigation actions through our supplier governance process. In addition, due to the multi-tiered nature of global supply chains and our reliance on company-level supplier responses, we cannot determine with certainty the specific smelters, refiners, or countries of origin associated with the 3TG used in the Covered Products. As a result, as of this reporting period, the Company does not know all facilities used to process the 3TG in the Covered Products or the country of origin of all such 3TG.

Steps to be Taken to Mitigate Risk

• Continue to work closely with the Supplier Group to obtain the necessary information on the origin of 3TG contained in the materials or components used in the Covered Products and continue to refine our applicability assessment process.
• Monitor and encourage the continuing development and progress of traceability measures of the suppliers within the Supplier Group, which indicated that the source of 3TG was unknown or not determined.
• Engage suppliers to request smelters or refiners who do not participate in the RMI RMAP (or a cross-recognized program) to participate, or to work to transition away from such smelters or refiners.

Cautionary Statement about Forward-Looking Statements

This report contains “forward-looking statements” within the meaning of Section 21E of the Securities Exchange Act of 1934 as amended. Forward-looking statements are those that address activities, events, or developments that we or our management intends, expects, projects, believes, or anticipates will or may occur in the future. They are based on management’s assumptions and assessments in the light of past experience and trends, current economic and industry conditions, expected future developments and other relevant factors. They are not guarantees of future performance, and actual results, developments and business decisions will likely differ, and may differ materially, from those envisaged by our forward-looking statements. Our forward-looking statements are also subject to risks and uncertainties, which can affect our performance in both the near and long term. These forward-looking statements should be considered in the light of the information included in this report and our other filings with the SEC, including, without limitation, the “Risk Factors” as well as the description of trends and other factors in “Management’s Discussion and Analysis of Financial Condition and Results of Operations” set forth in our Annual Report on Form 10-K for the year ended December 31, 2025, our Quarterly Report on Form 10-Q for the quarter ended March 31, 2025 and our other filings with the SEC.

Appendix 1

Known Smelters and Locations