UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

Apple Inc.

(Exact name of registrant as specified in its charter)

1 Infinite Loop

Cupertino, California 95014

(Address of principal executive offices) (Zip Code)

D. Bruce Sewell

Senior Vice President,

General Counsel and Secretary

(408) 996-1010

(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:

Section 1 – Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

A copy of Apple Inc.’s (“Apple’s”) Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015 is provided as Exhibit 1.01 hereto and is publicly available at investor.apple.com/sec.cfm. Apple’s determination and related disclosures relating to materials that may come from recycled and scrap sources are included in Apple’s Conflict Minerals Report and incorporated by reference herein.

Section 2 – Exhibits

Item 2.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015.

* * * * *

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SIGNATURE

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.

Apple Inc.

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EXHIBIT INDEX

4

Exhibit 1.01

Apple Inc. | 2015 Conflict Minerals Report | 1

CONFLICT MINERALS REPORT

Overview of Apple’s Commitment To Responsible Sourcing

Apple is committed to responsible sourcing, and working to ensure that the minerals in its products do not finance armed conflict is an important part of its dedication to operate a responsible supply chain. As of December 31, 2015, after five years of devoted effort, 100% of the identified smelters and refiners in Apple’s supply chain for current products were participating in an independent third party conflict minerals audit (“Third Party Audit”) program. Apple believes that this effort has driven awareness and improved sourcing practices across a wide base of smelters and refiners that supply the industry well beyond Apple.

While this is an important milestone, and may be viewed by some companies as grounds to declare themselves “conflict free,” Apple does not believe that Third Party Audit program participation alone is sufficient to label products “conflict free.” Apple believes it has more work to do. In 2016, Apple is turning its attention to two key areas: enhancing due diligence in the gold supply chain and helping improve local incident reporting and issue resolution.

Apple plans to continue to review in detail credible reports of incidents in the Democratic Republic of the Congo (the “DRC”) and adjoining countries (collectively, the “Region”) that may potentially connect to Apple’s supply chain and confirm the transparent reporting and resolution of any incidents related to armed groups where these incidents may reasonably relate to its supply chain. Additionally, Apple intends to further its efforts to drive smelters and refiners to comply with Third Party Audits, and Apple will continue to remove from its supply chain those smelters or refiners that do not comply.

Apple recognizes that it will take the contributions of many different stakeholders to effect lasting change in the minerals sector of the Region. Accordingly, Apple will continue its efforts to partner with like-minded companies, directly engage with key non-government and government organizations, and work with Third Party Audit program facilitators to drive improvements aimed at the ultimate objective of protecting human rights in the Region.

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Details of Apple’s Approach to Responsible Sourcing

Foundational Due Diligence: Third Party Audit Program Participation

Apple believes that foundational conflict minerals due diligence necessitates having all smelters and refiners in Apple’s supply chain participating in a Third Party Audit program. Third Party Audits typically involve an examination of individual purchasing transactions on a sample basis to assess the reasonableness and effectiveness of conflict mineral sourcing practices at the particular smelter or refiner.

Currently there exist a number of different Third Party Audit programs. Apple principally supports the work of the Conflict Free Sourcing Initiative (the “CFSI”). Apple has served in leadership roles supporting the CFSI’s Third Party Audit program—the Conflict Free Smelter Program (the “CFSP”). Apple also supports the efforts of other Third Party Audit programs, such as those carried out by the London Bullion Market Association (the “LBMA”), the Responsible Jewellery Council and ITRI through its Tin Supply Chain Initiative (“iTSCi”), to be better aligned with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Apple believes that Third Party Audits play a significant role in providing assurances that smelters and refiners have due diligence systems in place to ensure that their operations and sourcing do not support conflict in the Region. To expand the number of smelters and refiners participating in a Third Party Audit program, Apple representatives have worked directly on the ground with smelters and refiners since 2011 to assist them with the audit process, and Apple representatives also have provided due diligence assistance to many smelters and refiners.

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Further Due Diligence: Incident Review and Resolution

As part of its reasonable due diligence, Apple takes additional steps beyond the foundational due diligence embodied by Third Party Audit programs for smelters and refiners. These steps include detailed review of credible reports of incidents which may potentially connect to Apple’s supply chain, and confirming that incidents related to armed groups which may reasonably relate to Apple’s supply chain are transparently reported and addressed.

Apple reviewed more than 700 iTSCi reports for 2015 relating to incidents, potentially associated with mine sites connected to various smelters in Apple’s supply chain. These smelters also support many other companies in the electronics industry. Based on its review, Apple found that in a few cases individuals associated or potentially associated with armed groups, in particular the police in the DRC and the DRC national army, were alleged to be involved in incidents linked to smelters in Apple’s supply chain. While, to date, Apple does not have reason to believe that these incidents resulted in associated specified minerals being included in Apple’s products, Apple remains concerned about a number of reported incidents. Accordingly, Apple is actively engaged with appropriate stakeholders to better understand incident reports and how they are addressed and, in the case of three specific incidents, continues to actively investigate the follow-up actions that have been taken to address these incidents.

Driving Measurable Progress for the Collective Good

In response to concerns raised that gold, columbite-tantalite (coltan), cassiterite, wolframite, tantalum, tin, and tungsten (collectively, the “Subject Minerals”) from the Region were supporting conflict by armed groups, Apple determined to expand its smelter and refiner base participating in Third Party Audit programs rather than simply ban minerals from the Region in its supply chain. Apple’s decision was intended in part to increase the number of such participating smelters and refiners across the industry, not only in Apple’s supply chain. What began with 109 identified non-compliant smelters and refiners at the end of 2010, turned into significant, measurable progress over a few short years.

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By the end of 2013, 44% of smelters and refiners were participating in a Third Party Audit program. While this was more than double the number of participating smelters and refiners at the end of 2012, it was still a long way from Apple’s goal of 100% smelter and refiner participation. In order to achieve this goal, Apple increased the pressure each year. In 2014, Apple began publishing the names, countries and compliance status of smelters and refiners in its supply chain. Beginning in 2014, Apple also launched supply chain wide campaigns that established strict deadlines for smelters and refiners to demonstrate their commitment to undergo a Third Party Audit or be removed from Apple’s supply chain.

Leveraging Expertise to Drive Desired Outcomes

Knowing that sustainable responsible sourcing cannot be achieved by pressure alone, Apple began offering assistance and support to smelters and refiners, as well as suppliers. Since 2011, Apple representatives and subject matter experts have met in the field with smelters and refiners to encourage participation and offer audit preparation assistance (see Annex I: 2015 Due Diligence Measures Performed, point 2, for 2015 details). And in an effort to strengthen alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, including the related supplements on tantalum, tin, tungsten, and gold (the “OECD Due Diligence Guidance”), in 2015 Apple notified smelters and refiners of identified risks and requested they report on and respond to those risks.

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Apple has also been conducting spot audits since 2013 to assess suppliers’ understanding of due diligence requirements. In order to better support suppliers having to change sourcing or push smelters or refiners to become compliant, in 2015 Apple provided in-person training to 58 suppliers not yet meeting Apple’s requirements and developed a web-based training tool. Relevant training materials have been made available to partners outside of Apple’s supply chain in order to be further developed for use industry-wide. Apple believes that making these materials available will strengthen supplier due diligence across the industry.

The combination of training, public reporting and a ticking clock drove the number from 82 smelters and refiners participating in a Third Party Audit program by the end of 2013 to 242 participating smelters and refiners by the end of 2015. Of these 242 participating smelters and refiners, 86% had already completed a Third Party Audit by the end of 2015, while the other 14% were in the process of undergoing such a Third Party Audit as of December 31, 2015.

Still, some smelters and refiners chose not to take advantage of Apple’s assistance programs, while others refused to take part in any Third Party Audit entirely. Neither pressure nor incentives for help were enough to persuade them to comply. Accordingly, Apple directed the removal of 35 smelters and refiners not willing to participate in a Third Party Audit, and as of December 31, 2015, these 35 smelters and refiners are no longer reported in Apple’s supply chain. In addition, Apple has notified its suppliers that it has recently required the removal of another refiner from its supply chain for its failure to satisfy requirements in connection with its Third Party Audit and its subsequent delisting by the LBMA after December 31, 2015. Apple has had no choice but to remove these smelters and refiners from its supply chain, as Apple views compliance as non-negotiable.

Going to Greater Lengths on the Ground

In 2015, Apple personnel spent hundreds of hours in the Region, to better understand the challenges of conducting effective due diligence in high-risk areas. Based on this work, Apple is focusing further attention on two key areas: allegations of illicit trade of gold and local incident reporting in existing traceability systems.

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The focus on gold was chosen because of the low number of gold mine sites participating in a traceability program, and a high concentration of armed groups purportedly involved in the gold trade. Accordingly, Apple initiated an independent third party investigation of its gold supply chain, and, as part of this investigation, uncovered specific allegations of, among other things, smuggling of gold that could be associated with armed groups (see Annex I for further details). Though still unsubstantiated, Apple continues to investigate such allegations in order to determine their veracity. Where necessary, Apple will consider and address, if reasonably practical, the situation, to the extent it relates to Apple’s supply chain.

Considering reports from numerous groups and organizations related to traceability gaps, stolen minerals, and fraudulent use of tags, Apple has focused on local incident reporting to determine if local systems are effectively able to capture and remediate incidents when they arise, and if any incidents of concern may be associated with Apple’s supply chain. Apple’s review identified incidents of varying nature and concern, including, among others, incidents involving theft of, and/or fraud in connection with, tags and minerals and military and police levies or payments at or near mine sites. As of the date of this report, not all 2015 incidents have been publicly reported, fully traced to minerals associated with smelters, resolved or remediated. Notwithstanding these limitations, Apple has sought to confirm that every relevant identified incident was followed up including, where appropriate, by applicable local authorities.

Based on the reports reviewed by Apple and additional information provided by iTSCi, Apple has received confirmation that three incidents linked to smelters reported in Apple’s supply chain have occurred in which individuals identified as members or potential members of organizations within the meaning of “armed groups,” as defined in Item 1.01(d)(2) of Form SD, in particular the police in the DRC and the DRC national army, were alleged to be involved. Each incident appears to have involved no more than a few individuals in isolated theft, illegal tax or similar criminal activity, potentially for personal gain, and, based on information received to date, the alleged perpetrators have been sanctioned or the specific incident has otherwise received some level of official redress by the local authorities. Apple continues to actively investigate the follow-up actions that have been taken to address these incidents. However, with respect to these three incidents, Apple has not, to date, been able to determine whether specific minerals were included in Apple’s products. The challenges with tracking specific mineral quantities through the supply chain currently prevent the traceability of any specific mineral shipment through the entire manufacturing process.

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Apple believes there is little doubt that there is a need to enhance gold trading due diligence, to increase local stakeholder involvement, and to ensure that Third Party Audit programs reinforce requirements for smelter and refiners to be aware of and follow-up on the resolution of incidents. Accordingly, Apple has taken initial steps to address identified deficiencies and incidents by contributing to Partnership Africa Canada to develop responsible gold traceability programs and channels for legally traded artisanal gold. Additionally, Apple has funded the first comprehensive due diligence training that brought together more than 60 DRC government and civil society actors from multiple territories to deepen their understanding of the incident reporting process. Apple also has funded the development of training materials to clarify the iTSCi incident reporting process.

To better understand how due diligence programs impact changes on the ground, Apple and its consultants also reviewed various program reports, including those from relevant government and non-governmental reporting organizations. Apple found that the lack of consistency in data across programs hampered the opportunity to assess the impacts of in-region initiatives. As a result, Apple is working with partners to learn how better data coordination may be achieved, and intends to take further steps to develop comparable metrics that can assess the impact of responsible sourcing initiatives in the Region.

Recognizing that creating sustainable change on the ground in the Region will take the efforts of many actors, Apple has provided financial support for several in-region programs. Apple intends to continue working collaboratively to push those systems designed to ensure smelters and refiners are sourcing responsibly to become consistently accurate and secure and yield the high standards of transparency and accountability that Apple demands. The broader change that needs to occur will only be possible with continued strategic collaboration across law enforcement, governments, non-governmental organizations and multiple industries.

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Risk Mitigation and Future Due Diligence Measures

Apple designed its due diligence measures to conform to OECD Due Diligence Guidance. Apple’s supply chain mapping and due diligence activities have highlighted specific improvements Apple intends to pursue not only to advance its own due diligence measures but also to mitigate and address systemic risks:

Determination

Based on the information provided by Apple’s suppliers and its own due diligence efforts through December 31, 2015 (see Annex I), Apple believes that the facilities that may have been used to process the Subject Minerals in Apple’s products include the smelters and refiners listed in Annex II below.

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Through the smelter and refiner identification and validation process, Apple has identified a total of 284 smelters and refiners as potential sources of Subject Minerals that, initially, were believed to have been in its supply chain at some point during 2015 (see Annex II). Of this group, 242 smelters and refiners were determined to be in Apple’s supply chain as of December 31, 2015. Of the remaining 42, Apple determined that seven smelters and refiners were found to be inoperative during 2015 and the remaining 35 reported smelters and refiners were actively removed from Apple’s supply chain at the request of Apple. Of these 35 removed smelters and refiners, 24 had been reported in previous Apple Conflict Minerals Reports and the remaining were newly identified and reported to Apple in 2015. While mineral stock from removed smelters and refiners may remain in Apple’s supply chain, Apple has no reason to believe that any of the foregoing 42 smelters and refiners were sourcing minerals from the Region.

Apple’s reasonable country of origin inquiry is based on Third Party Audit information and, to the extent that country of origin information has not been audited, additional information collected by it and others. To the extent reasonably possible, Apple has documented the country of origin of identified smelters and refiners based on information received through the CFSP, surveys of smelters and refiners, and/or third party reviews of publicly available information. However, some country of origin information has not been audited by a third party because, among other reasons, applicable smelters and refiners have gone out of operation before completing a Third Party Audit, smelters and refiners have not gone through a Third Party Audit, or the Third Party Audit does not yet include reporting of country of origin information. Therefore, Apple does not have sufficient information to conclusively determine the countries of origin of the Subject Minerals in all of its products; however, based on the information provided by Apple’s suppliers, smelters, and refiners, as well as from the CFSP and other sources, Apple believes that the Subject Minerals contained in its products originate from the countries listed in Annex III below, as well as from recycled and scrap sources.

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Of all of the smelters and refiners of Subject Minerals identified for 2015, Apple found no reasonable basis for concluding that any such smelter or refiner sourced Subject Minerals that directly or indirectly finance or benefit armed groups. The 29 smelters and refiners known to be sourcing from the DRC or an adjoining country all completed a Third Party Audit.* Of these 29 smelters and refiners, 23 have undergone a Third Party Audit requiring the review of the smelter or refiner’s traceability of Subject Minerals and the smelter or refiner’s country of origin information in addition to a validation of its due diligence systems. The remaining six were audited with respect to their due diligence systems and Apple expects them, as part of their next Third Party Audit, to have their country of origin information audited.

About this Report

This report has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 to December 31, 2015.

This report relates to the process undertaken for Apple products that were manufactured, or contracted to be manufactured, during 2015 and that contain Subject Minerals.

These products are Apple’s iPhone®, iPad®, Mac®, iPod®, Apple TV®, Apple Watch®, Beats® products, displays, and Apple accessories. Third party products that Apple retails but that it does not manufacture or contract to manufacture are outside of the scope of this report. The smelters and refiners identified in this report include smelters and refiners producing service or spare parts contract manufactured in 2015 for use in connection with the subsequent service of previously sold products, including products serviced in subsequent years using those parts. This report does not include smelters and/or refiners of tantalum, tin, tungsten, and gold included in end-of-life service parts for products that Apple no longer manufactures or contracts to manufacture.

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This report’s use of the terms “smelters” and “refiners” refers to the facilities processing primary Subject Minerals to retail purity. Apple suppliers have in some cases reported smelters and refiners that Apple believes are not operational or may have been misidentified as smelters and refiners. As a result, Apple continues to conduct independent research on smelters and refiners and to work with suppliers throughout its supply chain to re-validate, improve, and refine their reported information, taking into account supply chain fluctuations and other changes in status or scope and relationships over time. “Identified” smelters and refiners are those that (i) have been reported in supplier surveys, (ii) Apple believes are currently operational, were operational at some point during the applicable year or, while inoperative, were capable of re-engagement with minimal delay or effort, and (iii) otherwise meet the definition of a smelter or refiner. As part of its reasonable country of origin inquiry, Apple concluded that several processing facilities are using only recycled material. Facilities that process only secondary materials (i.e., scrap or recycled material) are excluded from the scope of this report, except where the entity has undergone a Third Party Audit and is otherwise identified in Annex II.

Participating smelters and refiners are those that have agreed to participate in, or have been found compliant with, the CFSP or cross-recognized independent third party conflict minerals audit programs confirming their conflict mineral sourcing practices. Such programs may also include audits of traceability requirements, conformity with OECD Due Diligence Guidance, management systems, and/or risk assessments. Cross-recognized independent third party conflict minerals audit programs include the LBMA’s Responsible Gold Program and the Responsible Jewellery Council Chain-of-Custody Certification. Throughout this report the audits by these programs are included in references to “Third Party Audit” programs.

This report includes forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties. Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward-looking statements can also be identified by words such as “expects,” “plans,” “intends,” “will,” “may,” and similar terms. Forward-looking statements are not guarantees of future performance. Apple assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law. Subsequent events may affect Apple’s future determinations under Rule 13p-1.

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ANNEX I

Design of Due Diligence

Apple designed its due diligence measures to conform to the OECD Due Diligence Guidance.

2015 Due Diligence Measures Performed:

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ANNEX II

Smelters And Refiners Reported In Apple’s Supply Chain As Of December 31, 2015.

Smelters or refiners that complete a Third Party Audit will be approved for Apple’s supply chain; otherwise, such smelters and refiners will be removed from Apple’s supply chain.

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Apple Inc. | 2015 Conflict Minerals Report | A-3

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Apple Inc. | 2015 Conflict Minerals Report | A-6

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Smelters And Refiners Identified In Apple’s Supply Chain During 2015 But Subsequently Determined to Be Inoperative Or Removed Prior to December 31, 2015.

Some smelters or refiners that are no longer reported in Apple’s supply chain may currently be participating in a Third Party Audit.

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Note: Smelter and refiner facility names originate from information provided by the LBMA and/or the CFSP.

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ANNEX III

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