Conflict-Free Materials Supply Policy

Praxair Conflict-Free Materials Supply Policy

Scope

Global. Applicable to relevant suppliers and their suppliers.

Dodd-Frank Act

Pursuant to Section 1502 of the Dodd‐Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), the U.S. Securities and Exchange Commission (“SEC”) has adopted rules imposing SEC reporting requirements upon publicly-traded companies whose products contain metals derived from minerals defined as “conflict minerals.” Conflict minerals include wolframite (tungsten), cassiterite (tin), coltan (tantalum) and gold. Praxair uses these minerals in producing certain products and applications for customers within the electronics, aerospace, oil and gas and other industries. Praxair takes seriously the global concern that minerals mined from some sources within the Democratic Republic of the Congo or its adjoining countries (the "conflict region”), that benefit armed groups, may be making their way into the general industry supply chain, and that profits from this could potentially contribute to human rights violations.

Commitment to Responsible Sourcing 

Due to the complexities of the mining process and because Praxair does not purchase minerals directly from smelters or mines, it must rely on sourcing information provided by our suppliers. Praxair is committed to socially responsible sourcing and supports the humanitarian goals of the Dodd-Frank Act, the Responsible Minerals Initiative and the development of regulations and processes for suppliers to determine whether materials within their supply chain are sourced from the conflict region. Guided by the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas , Praxair has adopted this Conflict Materials Supply Policy and has implemented a supply chain due diligence framework that includes policies similar to those set forth in the Responsible Business Alliance (formerly the Electronics Industry Citizenship Coalition (EICC)) Code of Conduct 5.1 (2016). Praxair also works with the Global eSustainability Initiative (GeSI) to further develop non-conflict sourcing requirements.

Supplier Expectations 

Praxair’s Supplier Expectations outlines our goal of developing long-term and mutually beneficial supplier relationships based on strong performance standards. It requires that our suppliers engage in dealings based on fairness, honesty, lawfulness, safety, environmental stewardship and social consciousness equivalent to the values and standards set forth in Praxair’s Standards of Business Integrity and Human Rights Policy. In addition, Praxair expects its suppliers or potential suppliers of conflict minerals or other materials, and their sub-suppliers, to only source materials from environmentally and socially responsible sources.

In furtherance of our goal of utilizing “conflict-free” materials, Praxair has developed procedures that communicate our expectation that suppliers of conflict minerals (1) will implement due diligence processes to determine the origin of raw materials within their supply chain, and (2) will not supply to Praxair any conflict minerals known to come from the conflict region that are not either (a) from a compliant smelter or refiner, or (b) from recycled or scrap sources. Suppliers of conflict minerals must submit written evidence of due diligence documentation to Praxair which may include completing the standardized Responsible Minerals Initiative Conflict Minerals Reporting Template (CMRT) or other certifications. If Praxair identifies a reasonable risk that a supplier, or any of its affiliates or sub-suppliers, is (i) sourcing conflict minerals from the conflict region and such conflict minerals are not from a compliant smelter or refiner or from recycled or scrap sources, and/or (ii) engaged in conduct inconsistent with Praxair’s Standards of Business Integrity or Human Rights Policy, we will reassess our business relationship with such supplier.

Conformance with this policy is a requirement of all suppliers, or potential suppliers, of conflict minerals. Praxair continues to communicate this policy to our suppliers and encourages them to adopt similar policies with respect to conflict minerals and due diligence frameworks for their supply chains.

Signed,

Luiz Oliveira
Vice President, Global Procurement and Materials Management

Last updated:July 2017