UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

TE CONNECTIVITY LTD.

(Exact name of registrant as specified in its charter)

Mühlenstrasse 26
CH-8200 Schaffhausen
Switzerland
(Address of principal executive offices, including zip code)

John S. Jenkins, Jr.

610-893-9341

(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.

Section 1 — Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Form SD of TE Connectivity Ltd. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2021 to December 31, 2021.

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available on our website at http://investors.te.com/financial-reports/sec-filings/default.aspx. The website and the information accessible through it are not incorporated into this Form SD.

Item 1.02 Exhibit

As specified in Section 3, Item 3.01 of this Form SD, the Company is hereby filing this Conflict Minerals Report as Exhibit 1.01 to this report.

Section 2 — Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not Applicable

Section 3 — Exhibits

Item 3.01 Exhibits

The following exhibit is filed as part of this 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.

EXHIBIT INDEX

Exhibit 1.01

TE Connectivity Ltd.
Conflict Minerals Report

For The Calendar-Year Reporting Period Ended December 31, 2021

1. Overview

This Conflict Minerals Report has been prepared by TE Connectivity Ltd. (herein referred to as TE, the Company, we, us, or our) pursuant to Rule 13p-1 (the Rule) promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended (Exchange Act). Rule 13p-1 and Form Specialized Disclosure (SD) were adopted by the Securities and Exchange Commission (SEC) to implement disclosure and reporting requirements related to “conflict minerals,” as directed by Congress in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) which, among other things, added Section 13(p) to the Exchange Act. Specifically, Section 13(p), the Rule and Form SD together impose certain reporting obligations on those SEC registrants, like TE, whose manufactured products contain so-called “conflict minerals” that are necessary to the functionality or production of their products. The term “conflict minerals” is defined to mean cassiterite, columbite-tantalite (coltan), gold, wolframite, including their derivatives, which are limited to tin, tantalum, and tungsten (together, 3TG). The term “Covered Countries” for purposes of Section 13(p) and the SEC rules thereunder, as well as this report and the accompanying Form SD, are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

In 2021, we designed and manufactured products to connect power, data, and signal in a broad array of industries, including automotive, energy, industrial, data communications, appliances, medical, and aerospace and defense. Our principal product families included terminals and connector systems and components, sensors, interventional medical components, relays, heat shrink tubing, cable, application tooling, and antennas.

For the 2021 reporting period, our reasonable country of origin inquiry (RCOI) survey process targeted a refined list of products deemed at risk for having any quantity of tin, tantalum, tungsten or gold that is “necessary to the functionality or production” of these products within the meaning of Section 13(p) and the SEC’s Rule and Form SD thereunder (necessary conflict minerals). We continue to refine our survey process as part of our continuous efforts to bring the TE program into greater alignment 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, Third Edition, and the supplements thereto relating to tin, tantalum, tungsten and gold (OECD Due Diligence Guidance). The OECD Due Diligence Guidance has been identified by the SEC as an appropriate internationally recognized framework for conducting the RCOI and due diligence relating to necessary conflict minerals called for by Section 13(p), the Rule and Form SD. TE supplier information gathering is facilitated by a third-party compliance information gathering service (TPCS) provided by a leading software-as-a-service solution.

Based on our due diligence, we are unable to determine with absolute assurance the origin of all the necessary conflict minerals in our products for the 2021 reporting period (January 1 through December 31, 2021), and therefore cannot exclude the possibility that some of these minerals may have originated in one or more of the Covered Countries (beyond those identified herein) and are not derived from recycled or scrap sources. Accordingly, under Section 13(p) and the Rule we have prepared and are filing this Conflict Minerals Report as an exhibit to our accompanying Form SD.

Conflict Minerals Policy

In 2021, we updated our conflict minerals policy to a responsible minerals and materials policy which is publicly available on our website at https://www.te.com/usa-en/utilities/product-compliance/conflict-minerals.html. Supplier adoption of TE’s due diligence standards is a standard requirement of doing business with TE.

Grievance Mechanism

We have well established processes to allow interested parties to contact us anonymously through our Office of the Ombudsman. Our Office of the Ombudsman can be contacted by email at directors@te.com, through the Internet at http://www.te.com/global-en/about-te/corporate-responsibility/governance/ombudsman.html or through mail at TE Connectivity, Office of the Ombudsman, 1050 Westlakes Drive, Berwyn, Pennsylvania 19312.

Supply Chain — Reasonable Country of Origin Inquiry

The products that we manufacture are complex, and we utilize thousands of components from many direct suppliers. We have relationships with a vast network of suppliers throughout the world and there are generally multiple tiers between the 3TG mines, the smelter or refinery processing facilities (SOR), and our direct suppliers. Therefore, we must rely on our direct suppliers to work with their upstream suppliers (suppliers that are closer to the SORs than TE in the supply chain) to provide us with accurate information about the origin of 3TG in the components and raw materials we purchase. We work to implement contracts with those direct suppliers to impose contract terms that compel these suppliers to support our due diligence efforts with respect to 3TG content.

Because of the complexity and size of our supply chain, we developed a risk-based approach to determining whether we had any necessary 3TG in our supply chain. Each year TE’s raw material and commodity code groupings are reviewed for the presence of potential 3TG. Once those products and materials are identified, internal subject matter experts and engineers analyze whether the 3TG in the products and materials are “necessary to the functionality or production” of such products within the meaning of the SEC’s rules. The end result of that analysis leads to the identification of supplier products in-scope for being potentially at risk of containing necessary conflict minerals. In 2021, a total of approximately 187,812 products (including components) were identified and subject to our RCOI survey.

Our 2021 supplier survey campaign requested that the identified suppliers provide information to us regarding 3TG and SORs using the Conflict Minerals Reporting Template (the “Template” or “CMRT”) developed by the Responsible Minerals Initiative (RMI). We accept company level CMRTs from suppliers, and, when necessary, seek additional information and/or product level CMRTs. As in past years, some supplier responses continued to note that the source of the conflict minerals could not be ascertained at the time of the supplier’s response.

Efforts to Determine Mine or Location of Origin

We have determined that requesting the identified suppliers to complete the Template, together with resources offered by our TPCS, represents our reasonable efforts to determine the mines or locations of countries of origin of necessary 3TG in our supply chain. We have reached this conclusion in part as a result of our membership in the RMI - an initiative of Responsible Business Alliance (RBA), formerly known as the Electronic Industry Citizenship Coalition (whose efforts focus on the location and the commitment of smelters and refineries to go through its Responsible Minerals Assurance Process (RMAP) or participate in a recognized certification program), our understanding of the OECD guidelines, and based on consultation with compliance and sustainability leaders in companies similarly situated to TE. TE relies on the RMI to help keep us abreast of developments in conflict minerals sourcing, the evolution and refinement of the CMRT form, and as a source of process improvements and informal benchmarking opportunities with other members.

Smelters or Refiners and Country of Origin of 3TG

We attach here a complete listing of those SORs ascertained, through TE’s supplier responses to the Template or upon further inquiry after a review of such responses, as providing necessary conflict minerals to TE for manufacture in 2021 (“Exhibit A”). As to country of origin, TE relies on third-party assessments and information available from such sources as RMI RMAP and the London Bullion Market Association, as well as our assessment of our supplier responses, and has concluded that TE, at this time, does not have sufficient information to conclusively determine the countries of origin of the 3TG in all of our products.

Description of Products Containing “Necessary” Conflict Minerals

We identified approximately 187,812 products supplied to TE potentially containing one or more 3TG minerals necessary to the functionality or production of our products; approximately 65,836 products were eliminated as out-of-scope pursuant to the RCOI process and approximately 66,681 products were deemed to contain necessary conflict minerals. These products fall into all of our product families, including but not limited to the following: terminals and connector systems and components, sensors, interventional medical components, relays, heat shrink tubing, wire and cable, application tooling, and antennas.

We were unable to ascertain the country of origin of 3TG minerals necessary to the functionality or production of the identified TE products and, as a consequence, proceeded to conduct the due diligence required under the OECD Due Diligence Guidance as applicable to downstream companies.

2. Due Diligence

Design of Due Diligence

Our due diligence measures have been designed to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance as applicable to downstream companies such as TE. As discussed above, the OECD Due Diligence Guidance has been identified by the SEC as an appropriate (and thus far, the only), internationally recognized due diligence framework for purposes of Section 13(p) of the Exchange Act and the Rule and Form SD thereunder.

Due Diligence Performed

MANAGEMENT SYSTEMS

We have adopted a responsible minerals and materials policy related to our sourcing of 3TG, as previously noted, and have developed a formalized Conflict Minerals Program for our suppliers which is governed by an official standard operating procedure (the Program). TE’s conflict minerals requirements are set forth in our Purchase Order terms, RFP documentation, supply contracts, and our supplier portal.

Internal Team

We have established a management system to support supply chain due diligence related to 3TG. Our management system includes an executive steering committee overseen by the Global Supply Chain Counsel, and a team of subject matter experts from functions such as supplier management (Global Procurement), engineering, finance, and law. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy as approved by our Law Department. As discussed further below, this team met regularly throughout 2021 and early 2022 to discuss the supply chain compliance process relating to conflict minerals.

Control Systems

Maintain Records

Program data is stored in accordance with our established corporate records schedule to ensure that relevant materials are preserved for appropriate periods.

Supplier Engagement

We have adopted a number of supplier outreach tools developed by our TPCS, including but not limited to training and program materials, all of which are designed to encourage suppliers to develop their own conflict minerals due diligence programs in accordance with the SEC’s conflict minerals regulatory requirements. We also maintain an electronic portal which directs suppliers to informational resources related to conflict minerals and our responsible minerals and materials policy.

IDENTIFY AND ASSESS RISK IN THE SUPPLY CHAIN

We survey direct suppliers of components or raw materials that were at risk for containing 3TG that were “necessary to the functionality or production” of our products described above. For 2021, TE relied on our TPCS to lead our supplier survey. For 2021, approximately 308 commodity codes and 187,812 associated TE products required RCOI survey activity due to their risk profiles.

Survey Responses For TE Products

We received a supplier response rate of 70.7% of the in-scope TE products surveyed. Despite our continued efforts in furtherance of surpassing our internal goal of a 75% supplier response rate, some incomplete supplier responses for TE’s 2021 conflict minerals campaign were provided using the Template, or a substantially similar variation thereof. We reviewed the responses against criteria developed by our internal team to determine which suppliers required further engagement. As in past years, the review criteria included assessing incomplete responses as well as inconsistencies within the data reported by those suppliers, and we have worked directly with suppliers to obtain additional engagement in an effort to secure improved responses. From the responses received, the following statistics were compiled:

DESIGN AND IMPLEMENT A STRATEGY TO RESPOND TO RISKS

CARRY OUT INDEPENDENT THIRD PARTY AUDIT OF SUPPLY CHAIN DUE DILIGENCE AT IDENTIFIED POINTS IN THE SUPPLY CHAIN

We do not typically have a direct relationship with 3TG smelters and refiners and therefore do not perform or direct audits of these entities. We support SOR audits conducted by independent third parties through our RMI membership, and have obtained the RMI list of “RMAP Conformant” smelters and refineries. We continue to examine how best to improve our upstream diligence efforts, possibly in tandem with our third-party conducted supplier social responsibility audits and future human rights/modern slavery due diligence.

REPORT ON SUPPLY CHAIN DUE DILIGENCE

This Conflict Minerals Report constitutes our annual report on our 3TG due diligence and is available on our website, along with the accompanying Form SD, at http://investors.te.com/financial-reports/sec-filings/default.aspx. In addition, this Report and the accompanying Form SD have been filed with the SEC and are publicly available on the SEC’s EDGAR website (https://www.sec.gov).

RESULTS OF DUE DILIGENCE

Notwithstanding continued improvements made to our RCOI and due diligence processes, we are unable to determine with absolute assurance the origin of all the necessary conflict minerals in our products for the 2021 reporting period (January 1 through December 31, 2021), and therefore cannot exclude the possibility that some of these minerals may have originated in one or more of the Covered Countries and are not derived from recycled or scrap sources.

3. Steps to be Taken in 2022 to Mitigate Risk

We intend to take the following steps as continuous improvement measures to our due diligence to be conducted in 2022, to further mitigate the risk that any necessary 3TG in our products finance or benefit armed groups in any of the Covered Countries:

Cautions Concerning Website Information and Forward-Looking Statements

Other than any documents expressly incorporated by reference in this Conflict Minerals Report and/or the accompanying Form SD, the information on any of our websites referred to in this report is not part of this report or any other document filed with the SEC, including but not limited to the accompanying Form SD.

Certain statements in this report may be “forward-looking” within the meaning of the U.S. Private Securities Litigation Reform Act of 1995. Words such as “expects,” “intends,” “plans,” “projects,” “believes,” “estimates,” “targets,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements addressing our future financial condition and operating results, the impact on our operations resulting from the COVID-19 pandemic, other information relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. Actual outcomes and results may differ materially from those anticipated in any of our forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.

Exhibit A – Smelters identified during the reporting period which, to the extent known, processed necessary conflict minerals in TE products for Calendar 2021 Reporting Period.