FLS Flowserve Corp

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form SD

SPECIALIZED DISCLOSURE REPORT

Flowserve Corporation

(exact name of the registrant as specified in its charter)

Shakeeb Mir

(972) 443-6500

(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed:

SECTION 1 – CONFLICT MINERALS DISCLOSURE

Item 1.01. Conflict Minerals Disclosure and Report.

Conflict Minerals Disclosure

A copy of the Flowserve Corporation (the “Company”) Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at https://ir.flowserve.com/financial-information/sec-filings as well as the SEC’s EDGAR database at www.sec.gov.

Item 1.02. Exhibit

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

SECTION 2 – RESOURCE EXTRACTION ISSUER DISCLOSURE

Item 2.01. Resource Extraction Issuer Disclosure and Report.

Not applicable.

SECTION 3 – EXHIBITS

Item 3.01. Exhibits.

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.

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SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

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Exhibit 1.01

Flowserve Corporation

Conflict Minerals Report

For The Year Ended December 31, 2023

This report for the year ended December 31, 2023 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants who manufactured or contracted to manufacture products which contained Conflict Minerals that are necessary to the functionality or production of such products.

Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“Conflict Minerals”, or “3TG”). These requirements apply to all registrants that have Conflict Minerals that are necessary to the functionality or production of their products whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.

This report has been prepared by management of Flowserve Corporation (herein referred to as “Flowserve,” “the Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated under U.S. generally accepted accounting principles.

Flowserve is a world-leading manufacturer and aftermarket service provider of comprehensive flow control systems. We develop and manufacture precision-engineered flow control equipment integral to the movement, control and protection of the flow of materials in our customers’ critical processes. Our product portfolio of pumps, valves, seals, automation and aftermarket services supports global infrastructure industries, including oil and gas, chemical, power generation and water management, as well as general industries markets where our products and services add value. Our principal products are sold through two business segments:

Supply Chain

We manufacture a wide range of products that contain Conflict Minerals, but we do not purchase ore or unrefined Conflict Minerals from mines, smelters or refiners and generally are many steps removed in the supply chain from the mining of these minerals. As a result, we rely on suppliers for various components and parts that contain Conflict Minerals that are utilized in the assembly of our products. Due to the size of our Company, the complexity of our products, and our location in the supply chain being many steps downstream from mines, smelters and refiners, we must rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in the components and parts supplied to us (including sources of Conflict Minerals that are supplied to them from their suppliers). Further, many of our suppliers are not SEC registrants subject to the reporting requirements of the Rule and as a result, have immature Conflict Minerals programs. As a result of this complexity, we conducted a survey of the suppliers that focused not only on those who represented the majority of our expenditures in 2023, but also focused on suppliers where the nature of the component, or the location of the supplier, indicated that those components had a higher probability to contain Conflict Minerals.

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Flowserve undertook the following measures to perform a country of origin inquiry on its Conflict Minerals:

The above efforts led to a response rate of 39%. The suppliers that responded captured over 78% of the relevant spend, up from 65% for the year ended December 31, 2022.

As a result of the reasonable country of origin inquiry, we are unable to determine the origin of the Conflict Minerals in our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries. For that reason, we performed additional due diligence and are required under the Rule to submit to the SEC this Conflict Minerals Report.

Conflict Minerals Policy:

Flowserve culture is centered on ethics, integrity, and trust. Our values drive how we treat each other, our customers, suppliers, partners and even our competitors. By combining uncompromising character, transparent business behavior, mutual respect, and world-class products and services, we seek to build an enduring culture that creates satisfied customers, engaged employees and sustainable, profitable growth. As a result, our ethical business culture supports global efforts to assist in the eradication of Human Rights abuses in the Covered Countries, where the mining of certain minerals has partially financed the long-standing conflict in this region.

Flowserve supports the objectives and intent of this Conflict Minerals legislation. Additionally, we are committed to working toward a conflict free supply chain by implementing a management program integrated with our policies and processes to align our worldwide suppliers with this policy. Our Conflict Minerals program is addressed in our Supplier Code of Business Conduct, our Terms and Conditions with suppliers, and our Purchase Order requirements.

For additional information about our commitment to responsible sourcing and for our full Conflict Minerals policy, please visit our website at: http://www.flowserve.com/About-Flowserve/Corporate-Information/Conflict-Minerals-Policy

Our due diligence measures have been designed to conform, with the framework in The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third edition, 2016) (the “OECD Guidance”) and the related Supplement on Tin, Tantalum, and Tungsten and the Supplement on Gold.

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3.2. Due Diligence Performed

3.2.1. Establish Strong Company Management Systems

As described above, Flowserve has adopted a company Conflict Minerals policy which is posted on our website. Additionally, as part of our management system for Conflict Minerals, Flowserve has established a cross functional internal task force, realigned active management resources, and created a position that is responsible for managing the Conflict Minerals program and requirements at Flowserve. A senior Flowserve executive, supported by a senior Flowserve lawyer, has oversight responsibility for Flowserve’s Conflict Minerals task force. This management team is responsible for implementing the Conflict Minerals management systems and communicating them throughout the organization and our business segments. The team is comprised of subject matter experts from relevant functional areas such as supply chain, engineering, communications, legal, and business integrity and compliance. Senior management and the Board of Directors are briefed about our management systems and due diligence efforts on an annual basis.

3.2.2. Identify and Assess Risks in Supply Chain

Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives to leverage information and common process. Further, as discussed above, we conducted an analysis of our supply base, and identified and performed additional diligence on suppliers that supply products that may contain Conflict Minerals and continued to contact unresponsive suppliers. We also monitor and track suppliers that may not meet the requirements set forth in our Conflict Minerals policy to determine their progress in meeting those requirements.

3.2.3. Design and Implement a Strategy to Respond to Risks

With respect to those products we manufacture or cause to be manufactured, Flowserve seeks to implement the following steps to mitigate the risk that necessary Conflict Minerals benefit armed groups:

3.2.4. Carry out Independent Third Party Audit of Supply Chain Due Diligence

Flowserve does not have a direct relationship with smelters and refiners, nor do we perform direct audits of these entities that potentially provide our supply chain with Conflict Minerals. However, we do rely upon industry efforts to influence smelters and refineries to undertake audits and certification processes through RMI’s Responsible Minerals Assurance Process (“RMAP”).

3.2.5. Report on Supply Chain Due Diligence

In addition to this report, see our website at https://www.flowserve.com/en/more/about-company/conflict-minerals-policy for our full Conflict Minerals policy.

Survey Responses

Responses included the names of 470 entities listed by our suppliers as smelters or refiners (“SORs”), and based on our due diligence to date and information available from public sources, the Company believes that only 371 of the entities identified by our suppliers are engaged in smelting and/or refining activities. Approximately 65% (or 241) of the 371 entities were identified as conformant using the RMI Conformant Smelter List. All SORs listed by Flowserve suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. The final comparison was done utilizing the RMI-maintained smelters list from May 21, 2024.

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Flowserve is typically many tiers in the supply chain removed from SORs, and our direct suppliers have not traced materials supplied to Flowserve back to individual SORs. Many of our suppliers provided information to Flowserve on all SORs identified to them by their suppliers and have not been able to confirm that necessary 3TG processed by these SORs is contained in the products they have supplied to us because some of the suppliers did not provide their CMRT at the product level. Therefore, it is possible that the list contains SORs not used to process necessary 3TG contained in our products.

Efforts to determine mine or location of origin

Through our participation in RMI, the OECD implementation programs, and requesting our suppliers to complete the template, we have determined that seeking information from our suppliers and their diligence with their sub-suppliers about Conflict Minerals smelters and refiners in our supply chain represents the most reasonable effort to determine the mines or locations of origin of the Conflict Minerals in our supply chain.

Smelters or Refiners

To date, Flowserve has received very limited information regarding smelters and/or refiners involved in the Company’s supply chain, as well as the origin of any materials they may potentially produce for Flowserve’s suppliers. The majority of our suppliers were unable to represent and/or confirm to us that Conflict Minerals from entities that are smelters and refiners had actually been included in components such suppliers supplied to Flowserve. Again, this reality is principally due to the fact that our suppliers provided data at a company or divisional level, and, not specific to the products such suppliers produce for Flowserve.

Appendix A, as attached, contains a list of smelters and refiners that Flowserve suppliers identified as being present in their supply chains that we believe may have processed 3TG contained in materials supplied to the Company. While our suppliers have provided names of additional entities to those listed in Appendix A, our review process remains ongoing related to the determination of whether they are smelters or refiners for Conflict Minerals relevant to our products.

We are uncertain of the Conflict Mineral status of the products that we manufacture that are subject to the reporting obligations of Rule 13p-1, because we have been unable to determine the origin of the Conflict Minerals they contain or to determine whether they come from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. This said, however, Flowserve will continue due diligence efforts going forward.

We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries:

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APPENDIX A¹

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