Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure
This filing
is being made by Waters Corporation (Waters, the Company, we, us, or our) for the calendar year January 1 to December 31, 2021 in accordance with Rule
13p-1 (Rule 13p-1) under the Securities Exchange Act of 1934 (the 1934 Act) and Form SD (collectively, the Conflict Minerals Rule). Consistent with the Conflict Minerals
Rule, as used herein, Conflict Minerals or 3TG are tin (cassiterite), tungsten (wolframite), tantalum (columbite-tantalite or coltan) and gold. 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 Securities and Exchange Commission on April 7, 2017, we have not included a Conflict Minerals Report exhibit as part of this filing.
Company Overview
Waters is a specialty
measurement company that operates with a fundamental underlying purpose to advance the science that enables our customers to enhance human health and well-being. The Company has pioneered analytical workflow solutions involving liquid
chromatography, mass spectrometry, and thermal analysis innovations serving the life, materials, and food sciences. The Company primarily designs, manufactures, sells and services high performance liquid chromatography (HPLC),
ultraperformance liquid chromatography (UPLC and together with HPLC, referred to as LC) and mass spectrometry (MS) technology systems and support
products, including chromatography columns, other consumable products and comprehensive post-warranty service plans. These systems are complementary products that are frequently employed together
(LC-MS) and sold as integrated instrument systems using common software platforms. LC is a standard technique and is utilized in a broad range of industries to detect, identify, monitor and measure
the chemical, physical and biological composition of materials, and to purify a full range of compounds. MS technology, principally in conjunction with chromatography, is employed in drug discovery and development, including clinical trial testing,
the analysis of proteins in disease processes (known as proteomics), nutritional safety analysis and environmental testing. LC-MS instruments combine a liquid phase sample introduction and
separation system with mass spectrometric compound identification and quantification. In addition, the Company designs, manufactures, sells and services thermal analysis, rheometry and calorimetry instruments through its TA Instruments product line. These instruments are used in predicting the suitability and stability of fine chemicals, pharmaceuticals, water, polymers, metals and viscous liquids for various industrial,
consumer goods and healthcare products, as well as for life science research. The Company is also a developer and supplier of advanced software-based products that interface with the Companys instruments, as well as other manufacturers
instruments.
Product Scoping; Reasonable Country of Origin Inquiry (RCOI)
The Company determined that 3TG are used in certain components contained in the Companys instrument systems, which are products that the Company
manufactures. These 3TG are necessary to the functionality or production of the Companys instrument systems.
As required by the Conflict Minerals
Rule, the Company conducted a RCOI to determine whether any of the 3TG in the Companys products originate in the Democratic Republic of the Congo (the DRC) or its adjoining countries or are from recycled or scrap sources. The
Companys due diligence program is based upon industry guidance published by the Organisation for Economic Co-operation and Development, the Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk Areas (the OECD Guidance).
As part of our RCOI, we
asked 4,416 potentially in-scope suppliers to complete the Conflict Minerals Reporting Template (CMRT), developed by the Responsible Minerals Initiative (the RMI). The CMRT includes
questions about suppliers uses and sourcing of 3TG, as well as questions about their own due diligence measures. All potentially in-scope suppliers received a letter from the Companys Senior Vice
President of Global Operations, requesting their compliance with the annual RCOI process.
Due Diligence Program
The Company has designed its due diligence program to align with ongoing compliance with the Conflict Minerals Rule. As recommended by the OECD Guidance, the
Company published a Conflict Minerals Statement, which is made available to employees, suppliers and the public on our website at https://ir.waters.com/governance/governance-documents. Among other things, the Companys due diligence
program includes the review of its worldwide supply chain for materials that contain 3TG and the evaluation of the risk that these materials are from sources that directly or indirectly finance or benefit armed groups in the DRC or an adjoining
country.