Frequently Asked Questions

BASIC INFORMATION

1. What is this matter about?

On September 23, 2022, the Securities and Exchange Commission (or "SEC") issued an Order Instituting Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933 and Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order (the "Order") against Compass Minerals International, Inc. (the "Respondent"). Background on this case, including the Order, the Plan, and any other orders issued by the SEC in connection with this proceeding, is available on the SEC's website at: https://www.sec.gov/enforcement-litigation/distributions-harmed-investors/compass. In the Order, the SEC found that from 2017 to 2018, Compass made repeated misrepresentations about its plans to reduce costs and about the production levels at its Goderich salt mine in Canada. These misrepresentations were the consequence of a deficient disclosure process at the company in which statements to investors were not reviewed by personnel who were sufficiently knowledgeable about both Compass's operations and its disclosure obligations. The failures in Compass's disclosure controls and procedures resulted in material misstatements about the Goderich mine. The Goderich new mining system was unable to produce enough salt and the production shortfalls caused by the upgrade required the company to incur additional expenses that increased costs for Compass. Compass also misrepresented the amount of salt it was mining. In October 2018, Compass disclosed its continued production shortfalls which significantly impacted its financial results, thereby causing its share price to decline significantly. The company's senior management did not also have sufficient information about the environmental issues caused by a facility owned by its subsidiary in Brazil which resulted in imposed penalties from the Brazilian government and liabilities from third parties affected by these environmental issues, also resulting in financial consequences and risks. In addition to these violations, Compass filed material misstated financials which did not comply with General Accepted Accounting Principles (GAAP). The SEC ordered the Respondent to pay a $12,000,000.00 civil money penalty to the SEC. The SEC also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, so the penalty collected can be distributed to harmed investors (the "Fair Fund"). The Compass Minerals Fair Fund consists of the $12,000,000.00 collected from the Respondent. The Fair Fund has been deposited in a SEC-designated account at the U.S. Department of the Treasury, and any accrued interest will be added to the Fair Fund.

2. Why did I receive a Plan Notice?

You received a Plan Notice because you have been identified by the Fund Administrator as a person or entity who may have purchased or acquired Compass common stock during the period from March 2, 2017, through October 22, 2018, inclusive.

3. What is the Relevant Period?

The Relevant Period is from March 2, 2017, through October 22, 2018, inclusive. Please note, that in order to calculate your correct Recognized Loss amount, you may be asked to provide documentation outside of the Relevant Period, up to January 18, 2019.

4. How much is in the Compass Minerals Fair Fund?

The Fair Fund consists of the $12,000,000.00 paid by the Respondent plus accrued interest.

ELIGIBILITY

5. Who may be eligible for a payment from the Compass Minerals Fair Fund?

You may be eligible for a payment from the Compass Minerals Fair Fund if:

1. You purchased or acquired Compass common stock during the Relevant Period;
2. Your approved transactions calculate to a Recognized Loss, and your distribution amount is equal to or greater than the Minimum Distribution Amount of $10.00, as calculated under the Plan;
3. You are not an Excluded Party; and
4. You timely submitted a valid Claim Form.

To be considered for eligibility for a Distribution Payment from the Compass Minerals Fair Fund, you must timely submit the completed and signed Claim Form and any required documentation online or via mail to Compass Minerals Fair Fund, Fund Administrator, P.O. Box 25225, Santa Ana, CA 92799. Claim Forms completed online must be submitted on or before 11:59 p.m. Eastern Standard Time ("EST") on June 27, 2025. Claim Forms submitted via mail must be sent to the address provided on the Claim Form and postmarked (or if not sent by U.S. Mail, received) by June 27, 2025. Failure to timely submit the completed form with all requested documentation by the Claims Bar Date set forth in the Plan may result in your claim being rejected and you being precluded from any recovery from the Compass Minerals Fair Fund.

6. Who is excluded from payment from the Compass Minerals Fair Fund?

You are excluded from participation in the Compass Minerals Fair Fund if you are an Excluded Party as defined in the Plan, including:

1. The Respondent (Compass Minerals, Inc.);
2. Present or former officers or directors of the Respondent or any assigns, creditors, heirs, distributees, spouses, parents, dependent children or controlled entities of any of the foregoing Persons or entities;
3. Any employee or former employee of the Respondent or any of its affiliates who has been terminated for cause or has otherwise resigned, in connection with the conduct described in the Order;
4. Any Person who, as of the Claims Bar Date, has been the subject of criminal charges related to the conduct described in the Order or any related SEC action;
5. Any firm, trust, corporation, officer, or other entity in which Respondents has or had a controlling interest;
6. The Fund Administrator, its employees, and those Persons assisting the Fund Administrator in its role as the Fund Administrator; or
7. Any purchaser or assignee of another Person's right to obtain a recovery from the Fair Fund for value; provided, however, that this provision shall not be construed to exclude those Persons who obtained such a right by gift, inheritance or devise.

PLAN OF ALLOCATION

7. What is the Plan of Allocation?

The Plan of Allocation, available for review as Exhibit A of the Plan, states how Recognized Losses and Distribution Payments will be calculated. It is designed to compensate investors based on their losses on shares of Compass common stock (the "Security") that were purchased or acquired between March 2, 2017, and October 22, 2018, inclusive, (the "Relevant Period") due to the misconduct of the Respondent. Investors who did not purchase or acquire shares of the Security during the Relevant Period or who are an Excluded Party are ineligible to recover under this Plan. An investor who is not an Excluded Party under paragraphs 15(a)-(g) of the Plan, who submits a valid Claim Form, and who has suffered a Recognized Loss as calculated by the Plan of Allocation, will be deemed an Eligible Claimant. An Eligible Claimant whose Recognized Loss calculates to a distribution amount equal to or greater than $10.00, and will receive a Distribution Payment, will be deemed a Payee.

THE CLAIMS PROCESS

8. What is the deadline to submit a Claim Form?

The deadline to submit a Claim Form, also referred to as the "Claims Bar Date," is June 27, 2025.

Claim Forms completed online must be submitted on or before 11:59 p.m. EST on June 27, 2025.

Claim Forms submitted via mail must be sent to the address provided on the Claim Form and postmarked (or if not sent by U.S. Mail, then received) by June 27, 2025.

9. What do I need to submit a Claim Form online?

Online submissions are encouraged.

To submit a Claim Form online, go to Submit a Claim and follow the instructions provided.

As part of the Claim Form, you will be required to provide information necessary to substantiate the claim, including but not limited to: copies of third party documentary evidence of purchases and dispositions of the Security during the Relevant Period, as well as holdings of the Security at pertinent dates; any requested explanatory information or attestations; and/or any required personal identification information. If you are not a U.S. Person, as defined in Section IV of the Claim Form, you must also submit a completed IRS Form W-8BEN, W-8BEN-E, or other W-8 series form, which can be found by visiting the following IRS website: www.irs.gov/forms-instructions.

Claim Forms completed online must be submitted on or before 11:59 p.m. EST on June 27, 2025.

If you submit a Claim Form that fails to provide all required information or is otherwise deficient; or your claim is denied, you will receive a Claim Status Notice advising you of the reason(s) why the claim is deficient or denied and explaining how to cure the deficiencies or request reconsideration.

10. What do I need to submit a Claim Form via mail?

If you are unable to submit a Claim Form online, you may download a paper Claim Form here or request a copy of the paper Claim Form from the Fund Administrator via email at info@CompassMineralsFairFund.com or by calling 866-675-2446.

As part of the Claim Form, you will be required to provide information necessary to substantiate the claim, including but not limited to: copies of third party documentary evidence of purchases and dispositions of the Security during the Relevant Period, as well as holdings of the Security at pertinent dates; any requested explanatory information or attestations; and/or any required personal identification information. If you are not a U.S. Person, as defined in Section IV of the Claim Form, you must also submit a completed IRS Form W-8BEN, W-8BEN-E, or other W-8 series form, which can be found by visiting the following IRS website: www.irs.gov/forms-instructions.

Claim Forms submitted via mail must be sent to the address provided on the Claim Form and postmarked (or if not sent by U.S. Mail, then received) by June 27, 2025.

If you submit a Claim Form that fails to provide all required information or is otherwise deficient; or your claim is denied, you will receive a Claim Status Notice advising you of the reason(s) why the claim is deficient or denied and explaining how to cure the deficiencies or request reconsideration.

11. How will I find out about the outcome of my Claim?

Within 45 days of the Claims Bar Date, the Fund Administrator will send a Claims Status Notice to claimants with deficient claims and/or claims that will be denied, explaining how the claimant can cure deficiencies or seek a reconsideration of their claim.

Within 30 days of the Claims Bar Date, the Fund Administrator will send a Determination Notice to claimants, advising each claimant who submitted a Claim Form of their eligibility determination; and will further provide to those determined to be an Eligible Claimant, their calculated Recognized Loss. The Fund Administrator may consider disputes of an Eligible Claimant's Recognized Loss calculation if timely presented in accordance with the Plan.

Subject to paragraph 61 of the Plan, the Determination Notice will constitute the Fund Administrator's final ruling regarding the eligibility status of a claim.

DISTRIBUTION

12. When will Distribution Payments be disbursed?

There is no current estimate for when Distribution Payments will commence although the Fund Administrator, working with the SEC, intends to stay within the deadlines provided in the Plan. Please visit this website often to get the most up-to-date information.

13. Can I receive my payment in cryptocurrency?

No. Distribution Payments will be made in U.S. Dollars (USD).

ADDITIONAL INFORMATION

14. Who is the Tax Administrator?

On July 22, 2024, the SEC issued an order appointing Heffler, Radetich & Saitta, LLP, as the Tax Administrator of the Fair Fund. See the SEC Order: Release No: 34-100573.

15. Who is the Fund Administrator?

On November 26, 2024, the SEC issued an order appointing Simpluris, Inc. as the Fund Administrator, to oversee the administration and distribution of the Fair Fund and setting the administrator's bond amount. See SEC Order: Release No. 34-101761.

16. Where can I get additional information?

Copies of the Plan, the Notice, the Claim Form, and other relevant documents are available for download on the Important Documents page of this website. You can review also review background on this case, including the SEC's orders and the Plan, on the SEC's website at: https://www.sec.gov/enforcement-litigation/distributions-harmed-investors/compass

If you would like to request a copy of the Plan, the Plan Notice, and/or the Claim Form, or if you have any other questions, you may contact the Fund Administrator via email at info@CompassMineralsFairFund.com, or by calling 866-675-2446. The mailing address for the Fund Administrator is: Compass Minerals Fair Fund, Fund Administrator, P.O. Box 25225, Santa Ana, CA 92799.