Exhibit 1.01

 

 

 

Tapestry, Inc.

Conflict Minerals Report

For the Calendar Year Ended December 31, 2025

 

 

This report has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”) for the reporting period from January 1 to December 31, 2025, and relates to the process undertaken for Tapestry products that were contracted to be manufactured during calendar 2025 and that contain gold, tantalum, tin and/or tungsten (collectively the “3TG minerals”) that is necessary to the functionality or production of the products.

 

 

Tapestry is a global house of iconic accessories and lifestyle brands consisting of Coach and Kate Spade. Tapestry completed the sale of the Stuart Weitzman business on August 4, 2025. Because Stuart Weitzman was a subsidiary of Tapestry for a portion of the 2025 reporting period, partial data and information from Stuart Weitzman suppliers are included in this report. The information maintained or referenced on Tapestry’s or any of its brands’ websites is not incorporated by reference into this Conflict Minerals Report or the Form SD, of which it is a part, and should not be considered part of this Conflict Minerals Report or the Form SD.

 

Tapestry determined that it is subject to the requirements of the Conflict Minerals Rule because of the degree of influence that it exercises over the design, materials, and components of some of its products that contain necessary 3TG minerals. None of Tapestry’s brands directly manufacture products but instead “contract to manufacture,” and are far removed from the sources of ore from which 3TG metals are produced and the smelters or refiners (“SORs”) that process those ores. The efforts undertaken to identify the origin of those ores reflect Tapestry’s position in the supply chain.

 

The products covered by this Report include the following, although not all of Tapestry’s products in each of these categories are in-scope for purposes of its compliance:

 

 

Tapestry’s in-scope products for 2025 contain tin, gold, tungsten and tantalum. However, each in-scope product did not contain all four of the 3TG minerals.

 

For 2025, Tapestry identified 256 facilities supplying potentially in-scope products.

 

 

Tapestry has a policy for the supply chain of 3TG minerals (the “Conflict Minerals Policy”).

 

Consistent with its belief in the dignity of, and respect for, individuals, as demonstrated in its policies on labor practices, Tapestry is concerned with the potential humanitarian abuses involved in the mining of these minerals and subsequent financing of armed conflict, and takes its obligations under the Conflict Minerals Rule seriously. As such, Tapestry strives to deliver products to its consumers manufactured in an ethical way consistent with its humanitarian beliefs and to be compliant with the laws in the countries in which it operates. Tapestry does not ban the procurement of 3TG minerals from the Democratic Republic of the Congo (the “DRC”) and its adjoining countries, but seeks to source from responsible conflict-free sources in the region.

 

To further responsible 3TG minerals sourcing, Tapestry has adopted the following practices, in addition to the other practices discussed in this Conflict Minerals Report:

 

 

Tapestry expects its suppliers to adhere to the following guidelines when procuring 3TG minerals for use in Tapestry products:

 

 

In order to achieve these objectives, Tapestry developed a process consistent with the OECD Guidance due diligence framework for 3TG minerals, as further discussed below.

 

 

Following a risk assessment to scope where 3TG minerals may be found in its products, Tapestry conducted a “reasonable country of origin inquiry” (“RCOI”) within the meaning of the Conflict Minerals Rule. The RCOI was undertaken with respect to products sourced directly by, and manufactured for, Tapestry in 2025. Tapestry and its brands do not directly manufacture products, but instead contract with suppliers to manufacture products that may contain 3TG minerals necessary to their functionality or production. Tapestry then identified the suppliers who supplied the products. The survey was administered to those suppliers via a web-based portal, with manual and automated follow-up communications to improve survey response rate, and to complement Tapestry’s internal management process.

 

Based on its RCOI, Tapestry concluded that, of the 354 SORs identified by suppliers, 109 sourced 3TG minerals exclusively from outside of the DRC and its adjoining countries and/or from recycled or scrap sources and 90 may have sourced in whole or in part from the DRC and its adjoining countries. Tapestry does not have sourcing information for the remaining SORs, which are not listed as Conformant by the Responsible Mineral Initiative (the “RMI”). Tapestry’s conclusions concerning 3TG mineral origin are based on information derived from supplier responses and Tapestry’s own analysis. 214 (60.4%) of the identified SORs were listed as Conformant by the RMI, 4 (1.1%) were listed as Active and 136 (38.4%) were listed as Known (as defined later in this Conflict Minerals Report), in each case as of May 1, 2026. More detailed SOR and country of origin information is provided under “Item VI. Identified Smelters and Refiners” and “Item VII. Country of Origin Information” below, respectively.

 

Tapestry received survey responses from Tapestry’s suppliers, which were reviewed for plausibility, consistency and gaps. Tapestry requested suppliers to provide corrections and clarification where needed.

 

 

Based on the results of Tapestry’s RCOI, Tapestry exercised due diligence for 2025. These due diligence efforts are discussed below.

 

Design of Due Diligence

 

Tapestry designed its due diligence measures to conform with the OECD Guidance (Third Edition), which includes the related supplements on tin, tantalum and tungsten and gold. Specifically, due to its classification as a “downstream” company within the supply chain, Tapestry’s due diligence practices were tailored accordingly based upon the OECD Guidance.

 

Due Diligence Measures Performed

 

Based upon the OECD Guidance, Tapestry’s due diligence measures included the following elements. These are not all of the discrete elements and tasks that are part of Tapestry’s compliance program.

 

 

 

 

 

 

 

The table below describes the SORs that may have processed the necessary 3TG minerals in Tapestry’s in-scope products. The table is based on information provided by Tapestry’s suppliers and its own due diligence efforts within its supply chain for 2025.

 

Tapestry generally received data from its suppliers on a company-level basis, meaning that the suppliers reported 3TG minerals contained in all of their products, not just those in the products that they sold to Tapestry. Accordingly, not all included SORs may have processed the necessary 3TG minerals contained in Tapestry’s in-scope products. Furthermore, those SORs may not be all of the SORs in Tapestry’s supply chain, since some suppliers indicated that they did not identify all of the SORs used to process the necessary 3TG minerals content in the products covered by their CMRTs.

 

The table makes use of the terms “Conformant,” “Active” and “Known.” These terms have the following meanings:

 

“Conformant” means that the SOR has successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment. Included SORs were not necessarily Conformant for all or part of 2025 and may not continue to be Conformant for any future period.

 

“Active” means that the SOR has committed to undergo an RMAP assessment, completed the relevant documents and scheduled the on-site assessment. These SORs may be in the pre-assessment, assessment, or corrective-action phases of the assessment.

 

“Known” means that the SOR was not Conformant or Active but is listed on the CMRT Smelter Look-up tab. The status information reflected in this table is current as of May 1, 2026.

 

 

Because certain SORs process more than one 3TG mineral, the totals by mineral category exceed the number of unique SORs identified.  Tapestry suppliers disclosed 354 unique SORs

 

 

The countries of origin of the newly-mined 3TG minerals processed by the Conformant SORs in the table above may have included the countries listed below. Country of origin information has been provided in the Reasonable Country of Origin Inquiry (RCOI) data provided by the Responsible Minerals Initiative (RMI). The 3TG minerals in the Company’s in-scope products may not have originated in all these countries. Additionally, 3TG minerals in the Company’s in-scope products may have originated in countries not listed below.

 

 

 

Alternatively, or in addition, some of the identified SORs may have been sourced from recycled or scrap sources.

 

Tapestry endeavored to determine the mine location of origin of the necessary 3TG minerals contained in its in-scope products by requesting that the suppliers provide it with a completed CMRT and through the other procedures followed by Tapestry that are described in this Conflict Minerals Report.

 

 

Tapestry intends to continue to improve upon its supply chain due diligence via the following measures:

 

 

All of these steps are in addition to the other steps that Tapestry took with respect to its 2025 compliance, which it intends to continue to take for 2026 to the extent applicable.

 

This document contains forward-looking statements based on management's current expectations. These statements can be identified by the use of forward-looking terminology such as “may,” “will,” “should,” “expect,” “intend,” “become,” “future,” “continue,” “strive,” “seek” or comparable terms. Future results may differ materially from management's current expectations, based upon risks and uncertainties such as (1) the continued implementation and maintenance of satisfactory traceability and other compliance measures by Tapestry’s direct and indirect suppliers, (2) whether SORs and other market participants responsibly source 3TG minerals, (3) political, regulatory and economic developments within the DRC and its adjoining countries, the United States or elsewhere, and (4) changes in Tapestry’s supplier base. Undue reliance should not be placed on these forward-looking statements, which speak only as of the date of the filing of this document. Tapestry does not intend, and undertakes no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of the filing of this document to reflect the occurrence of unanticipated events. Please refer to the Company’s latest Annual Report on Form 10-K and its other filings with the SEC for a complete list of risks and important factors. The Company assumes no obligation to revise or update any such forward-looking statements for any reason, except as required by law.