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Conflict Minerals Policy

Background

As a public company, IDEX CORP. (“IDEX”) is subject to rules[1] issued by the U.S. Securities and Exchange Commission (“SEC”) implementing the conflict minerals disclosure provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  These rules require publicly traded companies in the U.S. to report annually on the extent to which products manufactured by or for the companies and their subsidiaries contain “Conflict Minerals” that are (i) necessary to the functionality or productions of those products and (ii) derived from sources that are believed to, directly or indirectly, finance armed conflict or benefit armed groups within The Democratic Republic of the Congo (“DRC”) or certain adjoining countries.[2]

The “Conflict Minerals” of concern are cassiterite (used to produce tin), wolframite (used to produce tungsten), columbite-tantalite (used to produce tantalum), and gold.  These Conflict Minerals are also commonly referred to as “3TGs.”

Commitment

IDEX is committed to complying fully with the SEC’s Conflict Minerals reporting requirements. To that end, IDEX and its manufacturing subsidiaries are working with applicable suppliers to perform the necessary due diligence in determining the potential for Conflict Minerals in their supply chain and products. IDEX and its manufacturing subsidiaries are designing their due diligence program in accordance with the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Expectations of Suppliers

IDEX expects that applicable suppliers will cooperate with its due diligence efforts in support of its Conflict Minerals commitment and otherwise assist IDEX in complying with the Conflict Minerals rules established by the SEC.  If a supplier to one of IDEX’s manufacturing subsidiaries is unwilling to support IDEX in its Conflict Mineral program efforts, IDEX and its subsidiaries may take remediation steps, up to and including alternative sourcing arrangements.  IDEX and its subsidiaries also may take remediation steps if a supplier cannot determine whether its materials or products contain Conflict Minerals.

In support of its Conflict Minerals commitment, IDEX expects that suppliers to its IDEX manufacturing subsidiaries will:

  • Establish a supplier Conflict Minerals policy in accordance with SEC rules (except with respect to SEC reporting requirements), implement management systems to support compliance with their policy, and require their suppliers of any tier to take the same steps;
  • Identify, in the manner and form specified by IDEX and its manufacturing subsidiaries, materials or products they sell to the applicable IDEX manufacturing subsidiary and the smelter that provided the original Conflict Minerals.  Direct suppliers to IDEX manufacturing subsidiaries may have to require successive upstream suppliers to complete IDEX’s Conflict Minerals survey until the smelter is identified;
  • Provide reports to support IDEX’s SEC reporting requirements; and
  • Upon request, permit auditing of their Conflict Minerals policies and procedures.

If you have any questions or would like additional information about this policy, please email: [email protected]

 

[1] A copy of the applicable rules is available at: http://www.sec.gov/rules/final/2012/34-67716.pdf

[2] The adjoining countries to the DRC which are of concern include Angola, Burundi, Central African Republic, The Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.