Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Vontier Corporation (the Company) is filed pursuant to Rule 13p-1 (the Rule)
promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023.
The Rule
requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The minerals specified by
the Rule are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the Conflict Minerals). The Covered Countries for the
purposes of the Rule are the Democratic Republic of the Congo or an adjoining country.
The following disclosure, in response to the provisions of
paragraphs (a) and (b) of Item 1.01 of Form SD, has been made in accordance with the Updated Statement on the Effect of the Court of Appeals Decision on the Conflict Minerals Rule issued by the Division of Corporation Finance of the U.S.
Securities and Exchange Commission on April 7, 2017 (the April 2017 Guidance). As permitted under the April 2017 Guidance, this Form SD does not address Item 1.01(c) of Form SD.
Conflict Minerals Disclosure
Description of the Companys Products
This Form SD relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were
manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2023. These products (collectively, the Covered Products) consist of professional and engineered
products.
Reasonable Country of Origin Inquiry
The Company has conducted a reasonable country of origin inquiry regarding the Conflict Minerals that are necessary to the functionality or production of its
Covered Products. This inquiry was reasonably designed and performed in good faith to determine whether any of such Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may have been from recycled or scrap
sources. The Companys supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of the Conflict
Minerals; the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Conflict Minerals that are included in the Covered
Products. Moreover, the Company believes that the smelters and other refiners (smelters) of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore has structured its reasonable country of
origin inquiry and due diligence processes to ultimately identify the applicable smelters of Conflict Minerals in the Companys supply chain. The Companys reasonable country of origin inquiry was based upon the due diligence framework in
the Organization for Economic Cooperation and Developments Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements as applicable for downstream companies (the
OECD Guidance). The Companys reasonable country of origin inquiry included the following steps:
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The Company identified the suppliers that presented the greatest risk in the Companys supply chain and
emailed to each such supplier a copy of the Companys policy related to the Conflict Minerals, which incorporates the standards set forth in the OECD Guidance, as well as a link to the Responsible Minerals Initiative (RMI) Conflict
Minerals Reporting Template (the Template) declarations, and requested that such supplier return to the Company a completed Template with respect to all components and materials that such supplier provides to the Company.
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As necessary, the Company educated suppliers regarding the reasons for requesting the Conflict Minerals data and
answered supplier questions relating thereto. |
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The Company followed up with the suppliers that did not respond to the Companys initial outreach, and also
followed up with suppliers who submitted data that appeared to be incomplete or incorrect. |
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The Company amalgamated supplier-provided information regarding smelters into a single unique list of smelters.
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Some of the Companys suppliers were unable to identify the smelters or countries of origin in their supply chain, some suppliers
responded by providing information related to all of the items the supplier produces without identifying smelters specific to the items purchased by the Company, and some suppliers included names of smelters that the Company believes may have been
misidentified as smelters or that are not operational.
With respect to each smelter identified by the Companys supply chain that declared directly
or through their relevant industry association that they did not source from the Covered Countries, and were not recognized as conflict free by the RMIs Responsible Minerals Assurance Process (RMAP), the Company, with the
assistance of an outside consultant, reviewed publicly available information to determine if there was any contrary evidence to the smelters declaration. With respect to each smelter identified by the Companys supply chain that is
sourcing from or as to which there is reason to believe may be sourcing from the Covered Countries, the Company did not audit such smelters but instead relied on the RMAP, and if the smelter has not been audited and recognized as conflict free by
the RMAP, the Company conducted risk mitigation on the smelter according to Step 3B of the OECD Guidance.