Watts Water (WTS) SDConflict minerals disclosure

Exhibit 1.01

CONFLICT MINERALS REPORT

This is the Conflict Minerals Report for Watts Water Technologies, Inc. and its subsidiaries (the “Company”) for the calendar year ended December 31, 2023 (“calendar year 2023”) as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”).  Terms used and not otherwise defined in this Conflict Minerals Report have the definitions provided in Rule 13p-1 and the instructions to the Securities and Exchange Commission’s Specialized Disclosure Report on Form SD.  Pursuant to guidance from the staff of the Securities and Exchange Commission, the Company is not required to obtain an independent private sector audit of this report for 2023.  All information contained in this report is unaudited.

INTRODUCTION

The Company’s strategy is to be a preferred supplier of differentiated solutions, systems and products that manage and conserve the flow of fluids and energy into, through and out of buildings in the commercial and residential markets of the Americas, Europe, and Asia-Pacific, the Middle East and Africa (“APMEA”). The Company classifies its many products and solutions into four global categories. These categories are:

The Company has determined that many of the products that the Company manufactured or contracted to manufacture during calendar year 2023 contained one or more of the following minerals that are necessary to the functionality or production of those products: tin, tantalum, tungsten and gold (the “conflict minerals”). Specifically, the Company has determined that many of such products have brass or bronze components that contain tin or have electrical components that contain tin, tantalum, tungsten and/or gold.

Accordingly, the Company conducted in good faith a reasonable country of origin inquiry (“RCOI”) in accordance with Rule 13p-1.  The Company’s RCOI was reasonably designed to determine whether the conflict minerals contained in its products originated from the Democratic Republic of the Congo (the “DRC”) or an adjoining country (together with the DRC, the “Covered Countries”) or came from recycled or scrap sources.  As a result of its RCOI, the Company concluded that it had reason to believe that certain of its necessary conflict minerals may have originated in the Covered Countries.  In accordance with Rule 13p-1 and the instructions to Form SD, the Company undertook due diligence efforts on the source and chain of custody of the conflict minerals in its products that are necessary to the functionality or production of those products.

DUE DILIGENCE

Design of Due Diligence Framework

The Company designed its due diligence measures to be in conformity, in all material respects, with the criteria set forth in the internationally-recognized due diligence framework described in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, 2016 and related supplements for tin, tantalum and tungsten and for gold.

Due Diligence Measures Performed

The Company is a “downstream” consumer of necessary conflict minerals and is many steps removed from the “upstream” companies that smelt or refine conflict minerals.  The Company does not mine conflict minerals or directly purchase any conflict minerals from conflict mineral smelters or refiners.  The Company also does not have any direct suppliers that are located in any of the Covered Countries. Accordingly, the Company approached its conflict minerals due diligence efforts consistent with its position as a downstream company in the conflict minerals supply chain.

Establish Company Management Systems.  As part of its due diligence efforts, the Company established in 2013 an internal, cross-disciplinary conflict minerals working group to guide its conflict minerals compliance efforts and designated a conflict minerals program manager to coordinate its conflict minerals program implementation.  The conflict minerals working group includes the Company’s General Counsel.  The program manager provides periodic reports to the working group regarding the Company’s conflict minerals program performance and efforts.  In 2013, the Company also adopted a global Conflict Minerals Policy applicable to its suppliers of products and materials that form part of a bill of materials for a product sold by the Company.  A copy of this policy is available on the Company’s corporate website at https://www.watts.com/supplier.  The Company’s Conflict Minerals Policy includes a grievance mechanism, whereby concerns regarding compliance with the Company’s policy may be reported by telephone or online through the Company’s ethics hotline.  The Company has distributed training materials to its suppliers representing approximately 99% of the Company’s total spending on products, components or materials which contain conflict minerals that were necessary to the functionality or production of a product manufactured or contracted to be manufactured by the Company during 2023 (the “3TG Suppliers”). The training materials included an explanation of Rule 13p-1’s objective of furthering the humanitarian goal of ending the extremely violent conflict in the DRC, which has been partially financed by the exploitation and trade of conflict minerals originating in the DRC.  The training materials also provide an explanation of a reasonable country of origin inquiry and conflict minerals due diligence.  Finally, the training materials specifically communicate to 3TG Suppliers the Company’s expectation that these 3TG Suppliers support the Company’s public company reporting obligations by complying with the Company’s requests for information regarding the source and origin of any conflict minerals contained in materials or products supplied to the Company. The Company also makes a copy of the Company’s Conflict Minerals Policy available to its 3TG Suppliers.

Identify and Assess Risk in the Supply Chain.  To identify and assess risks regarding the source and origin of the conflict minerals in its supply chain, since 2021 the Company has engaged Assent Compliance Inc. (“Assent”), a third-party service provider, to assist the Company in reviewing its supply chain. The Company provided a list of its 3TG Suppliers to Assent, together with part numbers for materials or components sourced from each supplier. Assent uploaded these details to its Assent Compliance Platform (the “Assent Platform”), an online web portal that allows Assent to generate product-specific requests for 3TG Suppliers to complete and upload a Conflict Minerals Reporting Template ("CMRT") directly to the Assent Platform for inclusion in Assent’s assessment. Through the Assent Platform, in 2023 the Company contacted and conducted a survey of 449 3TG Suppliers using version 6.31 of the CMRT maintained by the Responsible Minerals Initiative ("RMI"). The Company requested that all 3TG Suppliers complete a CMRT and included video and written training and education resources to guide 3TG Suppliers on best practices and the use of the CMRT template and the Assent Platform. The Company followed up multiple times with unresponsive suppliers and tracked all supplier communications through the Assent Platform.

Strategy to Respond to Identified Risks. As part of identifying and assessing risk in its supply chain, the Company developed “red flags” designed to identify inconsistencies in its 3TG Suppliers’ responses to our survey or the risk that suppliers may be sourcing from the Covered Countries. The Assent Platform also validated supplier responses automatically based on pre-established criteria in order to identify certain risks. The Company reviewed supplier responses received from its 3TG Suppliers to identify those presenting red flags. The Company also followed up periodically with 3TG Suppliers who did not provide an initial response to our survey. The Company’s conflict minerals program manager aggregated the results of the Company’s 3TG Supplier responses to the Company’s conflict minerals inquiries and shared those results with the Company’s conflict minerals working group as part of the Company’s conflict minerals risk-assessment efforts.

Independent Third-Party Audit of Smelter/ Refiner Due Diligence Practices. The Company does not have any direct supplier relationships with any tin, tantalum or tungsten smelters or gold refiners.  As a downstream company that is several layers removed in the supply chain from such smelters and refiners, the Company’s 2023 due diligence efforts relied on the Responsible Minerals Assurance Process (“RMAP”) led by the RMI. The RMAP uses an independent third-party audit to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials.

Report Annually on Supply Chain Due Diligence.  The Company has filed this Conflict Minerals Report as part of its Specialized Disclosure Report on Form SD for calendar year 2023.  The Company has also made a copy of this Conflict Minerals Report available on its corporate website at https://www.watts.com/supplier.

Results of Due Diligence Measures

Through the Assent Platform, the Company surveyed a total of 449 3TG Suppliers, approximately 72% of which replied. Where a 3TG Supplier’s CMRT included the names and locations of smelters and refiners in that supplier’s conflict minerals supply chain, Assent validated such data by comparing it against the most recent list of known conflict minerals smelters and refiners published by the RMI and to other available information. Assent’s data validation process is designed to increase the accuracy of submissions and identify any contradictory answers in the CMRTs. If a supplier indicated that a facility was certified as conflict-free, Assent confirmed that the facility was listed on RMI’s list of validated conflict-free smelters and refiners of 3TGs. The Company’s 3TG Suppliers identified a total of 350 smelters and refiners that appear on the lists maintained by RMI. Of these 350 smelters and refiners, 225 are validated as conflict-free by RMI or a cross-recognized initiative. Furthermore, based on information provided by RMI, six smelters or refiners have agreed to undergo, or are currently undergoing, a third-party audit. The 350 smelters and refiners identified by our 3TG Suppliers are listed on Appendix A to this Report.

After reviewing the smelter and refiner information received from its suppliers through its RCOI and due diligence efforts, the Company determined that, in a majority of cases, the smelter and refiner information the Company received was provided by its 3TG Suppliers at a company level or divisional level, meaning that this information may not apply specifically to the products, components or materials purchased by the Company from these suppliers. In addition, some of the Company’s suppliers who responded to the Company’s survey did not provide smelter or refiner information, so the Company’s supply chain may contain additional smelters and refiners that have not yet been identified. Accordingly, the Company concluded that it did not receive sufficient information from its 3TG Suppliers to determine with certainty all of the facilities used to process the conflict minerals contained in its products, the country of origin of the conflict minerals contained in its products or the location of the mines from which such conflict minerals originated.

PRODUCT DESCRIPTION

The Company’s four universal product and solutions categories containing conflict minerals are described in detail as follows:

IMPROVEMENTS TO DUE DILIGENCE FOR CALENDAR YEAR 2023

To improve its conflict minerals due diligence efforts for calendar year 2023, the Company took the following actions: