Specialized disclosure report



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UNITED STATES




SECURITIES AND EXCHANGE COMMISSION




Washington, D.C. 20549




FORM SD




SPECIALIZED
DISCLOSURE REPORT




Imperial Oil Limited



(Exact name of the registrant as specified in its charter)

































CANADA





0-12014






98-0017682




(State or other jurisdiction of



incorporation or organization)





(Commission



File Number)





(IRS Employer



Identification No.)





505 QUARRY PARK BOULEVARD S.E., CALGARY, AB, CANADA, T2C 5N1



(Address of principal executive offices) (Postal Code)




Daniel E. Lyons (587)

476-3941




(Name and telephone number, including area code, of the person to contact in connection with this report)









Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form
applies:



[X] Rule

13p-1

under the Securities Exchange Act (17 CFR

240.13p-1)

for the reporting period from January 1 to December 31, 2020.

















Item 1.01




Conflict Minerals Disclosure




Section 13(p) of the Securities Exchange Act of 1934 and Rule

13p-1

thereunder (collectively, the “conflict
mineral rules”) require Imperial to make certain disclosures concerning supply sources for conflict minerals – principally consisting of gold, tin, tungsten, or tantalum – that may be necessary to the manufacture or functionality of
our products. Terms and phrases used but not defined in this disclosure have the meanings given under the conflict mineral rules.



Imperial manufactures
or contracts to manufacture certain catalysts for which tin or tungsten are necessary to the product’s functionality. Imperial also makes use of certain tin and tungsten catalysts in our own refineries and chemical plants. Depending on the type
of catalysis process used, trace amounts of such minerals may exist in some of our finished products.



Although these tin and tungsten catalysts are used
in compound form we have conducted in good faith a reasonable country of origin inquiry regarding the conflict minerals described above for 2020. Such inquiry is reasonably designed to determine whether any of these minerals originated in the
Democratic Republic of the Congo (“DRC”) or an adjoining country, or are from recycled or scrap sources. The inquiry included obtaining written representations from each of our suppliers for these minerals to the effect that (i) the
supplier has conducted its own reasonable country of origin inquiry within the meaning of the conflict mineral rules with respect to minerals sold to Imperial; and (ii) based on such inquiry, the supplier has determined such minerals do not
originate in the DRC or an adjoining country, or are from recycled or scrap sources, or the supplier has no reason to believe such minerals may have originated in the DRC or an adjoining country. We have also amended each of our contracts with
suppliers of conflict minerals to require the supplier to maintain procedures reasonably designed to ensure any conflict minerals sold to Imperial are not sourced from the DRC or an adjoining country, and to require prompt notice to Imperial of any
breach of this covenant.



Based on these inquiries, we have no reason to believe any of the conflict minerals necessary for products we manufactured or
contracted to manufacture in 2020 may have originated in the DRC or an adjoining country.



This Conflict Minerals Disclosure is available on
Imperial’s website at:







https://www.imperialoil.ca/-/media/Imperial/Files/00-SEC-Filing/2021/Form-SD-Conflict-minerals.pdf








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SIGNATURE



Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly
authorized undersigned.
































































Imperial Oil Limited












/s/ Daniel E. Lyons





May 26, 2021




By   Daniel E. Lyons






(Date)




Senior vice-president, finance and



administration, and controller



(Chief financial officer)












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The above information was disclosed in a filing to the SEC. To see the filing, click here.

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