Transparency in Supply Chain / Conflict Minerals

Pursuant to 

i. 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”.

ii. 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 in this context means coltan (tantalum), cassiterite (tin), wolframite (tungsten), their ores and gold.

With our efforts we also support industry initiatives such as those led by the Electronics Industry Citizenship Coalition to increase transparency in supply chains and to enable companies to source conflict-free minerals.

We are guided by the Organization for Economic Cooperation and Development (OECD) model supply chain policy for a responsible global supply chain of minerals from conflict-affected and high-risk areas.

Linde Engineering 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, Linde 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 Linde 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 Linde which may include completing the standardized Responsible Minerals Initiative Conflict Minerals Reporting Template (CMRT) or other certifications. If Linde 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 Linde’s Code of Business Integrity and our commitment to human rights, we will reassess our business relationship with such supplier.