UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

Date of report: May 13, 2022

ESCO TECHNOLOGIES, INC.

(Exact name of the registrant as specified in its charter)

9900A Clayton Road

St. Louis, Missouri 63124-1186

(Address of principal executive offices) (Zip code)

David M. Schatz, Senior Vice President and General Counsel

(314) 213-7200

(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:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021

¨     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

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, ESCO Technologies Inc. (“ESCO”) is filing this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report. This Form SD and the Conflict Minerals Report, as well as ESCO’s Conflict Minerals Policy, are posted and publicly available on ESCO’s corporate website,www.escotechnologies.com. Information contained on ESCO’s website does not constitute part of this Form SD or its Exhibits.

Item 1.02 Exhibit

The Conflict Minerals Report required by Item 1.01 is provided as Exhibit 1.01.

Section 2. Resource Extraction Issuer Disclosure

N/A

Section 3. Exhibits

Item 3.01 Exhibits

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.

ESCO TECHNOLOGIES INC.

EXHIBIT 1.01

Conflict Minerals Report of ESCO Technologies Inc.
for Calendar Year 2021

This is the Conflict Minerals Report of ESCO Technologies Inc. (“ESCO”) for calendar year 2021 provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”). The Conflict Minerals Rule requires ESCO to perform certain procedures and disclose information about the use and origin of “Conflict Minerals” which are necessary to the functionality or production of products ESCO manufactures or contracts to have manufactured. “Conflict Minerals” are defined for purposes of the Conflict Minerals Rule as cassiterite, columbite-tantalite, wolframite, their respective derivatives tin, tantalum and tungsten, and gold.

ESCO Technologies is a global provider of highly engineered products and solutions to diverse and growing end-markets that include the aerospace, space, healthcare, wireless, consumer electronics, electric utility, and renewable energy industries. During 2021, ESCO conducted its business in three operating segments, through a number of wholly-owned direct and indirect subsidiaries. These segments, together with the significant domestic and foreign operating subsidiaries within each segment during 2021, were as follows; more complete information about the Company and its subsidiaries is provided on the Company’s website and in its latest Form 10-K filed with the Securities and Exchange Commission:

Aerospace and Defense:

Crissair, Inc.

Globe Composite Solutions, LLC

Hi-Tech Metals, Inc.

Mayday Manufacturing Co.

PTI Technologies Inc.

VACCO Industries

Westland Technologies, Inc.

Utility Solutions Group:

Doble Engineering Company

I.S.A.–Altanova Group S.r.l.

NRG Systems, Inc.

RF Shielding and Test:

ETS-Lindgren Inc.

ESCO’s products require a wide variety of components and materials, and Conflict Minerals that are necessary to the functionality or production of ESCO’s products are common across its product portfolio. ESCO sources its components and subassemblies from a global supply base that includes distributors, value-added resellers, original equipment manufacturers and contract manufacturers.

ESCO’s Reasonable Country of Origin Inquiry

In accordance with the Conflict Minerals Rule, ESCO has performed a “reasonable country of origin inquiry” (“RCOI”) on Conflict Minerals in its supply chain to determine whether these Conflict Minerals were sourced from the Democratic Republic of Congo (“DRC”) or adjoining countries or were from recycled or scrap sources.

As a result of its RCOI process, ESCO has concluded in good faith that during 2021:

Description of ESCO’s Due Diligence

ESCO designed and performed its due diligence measures to conform in all material respects with the Organisation for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (CAHRAs): Third Edition (the “OECD Guidance”) including related Supplements for each of the Conflict Minerals in addition to guidance provided by the SEC and Responsible Minerals Initiative (RMI). Although the updated OECD Guidance clarifies that the framework requires detailed due diligence as a basis for responsible supply chain management of all minerals from Conflict Affected and High Risk Areas, currently ESCO is focused on the SEC required 3TGs in the DRC and surrounding countries and in the future will expand the program to other CAHRAs or minerals as recommended by the SEC.

ESCO’s due diligence measures were based on the OECD Guidance. ESCO is many steps removed from the mining of Conflict Minerals and does not purchase raw ore or unrefined Conflict Minerals, the due diligence included extensive communications with its suppliers. ESCO, for the last eight years, has focused its efforts on its suppliers and contract manufacturers in an effort to continue to build Conflict Mineral awareness, assess the transparency of its supply chain and identify the smelters/refiners in its supply chain.

ESCO maintains a system of internal procedures and controls to identify and trace Conflict Minerals within its supply chain. A summary of ESCO’s activities, which are in line with the OECD Guidance, are outlined below.

Step 1: Establish strong company management systems

Step 2: Identify and assess risks in the supply chain

Step 3: Design and implement a strategy to respond to identified risks

Step 4: Carry out independent third-party audit of smelters’/refiners’ due diligence practices

Step 5: Report annually on supply chain due diligence

Continuous Improvement of Supply Chain Due Diligence

ESCO will continue to improve its due diligence efforts through increasingly focused efforts including (but not limited to):

Determination

Based on the process described above, ESCO received responses from 542 direct material suppliers, representing 44% of total suppliers surveyed and 41% of the active parts surveyed that were used in its 2021 manufactured goods. ESCO believes the continued lower response rate since reporting year 2019, as compared to earlier years, is likely attributable to the continued impact of the COVID-19 coronavirus pandemic.

Based on the information provided by ESCO’s suppliers utilized during 2021, ESCO believes that the facilities that may have been used to process 3TGs in ESCO’s products include the smelters and refiners listed in Appendix I, starting on page 7. The supplier responses included Conformant, Active (in the process of a RMI audit), Known (previously identified as a Smelter or Refiner by RMI or CFSI) and Unknown smelters, but based on the absence of reliable information on the Unknown smelters, only the Conformant and Active and Known smelters have been included.

Based on the due diligence efforts and the absence of full supply chain visibility throughout the supply base, ESCO is unable to determine the source of origin of the conflict minerals and does not have sufficient information to conclusively determine the countries of origin of 3TGs contained in ESCO’s products.

APPENDIX I