CONFLICT MINERALS POLICY

Background

Pursuant to rules adopted by the U.S. Securities and Exchange Commission (“SEC”), as required by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, SPX Corporation is required to disclose the extent to which products we and our subsidiaries manufacture or contract to manufacture contain cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold, that are (i) necessary to the functionality or production of those products and (ii) sourced from mines in the Democratic Republic of the Congo or adjoining countries (“Conflict Minerals”).

Commitment

To aid in complying with the SEC disclosure requirements, SPX Corporation is working with our suppliers to perform due diligence in determining the potential for Conflict Minerals in our supply chain and products. We are designing our due diligence processes in accordance with the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Expectations of Suppliers

If a supplier cannot determine whether its materials or products contain Conflict Minerals within a reasonable period of time, or is unwilling to support SPX Corporation in our Conflict Minerals program efforts, SPX may execute remediation steps up to and including alternative sourcing arrangements. SPX expects to work with our suppliers to help ensure their compliance with the Conflict Minerals rules.

SPX Corporation expects each of our suppliers that supplies products that may contain Conflict Minerals to:

  • Establish a Conflict Minerals policy in accordance with applicable SEC rules, implement management systems to support compliance with its policy, and require its suppliers of any tier to take similar steps.
  • Identify, in the manner and form specified by SPX, materials or products it sells to SPX and its subsidiaries, and the smelter that provided the original Conflict Minerals. SPX’s direct suppliers may have to require successive downstream suppliers to provide information contained in SPX’s Conflict Minerals survey until the smelter is identified.
  • Provide reports to support SPX’s SEC reporting requirements.
  • Upon request, permit auditing of its Conflict Minerals policies and procedures.