Exhibit 1.01
Conflict Minerals Report of Ambarella, Inc.
in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934
This Conflict Minerals Report of Ambarella, Inc. (“Ambarella,” “we,” “us,” “our,” or the “Company”) is filed with the Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 for calendar year 2025. Rule 13p-1 implements the conflict minerals reporting and disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rule applies to SEC registrants whose products contain conflict minerals necessary to the functionality or production of those products. For purposes of this report, “conflict minerals” refers to cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”).
The statements in this report are based on the activities undertaken and information available as of the date of this filing.
| 1. | Company Overview; Covered Products |
Ambarella was incorporated in the Cayman Islands in 2004. We design and develop low-power system-on-a-chip, or SoC, semiconductors providing powerful artificial intelligence, or AI, processing, advanced image signal processing and high-resolution video compression. Ambarella’s SoC products are used in a wide variety of edge AI and human vision applications, including video security, advanced driver assistance systems (ADAS), electronic mirror, drive recorder, driver/cabin monitoring, autonomous driving, consumer cameras, and robotics applications. We sell our SoC solutions to original equipment manufacturers (OEMs) as well as to design manufacturers (ODMs) and other suppliers that support OEMs. During the 2025 calendar year, we sub-contracted to manufacture our SoC products containing 3TG minerals and the use of these minerals is necessary to the functionality or production of our SoC products.
| 2. | Supply Chain Overview |
We operate our business based on a fabless semiconductor model. Accordingly, we rely on third parties, primarily located in Asia, for substantially all of our manufacturing operations, including wafer fabrication, assembly and testing of our SoC products. There are multiple tiers between our company and the mines that produce conflict minerals used in our products. Accordingly, we rely on our direct suppliers to provide information on the origin of the conflict minerals that are included in our products. All of our suppliers of conflict minerals have adopted a conflict minerals policy and due diligence framework based on 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.
| 3. | Due Diligence Program |
Our due diligence processes and efforts have been developed in conjunction with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for 3TG minerals. We designed our due diligence process to conform in all material respects with these guidelines. Our due diligence measures include:
| • | Identification of the components in Ambarella products that contain conflict minerals, and the suppliers through which those components are sourced. |
| • | Conducting a supply-chain survey with direct suppliers of materials containing conflict minerals using the using the standard Conflict Minerals Reporting Template (CMRT) from the Responsible Minerals Initiative (RMI). |
| • | Communicating with any direct suppliers that did not timely respond to surveys or provide complete responses. |
| • | Comparing the smelters and refiners identified in the supply-chain survey against the list of smelter facilities which have been identified as compliant with RMI’s Responsible Minerals Assurance Protocol. |
Our conflict minerals project team responsible for conducting the due diligence is comprised of employees in our operations department, which is responsible for selecting and retaining relationships with our third-party vendors. Our due diligence process is overseen by executives from our operations and legal functions.
We have retained all relevant documentation from our reasonable due diligence measures to ensure the retention of relevant documentation.
| 4. | Reasonable Country of Origin Inquiry (RCOI) and RCOI Results |
We conducted a survey of our active suppliers using a template from the Responsible Minerals Initiative (RMI), known as the Conflict Minerals Reporting Template. The template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free sourcing policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in their products, as well as due diligence undertaken by the supplier. We believe this template is widely used by companies in our industry for the purpose of conducting due diligence related to conflict minerals.
During the process of our review, we identified our direct suppliers who fell within the scope of our RCOI. We sent the Conflict Minerals Reporting Template to these direct suppliers and received responses from each of them. Each of our direct suppliers indicated that they had received data or information about the origin of 3TG minerals from all of their suppliers. Each of our direct suppliers also indicated that they reported all of the applicable smelter and refinery information in their response to our inquiry.
Based on our due diligence activities, our suppliers identified a total of 91 smelters and refiners from which 3TG minerals may have been sourced. All of our suppliers indicated that some of the smelters they use do source some 3TG minerals from covered countries. Of the smelters and refiners identified by our suppliers as sourcing 3TG minerals from covered countries in the calendar year ended December 31, 2025, all have been certified as compliant with the Responsible Minerals Assurance Protocol (RMAP). The responses received from our suppliers provided data at the supplier company level relative to the supplier, rather than at a level directly relating to a Covered Product that the supplier supplies to us, or were otherwise unable to specify the smelters or refiners used for Covered Products supplied to us. We were therefore unable to validate which of these smelters or refiners are actually in our supply chain.
| 5. | Audit of Supply Chain Due Diligence |
As a fabless semiconductor company, we do not have a direct relationship with 3TG smelters and refiners and did not perform direct audits of the entities in our supply chain. As a downstream purchaser of materials and components that contain conflict minerals, our due diligence measures cannot provide absolute assurance regarding the source and chain of custody of the conflict minerals in our Covered Products. Instead, we rely on industry third-party audit programs, including RMI’s Responsible Minerals Assurance Process (RMAP).
| 6. | Facilities Used to Process Conflict Materials |
Based on the supplier information described above, we believe that, to the best of our knowledge, the smelters and refiners listed in the table below may have been used to process the 3TG contained in our products manufactured in the calendar year ended December 31, 2025. Because supplier responses were provided at the company level rather than for specific Covered Products supplied to us, we were unable to determine whether any particular smelter or refiner reported by a supplier was actually in our supply chain.
| METAL |
NAME OF SMELTER OR REFINERY |
LOCATION |
CID# | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | |||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | |||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 | |||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002542 | |||
| Tungsten | Masan High-Tech Materials | VIET NAM | CID002543 | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | |||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | |||
| Tin | Alpha Assembly Solutions, Inc. | UNITED STATES OF AMERICA | CID000292 | |||
| Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 | |||
| Tin | Dowa | JAPAN | CID000402 | |||
| Tin | Fenix Metals | POLAND | CID000468 | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | |||
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | |||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 | |||
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 | |||
| Tin | Minsur | PERU | CID001182 | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | |||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 | |||
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | |||
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 | |||
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 | |||
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 | |||
| Tin | Thaisarco | THAILAND | CID001898 | |||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 | |||
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | CID002180 | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | |||
| Tin | CV Ayi Jaya | INDONESIA | CID002570 | |||
| Tin | Super Ligas | BRAZIL | CID002576 | |||
| Tin | PT Rajehan Ariq | INDONESIA | CID002593 | |||
| Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 | |||
| Tin | Aurubis Beerse | BELGIUM | CID002773 | |||
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 | |||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 | |||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 | |||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 | |||
| Tin | Luna Smelter, Ltd. | RWANDA | CID003387 | |||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 | |||
| Tin | CRM Synergies | SPAIN | CID003524 | |||
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | CID003868 | |||
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA | CID004434 | |||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | |||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | CID000616 | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | |||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 | |||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 | |||
| Tantalum | NPM Silmet AS | ESTONIA | CID001200 | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | |||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | |||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | |||
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | CID002544 | |||
| Tantalum | TANIOBIS GmbH | GERMANY | CID002545 | |||
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | CID002548 | |||
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | CID002549 | |||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002550 | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | |||
| Gold | Asahi Metalfine, Inc. | JAPAN | CID000082 | |||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | |||
| Gold | JX Advanced Metals Corp. | JAPAN | CID000937 | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | |||
| Gold | MKS PAMP SA | SWITZERLAND | CID001352 | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | |||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 | |||