Conflict Minerals Disclosure
Reasonable Country of Origin Inquiry
Pursuant to the
Rule, we conducted, in good faith, a reasonable country of origin inquiry concerning any Conflict Minerals that were necessary to the functionality or production of products manufactured, or contracted to be manufactured, for sale by Dril-Quip
during the year ended December 31, 2021. As part of our analysis, we assessed our manufactured products to identify Conflict Minerals scope and risk. As a result of our analysis, we identified the following products containing Conflict
Minerals:
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Pipe thermal coating spray, which contains tungsten; |
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Welding wire, which contains tantalum and tin; and |
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Control system electrical circuit connections, which contain gold. |
Our analysis concluded that these Conflict Minerals are contained in components of our products manufactured by and purchased from our suppliers. Our analysis
further determined that no other Conflict Mineral or Conflict Mineral derivative is contained as a necessary element to the functionality or production of any product manufactured for sale by the Company.
In 2014, we adopted a Conflict Minerals policy. Under the policy, we expect each of our suppliers to respond to inquiries related to Conflict Minerals, to
undertake appropriate due diligence and to conduct its operations in an ethical manner.
We surveyed all suppliers of components of our products that
contain tungsten, tantalum, tin and gold and received responses from approximately 94% of such suppliers. No supplier provided any reason for the Company to believe that Conflict Minerals contained in components supplied to us originated in the
Covered Countries.
The Company has completed its Reasonable Country of Origin Inquiry for the year ended December 31, 2021 and has determined
that it has no reason to believe that the Conflict Minerals contained in components necessary to the functionality or production of its products manufactured for sale may have originated from the Covered Countries. The Company uses no other Conflict
Mineral or Conflict Mineral derivative as a necessary element to the functionality or production of any product it manufactures for sale.
As a downstream
purchaser of Conflict Minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals. Our conclusions are necessarily based on information from
our direct and indirect suppliers. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
In accordance
with the Rule, this disclosure is available on the Companys website at www.Dril-Quip.com.