SD

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

FORUM ENERGY TECHNOLOGIES, INC.

(Exact name of registrant as specified in its charter)

Delaware	001-35504	61-1488595
(State or other jurisdiction of incorporation)	(Commission File Number)	(I.R.S. Employer Identification No.)
920 Memorial City Way, Suite 1000 Houston, Texas 77024
(Address of principal executive offices)

Registrant’s telephone number, including area code: (281) 949-2500

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:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.

Introduction

Forum Energy Technologies, Inc. (the “Company,” “we,” or “our”), a Delaware corporation, is a global oilfield products company, serving the subsea, drilling, completion, production and infrastructure sectors of the oil and natural gas industry. The Company designs, manufactures and distributes products and engages in aftermarket services, parts supply and related services that complement the Company’s product offering. Our product offering includes a mix of highly engineered capital products and frequently replaced items that are used in the exploration, development, production and transportation of oil and natural gas.

The Company is committed to maintaining the highest standard of ethical conduct and is concerned with humanitarian and environmental abuses associated with the mining, transportation and trade of certain minerals from conflict-affected regions of the world, including the Democratic Republic of Congo (the “Covered Countries”). To that end, and in connection with the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”), the Company is compelled to determine whether its products contain tantalum, tin, tungsten, or gold (collectively, “3TG”) sourced from the Covered Countries and used to finance armed groups in the region.

Section 1 – Conflict Minerals Disclosure

Item 1.01. Conflict Minerals Disclosure and Report.

For the 2015 assessment period, the Company’s surface production and process equipment and subsea technologies product lines (the “Reviewed Product Lines”) reviewed their materials, parts, products and/or product families to determine whether 3TG was present and necessary to the functionality thereof. For the 2014 assessment period we focused our due diligence efforts on the Company’s downhole products, drilling technologies, well stimulation and intervention, and valve solutions product lines to obtain a greater number and improved quality of supplier responses, and improve our suppliers’ understanding of the applicable Securities & Exchange Commission rules and regulations.

Following the Company’s Conflict Mineral Policy and Manual, we engaged in a Reasonable Country of Origin Inquiry. We developed a supplier list for each of the Reviewed Product Lines. We then requested that each party identified as supplying products or materials containing or possibly containing 3TG complete the EICC GeSI Conflict Mineral Reporting Template (the “GeSI Template”) in an effort to determine the country of origin of any 3TG products or materials.

Approximately 49% of the suppliers identified for the Reviewed Product Lines responded to the Company’s request for information for the 2015 assessment period, an improvement in the supplier responses received by the Reviewed Product Lines as compared to their prior assessment. The Company conducted a review of all GeSI Template responses to determine if products or materials supplied were DRC Conflict free, not DRC Conflict Free, or DRC Conflict Undeterminable.

A copy of the Company’s Conflict Minerals Policy, this Form SD and the attached Conflict Minerals Report can be found on its website at http://www.f-e-t.com.

Item 1.02 Exhibit

A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01.

Section 2 – Exhibits

Item 2.01. Exhibits.

Exhibit Number	Description
1.01	Conflict Minerals Report.

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.

Date: May 26, 2016	FORUM ENERGY TECHNOLOGIES, INC.
	By:	/s/ James W. Harris
	Name:	James W. Harris
	Title:	Executive Vice President and Chief Financial Officer

EX-1.01

Exhibit 1.01

Conflict Minerals Report

Section 1 - Introduction

Forum Energy Technologies, Inc. (“Forum,” or the “Company”) is committed to sourcing materials in a responsible manner. The Company has implemented policies and procedures to ensure compliance with applicable laws, including the Securities and Exchange Commission’s (the “SEC”) final rule implementing Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010. The Company’s efforts related to conflict minerals are also aligned with the work of the Electronic Industry Citizenship Coalition^® (“EICC”) and Global e-Sustainability Initiative (“GeSI”). The EICC’s and GeSI’s work includes the Conflict-Free Smelter Program and the Conflict Minerals Reporting Template (the “Conflict Minerals Questionnaire”). In accordance with Rule 13p-1, the Company undertook due diligence efforts for two of its six product lines to determine whether materials necessary to the functionality or production of its products are “DRC conflict free.”

Section 2 - Due diligence framework and determination

The Company designed its due diligence measures to materially conform with the internationally recognized due diligence framework set forth in the Organization for Economic Cooperation and Development (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”).

Section 3 - Due diligence measures undertaken

In conformance with the OECD Framework, the Company undertook the following due diligence measures:

Governance

In February 2014, Forum established a Conflict Minerals Policy and has implemented its Conflict Minerals Manual in furtherance of Forum’s efforts in this area. The Conflict Minerals Manual specifically sets out the due diligence steps and actions taken by Forum, and provides guidance for ongoing due diligence.

Product Line Applicability

In an effort to improve the number and quality of supplier responses, and establish direct communication with suppliers to garner an improved understanding of the applicable SEC rules and regulations, Forum chose to focus on four of its product lines during the 2014 assessment period, leaving the remaining product lines for the 2015 assessment period. During 2015, Forum’s surface production and process equipment, and subsea technologies product lines reviewed their materials, parts, products and/or product families to determine whether tin, tantalum, tungsten or gold (collectively, “3TG”) are present in any such items and necessary to

the functionality thereof. The Company established a process for identifying and determining the presence of 3TG in each product line’s product list. Once the products and/or product families were identified, each of the product lines developed a supplier list for each piece of material, part, product and/or product family identified as containing or that may contain 3TG.

Supplier Engagement

The Company sent each supplier identified in the product line applicability procedure the EICC GeSI Conflict Mineral Reporting Template, along with a communication providing instructions and requesting information regarding such supplier’s current conflict minerals status and compliance. The Company surveyed a total of 383 suppliers during its 2015 due diligence effort. Responses from a total of 186 suppliers, or approximately 49% of the suppliers surveyed, were received, an improvement in the supplier responses received by the Reviewed Product Lines as compared to their prior assessment. In addition, the Company distributed supplemental communications to certain suppliers in order to develop a greater depth of understanding of the Company’s Conflict Minerals program.

Supplier Response Review and Analysis of Red Flags

Each of the Company’s product lines reviewed its respective supplier responses to determine if each supplier’s materials, parts, or products provided to the Company contain 3TG that is sourced from conflict-affected regions of the world, including the Democratic Republic of Congo. As part of the Company’s review process, criteria were established and utilized to review supplier responses. The Company believes the established criteria benefited the Company by ensuring the reliability of each supplier’s responses.

Section 4 - Independent audit

The Company is not required to obtain an independent private sector audit at this time.

Section 5 - Next steps

The Company will continue to review its manual, policies and procedures for the upcoming reporting year to obtain improved supplier responsiveness. For the 2016 assessment period, the Company will focus on all of its product lines to review and ensure updates are provided to responses from previous years. The Company will continue to strive to obtain a higher percentage of supplier responses, including distributing frequently asked questions, training pamphlets, and establishing direct communication with suppliers to ensure their understanding of the applicable SEC rules and regulations.

Section 6 - Limitations

Given that we are a downstream user of 3TG, we must rely on the representations and information provided by our suppliers and other third parties within our supply chain. As a result, incomplete or inaccurate information provided by our suppliers or by a smelter or refiner could affect the accuracy or completeness of the information contained in this Conflict Minerals Report.

Note also that many suppliers provided responses with information based on a company or divisional level, rather than a product-level specific to the materials and components we use. As such, we are unable to confirm whether particular smelters or refining facilities supplied 3TG in materials or components for our products.