Conflict Metals Corporate Policy

Purpose:

To outline Amphenol Corporation's practices regarding the sourcing of Conflict Minerals as well as the verification of such practices.

Scope:

This Policy applies to all employees of Amphenol Corporation ("Amphenol" or the "Company") and its subsidiaries and affiliates. Amphenol will, as far as it is reasonably practicable, ensure that the Company's activities, and those of its suppliers and subcontractors, will comply with this Policy.

Policy:

Amphenol is committed to implementing programs and practices that promote environmental sustainability and social responsibility, while continually improving product quality and reliability. To that end, Amphenol considers it unacceptable that the sourcing of certain "Conflict Metals" eventually incorporated into its products could be contributing to armed conflict. Conflict Metals are defined as gold (Au), tantalum (Ta), tin (Sn), and tungsten (W) derived from ores that have been mined in the Democratic Republic of the Congo or adjoining countries.

In carrying out this policy, Amphenol will implement programs and practices that, wherever practicable:

prevent the introduction of Conflict Metals into its products
verify the sources of gold, tantalum, tin, and tungsten used in its products
audit its suppliers for the continued accuracy of those verifications
maintain records of verifications for both internal and/or external audit
assign internal roles and responsibilities and provide appropriate staff training to manage program
communicate the Company's efforts to stakeholders

All Amphenol managers, employees, partners, and suppliers are expected to adhere to the spirit as well as the letter of this Policy.

Implementation:

The senior executive responsible for each local operating unit is ultimately responsible for the stewardship of the products made there and shall:

provide appropriate staffing and assign internal roles and responsibilities to manage the Product Stewardship - Conflict Metals Program
maintain an awareness of and familiarity with regional, national, and multi-national (e.g., European Union) statutes, regulations, directives, and criteria applicable to the operation
develop and implement programs and procedures necessary to carry out this Policy, addressing existing and new product lines
provide training to all affected employees of the requirements of this Policy and the implementation of its programs and procedures. In particular, that personnel who interface with Amphenol's customers (e.g., sales and marketing, product designers, quality assurance staff) should be familiar with all material aspects of this program
maintain an adequate, verifiable database, consistent with the products being manufactured at a local operating unit, to facilitate the transfer of information to customers and other stakeholders. Provide current information as input to an Amphenol-wide database of product information, if such is available.

The Company reserves the right to unilaterally terminate, suspend or amend this Policy at any time.