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Smith & Nephew Policy on Conflict Minerals

Smith & Nephew, Inc., and its affiliates and subsidiaries, (collectively “S+N”), support ending violence and human rights violations in all Conflict Affected and High Risk Areas (CAHRA) including parts of the Democratic Republic of the Congo and surrounding countries (consolidated as “Conflict Area”). This violence, and the related human rights violations, has been partially financed by the exploitation and trade of tin, tantalum, tungsten or gold (the “Conflict Minerals”) mined in the Conflict Area.

The U.S. Securities and Exchange Commission (“SEC”) adopted final rules to implement reporting and disclosure requirements related to Conflict Minerals, pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”). The rules require manufacturers who file certain reports with the SEC to disclose whether the products they manufacture or contract to manufacture contain Conflict Minerals in a manner or amount necessary to the functionality or production of those products. S+N supports the Dodd-Frank reporting requirements and the traceability of Conflict Minerals.

To meet its Dodd-Frank obligations, S+N has adopted due diligence measures designed to conform, in all material respects, with the framework set out by the Organization for Economic Co-operation and Development (“OECD”), in its Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and in the OECD’s related Supplements. S+N encourages transparency in the supply chain, and believes the Dodd Frank rules, and compliance with them, will further the humanitarian goal of ending violent conflict in the Conflict Area.

Within the European Union, EU Regulation 2017/821 (“Conflict Mineral Regulation”) also aims to prevent exploitation of minerals and metals by armed groups from resource-rich CAHRAs and imposes similar due diligence and disclosure requirements as of 1 January 2021. The Conflict Mineral Regulation does not formally apply to S+N, as it does not act as importer, refiner or smelter within the European Union. Nevertheless, in furtherance of S+N’s commitment for a responsible mineral supply chain, S+N will work towards voluntarily complying with the Conflict Mineral Regulation.

Smith+Nephew's Policy

  1. S+N will not knowingly procure or use Conflict Minerals the extraction or sale of which finances or benefits armed groups in the Conflict Area.
  2. S+N will work toward processes that will help assure S+N procures and uses Conflict Minerals only if they originate from outside the Conflict Area or from mines and smelters within the Conflict Area that have been certified by an independent third party as “conflict free”.
  3. S+N expects its suppliers to undertake documented due diligence, and to develop policies, to assure that Conflict Minerals are being sourced only from outside the Conflict Area or from mines and smelters which have been certified by an independent third party as “conflict free”. S+N reserves the right to verify the compliance of S+N’s suppliers with this expectation.
  4. If S+N discovers the use of Conflict Minerals considered to be “not conflict free”, in any material, parts or components S+N procures or produces, S+N expects its suppliers to take appropriate actions to transition such material, parts or components to “conflict free” status. S+N reserves the right to terminate S+N’s relationship with suppliers that do not meet this expectation.

Please contact if you have questions or need more information.