Conflict Minerals

Smith+Nephew 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:

• 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.
• 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”.
• 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.
• 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 Conflict-Minerals.Global@smith-nephew.com if you have questions or need more information.

Purpose

To encourage employees and the public to disclose any misconduct of which they become aware with regard to Smith+Nephew’s use, and its reporting of its use, of tin, tantalum tungsten and gold (the “Conflict Minerals”), and to provide protection for employees who report allegations of such misconduct.

Scope

This policy applies to all employees, including full-time, part-time and temporaries, and agents, contractors, suppliers and customers of Smith+Nephew, and to the general public.

Policy

This whistleblowing policy is designed to encourage employees to report alleged misconduct, to ensure that all allegations are thoroughly investigated and suitable action taken where necessary.  Smith+Nephew does not retaliate against employees who make reports in good faith. Every effort will be made to protect the anonymity of the whistleblower, however there may be situations where anonymity cannot be guaranteed.

Below are some examples of misconduct with regard to Conflict Minerals:

• Intentional misrepresentations regarding Smith+Nephew’s use of Conflict Minerals
• Failure to adequately investigate the source of Conflict Minerals used by Smith+Nephew
• Failure to follow Smith+Nephew’s proscribed procedures for determining and reporting on Smith+ Nephew’s use of Conflict Minerals

Reporting Procedures

A person who reasonably believes that inappropriate conduct is occurring with regard to Smith+Nephew Conflict Minerals should raise the issue to the Company for investigation.  Reports can be made via any of the following avenues:

• To a manager
• To an Office of Ethics and Compliance (OEC) employee
• To a member of the Smith+Nephew Legal team
• To a manager in Human Resources
• Via Smith+Nephew Integrity Line