Form SD SMITH & NEPHEW PLC

Executive Summary

Smith & Nephew performed a Reasonable Country of Origin Inquiry (“RCOI”) on suppliers believed to provide Smith & Nephew with materials or components containing Conflict Minerals necessary to the functionality or production of Smith & Nephew’s products. Smith & Nephew’s suppliers identified 301 unique smelters and refineries (“smelters”) in their supply chains as of February 5, 2016. Smith & Nephew identified 37 of these smelters as sourcing (or there was a reason to believe they may be sourcing) from Covered Countries. Smith & Nephew’s due diligence review indicated that 36 of these smelters have been audited and recognized as conflict free by the Conflict Free Smelter Program (“CFSP”). The remaining 1 smelter sourcing from the Covered Countries was subject to Smith & Nephew’s risk mitigation process according to the Organisation of Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High- Risk Areas (“OECD Due Diligence Guidance”) and did not require removal from Smith & Nephew’s supply chain. This CMR was subject to an independent private sector audit (“IPSA”) conducted by Resource Consulting Services Limited (“RCS Global”) in accordance with the requirements of the Rule, the audit report for which is attached as Exhibit A to this CMR.

Based on these results, Smith & Nephew is DRC Conflict Free for the 2015 reporting period.

Company Management Systems

Smith & Nephew established strong management systems according to Step 1 of the OECD Due Diligence Guidance. Smith & Nephew’s systems included:

Reasonable Country of Origin Inquiry (RCOI)

Smith & Nephew designed its RCOI process in accordance with Step 2A and 2B of the OECD Due Diligence Guidance. Smith & Nephew’s RCOI process involved two stages:

Supplier RCOI

Smith & Nephew designed its supplier RCOI process to identify, to the best of Smith & Nephew’s efforts, the smelters in Smith & Nephew’s supply chain in accordance with Step 2A of the OECD Due Diligence Guidance. Smith & Nephew’s supplier RCOI process for the 2015 reporting period included the following:

Smith & Nephew’s suppliers identified 301 smelters in their supply chain. The specific list of smelters is included in the ‘Smelters and Refineries’ section at the end of this CMR.

Smelter RCOI

Due to the overlap between smelter RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this CMR.

For the 2015 reporting period, Smith & Nephew’s Supplier and Smelter RCOI processes were executed by Claigan Environmental Inc. (“Claigan”). The design of Claigan’s processes was independently audited in 2015 against the requirements of Step 2 of the OECD Due Diligence Guidance.

Due Diligence

Smith & Nephew’s due diligence process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Due Diligence Guidance. The due diligence process has been audited by RCS Global, our independent private sector auditor. The audit report is set forth as Exhibit A to this CMR.

Smelter RCOI and Due Diligence

Smith & Nephew’s smelter RCOI and due diligence process were designed to:

Smith & Nephew’s smelter RCOI and Due Diligence Process included the following:

Smith & Nephew’s suppliers identified 301 smelters in their supply chain. Smith & Nephew identified 37 smelters that source, or there is a reason to believe they source, from the Covered Countries. Smith & Nephew determined that 36 of these 37 smelters have been audited and recognized as conflict free by the CFSP. Smith & Nephew conducted risk mitigation on the remaining 1 smelter.

Risk Mitigation

Smith & Nephew conducted risk mitigation on 1 smelter that was not recognized as conflict free by the CFSP and was sourcing from the Covered Countries. Smith & Nephew’s risk mitigation was designed in accordance with Step 3B of the OECD Due Diligence Guidance and was reported to the Matt Stober, Group President of Global Operations, in accordance with Step 3A of the OECD Due Diligence Guidance. Smith & Nephew’s risk mitigation process included the following:

Smith & Nephew did not require the removal of the smelter subject to Smith & Nephew’s risk mitigation process if there was no reason to believe it was directly or indirectly financing or benefitting armed groups in the Covered Countries. This smelter is scheduled to be re-visited in the 2016 reporting period. This process is consistent with Step 3B of the OECD Due Diligence Guidance and helps prevent unnecessary boycotts of the Covered Countries.

Risk mitigation was required for 1 smelter verified by suppliers likely to be in Smith & Nephew’s supply chain:

Tin Smelter - Rwanda

Improvement Plan

Smith & Nephew is taking and will continue to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary conflict minerals in Smith & Nephew’s products could directly or indirectly benefit or finance armed groups in the covered countries:

Independent Private Sector Audit

We obtained an independent private sector audit of whether the design of our due diligence process (as describe above) conforms to a recognized due diligence framework and whether our description of the due diligence process included in this CMR is consistent with the due diligence measures that we undertook. The audit report is set forth in Exhibit A to this CMR.

Smelters and Refineries

Below are the smelters reported to Smith & Nephew’s as likely in Smith & Nephew’s supply chain in the 2015 reporting period.

37 of the smelters above declared to be sourcing or there was reason to believe are sourcing from the covered countries. Under the Rule, the requirement is to identify whether a smelter is sourcing from the covered countries and there is no requirement to identify the specific covered country applicable to the smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified covered countries are The Democratic Republic of the Congo, Rwanda, Burundi, and Tanzania.

Exhibit A 

INDEPENDENT PRIVATE SECTOR AUDIT REPORT

DODD FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT, SECTION 1502

SMITH & NEPHEW INC.

To the Board of Directors

Resource Consulting Services Limited (“RCS Global” or “RCS”) conducted an Independent Private Sector Audit (IPSA) of Smith & Nephew Inc. (“the Company”) Conflict Minerals Report for the reporting period of January 1 to December 31, 2015. We examined evidence relating to the audit objectives set forth in 17 CFR Part 249b.400, Section 1, Item 1.01, which state that the auditor is to express an opinion or conclusion as to:

1) Whether the design of the Company’s due diligence framework as set forth in Sections on Company Management Systems and Due Diligence the Conflict Minerals Report for the reporting period from January 1 to December 31, 2015, is in conformity, in all material respects, with the criteria set forth in the Organisation of Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas, Second Edition 2013 (“OECD Guidance”), and

2) Whether the Company’s description of the due diligence measures it performed, as set forth in the Section on Due Diligence in the Conflict Minerals Report for the reporting period from January 1 to December 31, 2015, is consistent with the due diligence process that the Company undertook.

Management is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. The opinion or conclusion in this audit report is in relation to the two audit objectives. These audit objectives are narrowly defined and do not include the auditor’s opinion on:

Consequently, we do not express an opinion or conclusion on the matters listed above or any other matters included in any section of the Conflict Minerals Report other than the design of the Company’s due diligence framework and the Company’s description of the due diligence measures it performed as set forth in the Sections mentioned in the audit objectives.

We conducted this performance audit in accordance with generally accepted government auditing standards, in particular Chapters 1, 2, 3, 6 and 7 of the U.S. Government Accountability Office Generally Accepted Government Auditing Standards, Revision of December 2011. Those standards

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require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.

For the first audit objective, we reviewed policies, processes and procedures describing the design of the due diligence framework and conducted interviews with the persons directly responsible for the conflict minerals program at the Company as well as phone interviews with the third party service provider responsible for the design of the due diligence framework. For the second audit objective we reviewed records supporting the implementation of due diligence measures as described in the Conflict Minerals Report and conducted interviews with the persons of the Company and the third party service provider directly involved in the implementation of these measures. For the second audit objective we adopted a sampling approach for the review of records, taking into account the type of mineral, the total population as well as type and level of risk associated with sourcing practices of supply chain actors.

We believe that the evidence obtained provides a reasonable basis for our findings based on our audit objectives.

Management was provided an opportunity to review and offer comments on a draft of this report and had no comments to the draft report.

In our opinion,

Resource Consulting Services Limited

Kigali, 3^rd March 2016

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