Badger Meter Policy Statement: Conflict Minerals

CONFLICT MINERALS

Badger Meter is committed to sourcing components and materials from companies that share our values around human rights, ethics and environmental responsibility. On August 22, 2012, the final rule regarding sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act was approved by the U.S. Securities and Exchange Commission ("SEC").

The rule imposes reporting requirements on certain companies to perform due diligence with respect to the sourcing of conflict minerals and to file annual reports relating to the use of conflict minerals (tantalum, tin, gold or tungsten) originating in the Democratic Republic of the Congo and certain adjoining countries ("Covered Countries") in the products they manufacture or contract to manufacture if the conflict minerals are necessary to the functionality or production of a product. Reports must be filed with the SEC on or before May 31st for the previous calendar years in scope products.

Badger Meter's current Form SD Report filed in May 2023.

Badger Meter is committed to taking steps to comply with the legislation and has implemented a due-diligence process to meet its obligations. Badger Meter supports an industry-wide approach to addressing social responsibility issues throughout the supply chain and is using the Organization for Economic Cooperation and Development (OECD) Guidelines as a framework for its due diligence. The benefit of this approach is that the industry can look at these issues more strategically and holistically than any individual company.

In order to comply with the legislation and manage customer requests regarding conflict minerals, Badger Meter has and plans to continue the following:

• Educate its suppliers with respect to the requirements on conflict minerals. See Supplier Resources section on Conflict Minerals.
• Use an industry-wide identified approach to develop a centralized means of collecting, tracking and responding to customer requests.
• Assess its products and identify those for which conflict minerals are or may be necessary to their functionality or production.
• Develop processes to determine if such necessary conflict minerals originated in the Covered Countries or to confirm that they are from recycled or scrap sources. This will include supporting the Conflict-Free Smelter Program developed by the Electronic Industry Citizenship Coalition, Incorporated ("EICC") and Global e-Sustainability Initiative ("GeSI") and obtaining information and assistance from suppliers to trace the origin of any necessary conflict minerals.
• Based upon the information gathered utilizing the processes developed, prepare appropriate disclosure for Badger Meter’s Form SD and, if required, its Conflict Minerals Report.

Badger Meter expects its suppliers to conduct similar due diligence on the sources and chains of custody of these minerals and make their due diligence findings available to Badger Meter.

Grievance Mechanism and Reporting

Any individual or company that has a reasonable suspicion that conflict minerals are present in Badger Meter’s supply chain should alert Badger Meter or our third-party conflict mineral management team of the specifics regarding the suspicion. Badger Meter will perform due diligence on any reasonable inquiries, and will address any conflict minerals that are identified with the offending supplier.

SUPPLIER RESOURCES: CONFLICT MINERALS

Badger Meter has created this resource section with a list of links to conflict minerals resources to help suppliers understand the regulations and reporting requirements for Conflict Minerals. Badger Meter is providing this information to its suppliers to help them understand Badger Meter’s expectations and provide links to the documents and forms.

Tracing materials back to their mine of origin is a complex but critical requirement of responsible sourcing in the electronics supply chain. The EICC and GeSI are taking action to address material sourcing through the development of the Conflict Free Smelter (CFS) Program.

For more information on Conflict Minerals, visit the EICC website: http://www.eiccoalition.org/initiatives/conflict-free-sourcing-initiative/ 

To download the current CMRT (template) and other training materials, visit the CFSI website: http://www.conflictfreesourcing.org/