Please wait
Exhibit 1.01
CONFLICT MINERALS REPORT OF
IDEX CORPORATION
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2024
I.Introduction
This is the Conflict Minerals1 Report of IDEX Corporation (“we,” “our,” “IDEX,” “IDEX Corporation,” or the “Company”) prepared for calendar year 2024 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Form SD and the reader is referred to those sources, and also to Release No. 34-67716 (August 22, 2012) of the Act (the “Adopting Release”) for such definitions.
Conflict minerals are necessary to the functionality or production of certain products that we manufacture or contract to be manufactured. In accordance with Rule 13p-1, we undertook efforts to determine the content and source of the conflict minerals within those products. The Company designed its efforts in conformity with the internationally recognized due diligence framework put forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas2 (“OECD Due Diligence Guidance”) and related Supplements.
The statements below are based on the activities performed to date and in good faith by IDEX Corporation and are based on the infrastructure and information available at the time of this filing. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving identification of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the SEC final rules, and other issues.
II.Overview
Company Profile
IDEX Corporation (“IDEX” or the “Company”) is a global applied solutions provider serving niche markets with mission critical components for everyday life. Substantially all of the Company’s business activities are carried out through over 50 wholly-owned subsidiaries with shared values of Trust, Team and Excellence. IDEX’s diverse family of businesses is committed to making trusted solutions that improve lives and is innovative and inquisitive in its quest to solve customers’ most challenging applied technology problems.
The Company has three reportable business segments: Our Fluid & Metering Technologies segment designs, produces and distributes positive displacement pumps, valves, small volume provers, flow meters, injectors and other fluid-handling pump modules and systems and provides flow monitoring and other services.
Our Health & Science Technologies segment designs, produces and distributes a wide range of precision fluidics, positive displacement pumps, powder and liquid processing technologies, drying systems, micro-precision components, pneumatic components and sealing solutions, high performance molded and extruded sealing components, custom mechanical and shaft seals, engineered hygienic mixers and valves, biocompatible medical devices and implantables, air compressors and blowers, optical components and coatings, laboratory and commercial equipment and precision photonic solutions, technical ceramics and hermetic sealing products and porous material structures and flow control solutions.
1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.
2 OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris.
Our Fire & Safety/Diversified Product Segment designs, produces and distributes firefighting pumps, valves and controls, rescue tools, lifting bags and other components and systems; engineered stainless steel banding and clamping devices; and precision equipment for dispensing metering and mixing colorants and paint.
We are subject to this rule as we have determined that, during 2024, conflict minerals were likely necessary to the functionality or production of products we manufactured or contracted to manufacture (which we may refer to herein as “necessary conflict minerals”). The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals, and we conduct no purchasing activities directly in the DRC or adjoining countries.
Conflict Minerals Policy
The Company developed a policy statement to support the goals expressed by Congress in enacting Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The policy highlights the Company’s commitment to complying with the reporting and due diligence obligations required by the U.S. Securities and Exchange Commission (“SEC”) rule and the Company’s expectations from its suppliers, which include: establishing a supplier Conflict Minerals policy; exercising due diligence consistent with the OECD Due Diligence Guidance; providing the results of their due diligence efforts to IDEX; and, upon request, permitting auditing of their Conflict Minerals policies and due diligence measures. The policy resides on our corporate website (https://www.idexcorp.com/about-idex/compliance-integrity/) and is included in our supplier code of conduct and terms and conditions.
Reasonable Country of Origin Inquiry Information
We have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.
IDEX Corporation’s RCOI process included conducting an inquiry of our direct suppliers of in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance. Our due diligence efforts are discussed further in this Conflict Minerals Report.
Due Diligence Program Design
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Step 5: Report annually on supply chain due diligence.
III.Due Diligence Measures Performed by IDEX Corporation
The following describes the measures taken to reasonably determine the country of origin of the necessary conflict minerals and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
Step 1: Establish strong company management systems
a.Conflict minerals team – IDEX Corporation established a conflict minerals team that includes individuals from the appropriate business units and departments, including: Finance, Supply Chain, and Legal and Compliance. The team was structured to include the involvement from those in upper management roles to help ensure critical information, including the Company’s conflict minerals policy, reached relevant employees and suppliers. We also engaged a third party consulting firm to assist us with our compliance efforts.
b.Conflict minerals policy – IDEX Corporation adopted and published a policy highlighting the Company’s commitment to complying with the reporting and due diligence obligations required by the SEC rule and the Company’s expectations from its suppliers. The policy resides on our corporate website (https://www.idexcorp.com/about-idex/compliance-integrity/).
The policy is also incorporated into the Company’s terms and conditions with suppliers. It is reviewed annually and will be updated, if necessary.
c.Internal engagement – We developed a training program for internal use to educate relevant employees on our conflict minerals program and reporting obligations.
d.Supplier engagement – IDEX Corporation provided a Supplier letter, which included educational materials to our in-scope suppliers. Suppliers were provided information on the conflict minerals disclosure requirements and were directed to the RMI training programs for additional information.
e.Company level grievance mechanism – As recommended by the OECD Due Diligence Guidance, IDEX Corporation has established a grievance mechanism as a risk-awareness system for conflict minerals issues. Both internal and external stakeholders, can communicate directly and confidentially with our compliance officer or through our Conflict Minerals email inbox.
f.Records management – IDEX Corporation will maintain records relating to our conflict minerals program in accordance with the recommended record retention guidelines of five years.
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
a.Identified products in scope – Our conflict minerals team conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period as well as prior year’s conflict mineral information to identify products that should be deemed in-scope as described by the Adopting Release.
b.Conducted RCOI – IDEX Corporation utilized the most recent version of the industry-developed CMRT to query our in-scope suppliers for conflict minerals information. We requested this information from the suppliers that provide material and components for the products deemed in-scope by our conflict minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI. See Appendix I for a list of countries of origin identified through the RCOI process.
c.Completed additional follow-up – IDEX Corporation contacted direct suppliers multiple times to request detailed conflict minerals information. We also worked to clarify and validate the information provided by our suppliers by responding with standardized feedback questions to address any issues or uncertainty with the template provided when necessary and/or obtaining additional information upon request (product identification, order numbers, or shipping addresses) to help ensure we are receiving conflict minerals information specific to our supply-chain.
d.Identified smelters or refiners (“SORs”) – IDEX Corporation compiled a list of SORs in our supply chain using our supplier's responses in their CMRTs. The Company reconciled this list to the list of smelter facilities designated by the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP completes independent, third-party audits of smelters and refiners to determine which can be validated as having systems in place that help ensure the minerals are responsibly sourced according to the OECD Due Diligence Guidance. The company also utilized information provided by the London Bullion Market Association (LBMA), and Responsible Jewelry Council (RJC) cross-recognition audit programs. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs. We have provided the list of SORs in our supply chain in this report within Section IV – Product Description; Processing Facilities.
e.Performed smelter due diligence with suppliers - Suppliers that reported smelters deemed to be high risk received additional communication asking to confirm if those smelters were used in products purchased by IDEX and to continue due diligence on their supply chains. High risk smelters are those that have not yet undergone a third-party audit or have been deemed non-conformant.
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
a.Reporting results to senior management – The Conflict Minerals team reports the results of our RCOI to upper management at multiple points in time throughout the data collection period. These communications included the team’s plan to respond to risks identified in the due diligence processes.
b.Designed and implemented a plan – The Company used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT, as well as any additional documentation furnished to support those responses, and the suppliers’ due diligence processes. The resulting risk ratings were used to develop specific supplier outreach and training to address the identified risks and to take corrective actions with suppliers found not in compliance with the Company’s conflict minerals policy. These actions will include additional outreach to suppliers who failed to respond to our multiple requests for information, provided inconsistent or erroneous information, or indicated they had received responses from less than 50% of their in-scope suppliers. Our team further reviews the responses to verify the validity of
SORs reported by our suppliers, the audit status of such SORs and the country of origin of the minerals processed at such facilities.
c.Provided educational materials – The Company provided each supplier with educational materials that explain Section 1502 of the Dodd Frank Act, the OECD framework, the RCOI process, and general information on the contents of the most recent revision of the CMRT (including definitions of common phrases and frequently asked questions). These materials are provided to suppliers at the time of the initial request for a completed CMRT. The educational material serves as a point of reference for suppliers that are unfamiliar with the rule and helps limit the risk of obtaining inaccurate information from them. Throughout the process we offer assistance to our suppliers to improve the quality of the information provided to us.
d.Provided conflict minerals policy to suppliers – After working with a supplier to obtain a CMRT, we provide them with a copy of our conflict minerals policy for their records to ensure our suppliers continue to operate in line with our expectations.
e.Identified SORs – As part of the risk mitigation process, the Company reconciled the list of SORs collected from suppliers to the list of smelter facilities validated by the RMI. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs.
f.Ongoing risk monitoring – Suppliers, smelters and refiners that have been identified as high-risk through our risk assessment process are tracked to assess their progress towards meeting our expectations.
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
IDEX Corporation is using information provided by independent third party audit programs, including the RMI RMAP, LBMA, and RJC, to confirm the existence and verify the OECD-conformance status of SORs identified during our due diligence.
For SORs that had not been audited as conformant, the Company sent a communication to encourage participation in the RMAP and requested the SOR to provide the mines and/or locations the SOR sources from to assist in identifying all countries of origin. Additionally, the Company sent communications to all suppliers that reported SORs that had not been audited as conformant to request that these suppliers contact the SORs to encourage participation in the RMAP.
Step 5: Report annually on supply chain due diligence
Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our website at https://www.idexcorp.com/about-idex/compliance-integrity/.
IV.Product Description and Processing Facilities
Product Description – The Company has three reportable business segments: Fluid & Metering Technologies, Health & Science Technologies and Fire & Safety/Diversified Products. Descriptions of these segments can be found within Section II –Overview.
Processing Facilities – Based on our due diligence process and the information received from our suppliers, the following facilities were identified by the Company’s suppliers as the smelters and refiners of the tin, tantalum, tungsten and/or gold present in and necessary to the functionality of products manufactured by, or contracted to be manufactured by, the Company in the calendar year ended December 31, 2024. The information from our suppliers is still evolving and may contain company level declarations. As such, this smelter list is presented in good faith as the best information we have to date. For 2024, we identified 252 SORs in our supply chain, of which 205 have been audited by the RMI as conformant with the RMAP or equivalent third-party audit program. This list may contain SORs that do not provide materials for our products and are thus not in our supply chain, and there may be other smelters not yet identified in our due diligence process. We will continue to update the list as our information and the relevant third-party data from RMI, LBMA, and RJC improves.
V. Conclusion
Conflict minerals are included in many of our products and are sourced from multiple suppliers. A portion of our suppliers submitted CMRT responses encompassing their entire supply chains, rather than focusing only on components incorporated into our products. We are unable to trace, without unreasonable effort, which of our products included necessary conflict minerals from the SORs included in our smelter list during the calendar year ended December 31, 2024. As a result, based on our RCOI, we are unable to reliably determine whether any of the necessary conflict minerals in our products originated in the DRC and adjoining countries or whether such necessary conflict minerals were entirely from recycled or scrap sources.
Smelter Names
| | | | | | | | | | | |
| Metal | Standard Smelter Name | Country Location | Smelter ID |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
| Gold | Agosi AG | GERMANY | CID000035 |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| Gold | Dowa | JAPAN | CID000401 |
| Gold | Alexy Metals | UNITED STATES OF AMERICA | CID003500 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| Gold | ASAHI METALFINE, Inc. | JAPAN | CID000082 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
| Gold | Aurubis AG | GERMANY | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Gold | Boliden Ronnskar | SWEDEN | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
| Gold | Caridad | MEXICO | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
| Gold | Chimet S.p.A. | ITALY | CID000233 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | CID001916 |
| Gold | Chugai Mining | JAPAN | CID000264 |
| Gold | Coimpa Industrial LTDA | BRAZIL | CID004010 |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
| | | | | | | | | | | |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 |
| Gold | GG Refinery Ltd. | TANZANIA, UNITED REPUBLIC OF | CID004506 |
| Gold | Gold by Gold Colombia | COLOMBIA | CID003641 |
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | CID000711 |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
| Gold | Italpreziosi | ITALY | CID002765 |
| Gold | Japan Mint | JAPAN | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
| Gold | JX Advanced Metals Corporation | JAPAN | CID000937 |
| Gold | Kazzinc | KAZAKHSTAN | CID000957 |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
| Gold | Yamakin Co., Ltd. | JAPAN | CID002100 |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
| Gold | L'Orfebre S.A. | ANDORRA | CID002762 |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF | CID001078 |
| Gold | Marsam Metals | BRAZIL | CID002606 |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| Gold | MKS PAMP SA | SWITZERLAND | CID001352 |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
| | | | | | | | | | | |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
| Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 |
| Gold | Royal Canadian Mint | CANADA | CID001534 |
| Gold | SAFINA A.S. | CZECHIA | CID002290 |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
| Gold | T.C.A S.p.A | ITALY | CID002580 |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
| Gold | WEEEREFINING | FRANCE | CID003615 |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
| Tantalum | AMG Brasil | BRAZIL | CID001076 |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | CID000616 |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | CID002544 |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | CID002548 |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | CID002549 |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002550 |
| Tantalum | TANIOBIS GmbH | GERMANY | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
| Tantalum | KEMET de Mexico | MEXICO | CID002539 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
| | | | | | | | | | | |
| Tantalum | NPM Silmet AS | ESTONIA | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| Tantalum | PowerX Ltd. | RWANDA | CID004054 |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | CID003583 |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| Tin | Alpha Assembly Solutions Inc | UNITED STATES OF AMERICA | CID000292 |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
| Tin | Aurubis Beerse | BELGIUM | CID002773 |
| Tin | Aurubis Berango | SPAIN | CID002774 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | CID002180 |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | CID003486 |
| Tin | CRM Synergies | SPAIN | CID003524 |
| Tin | CV Ayi Jaya | INDONESIA | CID002570 |
| Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 |
| Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 |
| Tin | Dowa | JAPAN | CID000402 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | CID003582 |
| Tin | Fenix Metals | POLAND | CID000468 |
| Tin | Minsur | PERU | CID001182 |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | CID003410 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | AUSTRALIA | CID004754 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
| | | | | | | | | | | |
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | CHINA | CID004796 |
| Tin | Luna Smelter, Ltd. | RWANDA | CID003387 |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA | CID004434 |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | CID002015 |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | CID004065 |
| Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
| Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION | CID001305 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
| Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
| Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 |
| Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | CID003868 |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | INDIA | CID004692 |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| Tin | Super Ligas | BRAZIL | CID002756 |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | JAPAN | CID004403 |
| Tin | Thaisarco | THAILAND | CID001898 |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
| Tin | Woodcross Smelting Company Limited | UGANDA | CID004724 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
| Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
| Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | CID002513 |
| | | | | | | | | | | |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | CID002641 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000281 |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | CID003609 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | CID003417 |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | CID000568 |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
| Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF | CID003978 |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | CID000769 |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 |
| Tungsten | KENEE MINING VIETNAM COMPANY LIMITED | VIET NAM | CID004619 |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Tungsten | Masan High-Tech Materials | VIET NAM | CID002543 |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 |
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | CID003614 |
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | CID003612 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA | CID004430 |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | CID003993 |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA | CID003662 |
VI. Future Due Diligence
We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information globally available on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a supplier whose due diligence needs improvement, we may continue the trade relationship while that supplier improves its compliance program. We expect our suppliers to take similar measures with their suppliers to help ensure alignment throughout the supply chain.
In addition to those above, the Company will undertake the following steps during the next compliance period:
•Review the conflict minerals policy statement and update if necessary.
•Review supplier and employee training materials and update if necessary.
•Continue to collect responses from suppliers using the most recent revision of the CMRT.
•Engage with suppliers that did not provide a response in 2024 or provided incomplete responses to help with our data collections for 2025.
•Monitor and track performance of risk mitigation efforts including the performance of suppliers deemed high-risk.
•Compare and validate RCOI results to information collected via independent third-party audit programs, such as the RMI.
•Continue engagement with smelters by sending letters to those that have not been audited as conformant.
•Continue to send messages to our suppliers to engage with smelters that have not been audited and encourage these smelters to undergo an independent third-party audit (e.g., RMAP or equivalent).
•Collect from suppliers product-level or user-defined level responses when useful.
•Encourage responsible sourcing from the DRC and adjoining countries.
•Stay aware of new and related sourcing challenges that affect smelter RMI audit status.
APPENDIX I - Countries of Origin
The information provided in this Appendix is based on the information collected from IDEX Corporation’s suppliers.
| | | | | |
| Australia | Nicaragua |
| Benin | Niger |
| Bolivia (Plurinational State of) | Nigeria |
| Brazil | Papua New Guinea |
| Burundi | Peru |
| Canada | Philippines |
| Chile | Portugal |
| China | Russian Federation |
| Colombia | Rwanda |
| Congo, Democratic Republic of the | Sierra Leone |
| Ethiopia | South Africa |
| France | Spain |
| Guyana | Sweden |
| Indonesia | Tanzania |
| Japan | Thailand |
| Laos | Uganda |
| Madagascar | United Kingdom of Great Britain and Northern Ireland |
| Malaysia | United States of America |
| Mongolia | Uzbekistan |
| Mozambique | Vietnam |
| Myanmar | Zambia |
| Namibia | Zimbabwe |
