SEC Form SD filed by Innovex International Inc.

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

Innovex International, Inc.

(Exact name of registrant as specified in its charter)

Matt Steinheider, (346) 398-0000

(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, and provide the period to which the information in this form applies:

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2024.

☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended      .

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Disclosure Requirement

This disclosure for the year ended December 31, 2024 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 (defined below) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “Conflict Minerals”). The Rule imposes certain reporting obligations on SEC reporting companies whose manufactured products contain Conflict Minerals that are necessary to the functionality or production of their products. If a company can establish that its necessary Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) or from recycled or scrap sources, or if the company has no reason to believe that its necessary Conflict Minerals may have originated in the Covered Countries or reasonably believes that its necessary Conflict Minerals did come from recycled or scrap sources, it must disclose that determination, submitting a Form SD that includes a description of the Reasonable Country of Origin Inquiry it undertook in making its determination and the results of that inquiry.

The Company

This disclosure has been prepared by management of Innovex International, Inc.. Unless otherwise indicated, the terms “Company,” “Innovex,” “we,” “us” and “our” refer to Innovex International, Inc., together with its subsidiaries. The information in this disclosure includes the activities of all subsidiaries that are required to be consolidated.

Conflict Minerals Disclosure

Reasonable Country of Origin Inquiry

Pursuant to the Rule, we conducted, in good faith, a reasonable country of origin inquiry concerning any Conflict Minerals that were necessary to the functionality or production of products manufactured, or contracted to be manufactured, for sale by Innovex during the year ended December 31, 2024. As part of our analysis, we assessed our manufactured products to identify Conflict Minerals scope and risk. As a result of our analysis, we identified the following products containing Conflict Minerals:

Our analysis concluded that these Conflict Minerals are contained in components of our products manufactured by and purchased from our suppliers. Our analysis further determined that no other Conflict Mineral or Conflict Mineral derivative is contained as a necessary element to the functionality or production of any product manufactured for sale by the Company.

We have maintained a Conflict Minerals policy since 2014. Under the policy, we expect each of our suppliers to respond to inquiries related to Conflict Minerals, to undertake appropriate due diligence and to conduct its operations in an ethical manner.

We surveyed all suppliers of components of our products that contain tungsten, tantalum, tin and gold and acquired information from approximately 75% of our suppliers regarding their use of Conflicts Minerals. No supplier provided any reason for the Company to believe that Conflict Minerals contained in components supplied to us originated in the Covered Countries.

The Company has completed its Reasonable Country of Origin Inquiry for the year ended December 31, 2024 and has determined that it has no reason to believe that the Conflict Minerals contained in components necessary to the functionality or production of its products manufactured for sale may have originated from the Covered Countries. The Company uses no other Conflict Mineral or Conflict Mineral derivative as a necessary element to the functionality or production of any product it manufactures for sale.

As a downstream purchaser of Conflict Minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals. Our conclusions are necessarily based on information from our direct and indirect suppliers. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.

In accordance with the Rule, this disclosure is available on the Company’s website at www.innovex-inc.com.

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.