Conflict Minerals Policy

Last Updated: July 2026

Summary


The Democratic Republic of Congo and surrounding countries (collectively, the “Covered Countries”) are rich in natural resources, including gold and the minerals from which tin, tungsten, and tantalum are derived (collectively, “Conflict Minerals). Armed groups responsible for violence and human rights violations in the Covered Countries fund their activities by exploiting the trade in Conflict Minerals.


Lennox International Inc. and its subsidiaries and affiliates (collectively, the “Company”) are committed to conducting business with respect for human rights and in accordance with applicable laws, as outlined in our Code of Business Conduct, Business Partner Code of Conduct, and Human Rights Policy. As part of this commitment, we take steps that are designed to ensure that our sourcing of Conflict Minerals is done responsibly and does not help finance armed conflict or related human rights abuses in the Covered Countries. As required by the U.S. Securities and Exchange Commission, we publicly disclose information related to our sourcing of Conflict Minerals on an annual basis.


Policy

The Company does not source Conflict Minerals directly from smelters or refiners. We have established a Conflict Minerals compliance program that is designed to ensure that suppliers conduct responsible sourcing of Conflict Minerals. We expect our suppliers to comply with applicable laws, conduct due diligence on their respective supply chains, and provide information to the Company to support our public disclosure regarding the sourcing of Conflict Minerals.

As part of our Conflict Minerals supply chain due diligence process, the Company uses procedures designed by the Responsible Minerals Initiative (“RMI”) and the Organization for Economic Co-operation and Development. We require that suppliers provide us with country information about Conflict Minerals in our supply chain on an annual basis, including through the use of RMIS’ Conflict Minerals Reporting. We assess supplier responses for accuracy and completeness and may request further due diligence information as required. If a supplier refuses to adhere to this Policy or non-compliance is detected, we reevaluate the use of their materials in future projects.


The Company is committed to assisting customers’ efforts to adhere to their legal obligations and responsible sourcing of Conflict Minerals and will assist in providing appropriate information to support its customers’ compliance efforts.

Asking Questions and Reporting Suspected Violations


The Company is committed to the humanitarian goal of helping to end violent conflict in the Covered Countries. If you have questions or believe a Company employee or supplier is violating our values, this Policy, or applicable laws, you have a responsibility to speak up using one of the following options:

  • Filing a report with EthicsPoint – which is maintained by an independent third-party, is available 24/7 in a number of languages, and allows employees to remain anonymous if they choose:
  • Reaching out directly to a manager or a member of Human Resources, Legal, or Ethics & Compliance; or
  • Emailing Ethics & Compliance at ethics@lennox.com.


Employees can use the option they prefer; the important thing is to speak up. The Company prohibits retaliation against employees for reporting suspected violations in good faith or for participating in investigations.