Conflict Minerals Policy Statement

Xylem Inc. supports ending the violence and human rights violations related to the mining of certain minerals from a location described as the “Conflict Region,” which is situated in the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries.  As a result of the violence and violations, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 directed the U.S. Securities and Exchange Commission (SEC) to adopt rules to implement disclosure requirements related to these “conflict minerals”.  Conflict minerals refer to tin, tantalum, tungsten and gold(referred to as “3TG”), regardless of where they are sourced, processed or sold. 

These rules apply to manufacturers who file periodic reports with the SEC and who manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of those products.  These manufacturers are required to make inquiries as to the origin of these conflict minerals and file a report with the SEC to describe and disclose the results of their inquiries.  The intent of this new requirement is to further the humanitarian goal of ending violent conflict in the DRC and the surrounding countries, which has been partially financed by the exploitation and trade of conflict minerals.

Xylem’s Commitment: 

• To support the aims and objectives of the SEC rules and regulations related to the supply of conflict minerals.
• Our goal is to ensure that any tin, tantalum, tungsten or gold that we procure that has originated from the Conflict Region has been certified as “conflict free.”
• To ensure compliance with these requirements, and ask our suppliers to undertake reasonable due diligence with their supply chains to assure that the specified metals are only being sourced from:
• Mines and smelters outside the Conflict Region or
• Mines and smelters which have been certified by an independent third party as conflict free if sourced within the Conflict Region. 
  
  This due diligence includes requesting our suppliers to provide written documentation of the results of their due diligence.
• To ensure that any grievance from a supplier or other stakeholder regarding our approach to conflict minerals is addressed via our Supplier Ombudsperson Program or our internal Ombudsperson Program (the programs are available in our Supplier Code of Conduct and our Code of Conduct, respectively, available at Click Here).

If we discover the use of conflict minerals produced in facilities that are not considered to be conflict free in any material, parts or components we procure for use in our products, we will use our best efforts to transition the products to be conflict free.

Matthew Pine
President and Chief Executive Officer
Xylem Inc.