Conflict Minerals Report

Benchmark Electronics, Inc. (“Benchmark” or “Company”) has included this Conflict Minerals Report (“CMR”) as an exhibit to its Form SD as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”), including:

(collectively the “Interim Guidance”).

In Nat'l Ass'n of Mfrs. v. SEC1, the U.S. Court of Appeals for the District of Columbia Circuit held that requiring companies to describe their products as having "not been found to be 'DRC conflict free'" violates the First Amendment. On April 3, 2017, the U.S. District Court for the District of Columbia entered final judgment setting aside those portions of Rule 13p-1 and Form SD, and remanding to the Commission.

In the Updated Statement, the Division of Corporation Finance stated that, in light of the uncertainty regarding the rule and related judicial and administrative developments, it would not recommend enforcement action against companies that comply only with Items 1.01(a) and (b) of Form SD, including companies that would otherwise be subject to Item 1.01(c). Items 1.01(a) and (b) require, among other things, a brief description of the issuer's reasonable country of origin inquiry and its results. Item 1.01(c) requires a company to conduct due diligence, file a Conflict Minerals Report as an exhibit, and, in certain circumstances, obtain an independent private sector audit. Notwithstanding this relief, the Company voluntarily provides this CMR, including the due diligence information described herein, to promote supply chain transparency and responsible sourcing of conflict minerals.

Unless otherwise defined herein, terms used in this Report have the same meaning found in the Conflict Minerals Rule, the Final Release and the Interim Guidance. The date of filing of this CMR is May 29, 2026.

References in this CMR to Benchmark, the Company or use of the words “we”, “our” and “us” include Benchmark’s subsidiaries unless otherwise noted. As used herein, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin.

Forward-Looking Statements

This document contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended and Section 21E of the Securities Exchange Act of 1934, as amended. These forward-looking statements are identified as any statement that does not relate strictly to historical or current facts and may include words such as “anticipate,” “believe,” “intend,” “plan,” “project,” “forecast,” “strategy,” “position,” “continue,” “estimate,” “expect,” “may,” “will,” “could,” “predict,” and similar expressions of the negative or other variations thereof. Although we believe these statements are based upon and derived from reasonable assumptions, they involve risks, uncertainties and assumptions that are beyond our ability to control or predict, relating to operations, markets and the business environment generally, including but not limited to, (1) whether our direct and indirect suppliers implement appropriate traceability and other compliance measures on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, and (3) political and regulatory developments, whether in the Democratic Republic of the Congo, its adjoining countries, the United States or elsewhere. Should one or more of these risks or uncertainties materialize, or should underlying assumptions prove incorrect, actual outcomes, including the future results of our operations, may vary materially from those indicated. Undue reliance

should not be placed on any forward-looking statements. Forward-looking statements are not guarantees of performance. All forward-looking statements included in this document are based upon information available to us as of the date of this document, and we assume no obligation to update them.

Applicability of the Conflict Minerals Rule to Our Company

The Company is a Texas corporation that provides design engineering and advanced manufacturing services that include both electronic manufacturing services (EMS) and precision metal machining (PMM) services. We support customers throughout their product lifecycle starting from initial product concept through volume production, including the ability to manage direct order fulfillment and provide aftermarket services. We are a trusted partner to our European and US based national and multi-national original equipment manufacturers (OEMs). Served markets include: advanced computing and communication (AC&C), aerospace and defense (A&D), industrial, medical, and semiconductor capital equipment (semi-cap). The Company has manufacturing operations located in the United States and Mexico (the Americas), Asia and Europe.

We contract to manufacture products on behalf of our customers containing necessary Conflict Minerals. We primarily purchase component parts used in our manufacturing services through direct suppliers or authorized distributors from around the world. These component parts are typically finished goods or manufactured materials. We generally do not procure raw ore or unrefined Conflict Minerals, and therefore we do not have direct relationships with mines or smelters of Conflict Minerals found in our customers’ products. These mines or smelters are several distribution levels removed from us in the supply chain; therefore, we must rely on the many direct suppliers, supply-chain intermediaries and industry initiatives for information on these mines or smelters. Further, our OEM customers typically specify the components and materials required to manufacture their products, as well as the particular component and material suppliers. As a result, we typically have little or no control over the selection of these components, materials and suppliers. In these cases, we must rely on our customers and their selected suppliers for Conflict Minerals information.

This CMR relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were contracted to be manufactured by the Company; and (iii) for which the manufacture was completed during calendar year 2025. These products, which are referred to in this CMR collectively as the “Covered Products,” primarily consist of printed circuit board assemblies (“PCBAs”) using both traditional surface mount technologies (“SMT”) and microelectronics, subsystem assembly, system builds and integration. System builds and integration often involve building a finished assembly that includes PCBAs, complex subsystem assemblies, mechatronics, displays, optics, and other components. These final products are predominantly shipped to our customers for integration into higher level assemblies and/or resale to their ultimate customers. A small portion of these final products may be configured to order and delivered directly to our customers’ end-customer across all the industries we serve. Manufacturing services also include PMM services comprised of precision metal machining, advanced metal joining, assembly and functional testing primarily for the semi-cap market (serving semiconductor capital equipment customers) and A&D markets.

Conflict Minerals Policy

Benchmark’s Conflict Minerals Policy is as follows:

“Conflict Minerals” refers to certain minerals commonly referred to as “3TG” (Tin, Tantalum, Tungsten, and Gold) or other derivatives. The US Congress voiced concerns that the exploitation and trade of Conflict Minerals by armed groups helped to finance conflict in the Democratic Republic of the Congo (“DRC”) and adjoining countries and contributed to an emergency humanitarian crisis. To address these concerns, the United States Congress enacted Section 1502(b) of the Dodd-Frank Financial Reform Bill and Consumer Protection Act in July 2010, and in 2012 the U.S. Securities and Exchange Commission adopted “Rule 13p-1” under the Securities Exchange Act (collectively the “Conflict Minerals Law”). The Conflict Minerals Law identifies the DRC and adjoining countries as “Covered Countries,” and further requires US public companies to disclose annually certain information concerning Conflict Minerals contained in products they manufacture or contract to manufacture, to the extent that Conflict Minerals are necessary to the functionality or production of the products.

Benchmark Electronics, Inc. (“Benchmark”) supports the Conflict Minerals Law and efforts to avoid sourcing Conflict Minerals that directly or indirectly finance armed groups in the DRC and in adjoining countries. Consistent with the Conflict Minerals Law and the OECD Due Diligence Guidance concerning Conflict Minerals, Benchmark has adopted the Responsible Minerals Initiative (“RMI”) Due Diligence reporting process and seeks to obtain Conflict Minerals content declarations from its suppliers on the Conflict Minerals Reporting Template (“CMRT”) published by the RMI, thereby promoting supply chain transparency. Benchmark does not directly source 3TG from mines, smelters, or refiners and, in most cases, is several tiers removed from these supply chain participants. Benchmark therefore expects our suppliers to:

Any suppliers not willing to comply with these requirements shall be reviewed by global procurement with regard to future business and sourcing decisions. This Conflict Minerals Policy encourages suppliers to respect and protect human rights throughout the world. A copy of this Conflict Minerals Policy is available on our public website.

Reasonable Country of Origin Inquiry

For products manufactured during the reporting year, we performed a Reasonable Country of Origin Inquiry (“RCOI”) on our necessary Conflict Minerals. This RCOI was reasonably designed to determine whether any of such Conflict Minerals originated in the Covered Countries and whether any of such Conflict Minerals may be from recycled or scrap sources.

Our RCOI utilized a risk-based approach to solicit Conflict Minerals information from 610 suppliers, targeting 90% of our global component and materials procurement expenditures during the reporting year. We requested Conflict Minerals information from these suppliers via the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”). We reviewed and analyzed all CMRTs received, including some with missing or incomplete information, errors, or containing inaccuracies or implausible information. We made multiple contact attempts with non-responsive suppliers, as well as requests for revised responses where appropriate. We ultimately received 437 responses, which is approximately 72% of our targeted supplier group (representing approximately 72% of our reporting year component and materials procurement expenditures). These suppliers provide “company-level” CMRT responses that include Conflict Minerals information for all supplier products sold during the reporting year, even though we purchased only a limited subset of such supplier’s products. We also utilized a third-party software provider to assist us in the data collection effort, review, verification and follow-up contacts.

As a result of the Company’s RCOI, 69% of responding suppliers reported that Conflict Minerals were either not present, not sourced from Covered Countries, sourced from smelters or refiners certified by RMI or listed by other organizations as conflict free, or sourced from smelters or refiners that were not deemed by the RMI to be at a high risk of supporting armed groups or human rights abuses in the Covered Countries. Although a number of responding suppliers dealt with non-certified smelters known to source Conflict Minerals from the Covered Countries, we cannot

determine with certainty whether such Conflict Minerals were actually incorporated into our products or whether they directly or indirectly financed or benefitted armed groups in the Covered Countries.

Based on our RCOI, we determined that 271 of the suppliers sourced only from outside of the DRC and its adjoining countries or from recycled or scrap sources or RMI-certified conflict free smelters. Our determination was based on information provided by the collected supplier CMRTs, by the RMI to its members or by our software provider.

In addition to the RCOI, the Company also exercised due diligence on the source and chain of custody of its necessary Conflict Minerals where the Company, based on its RCOI, had reason to believe that such Conflict Minerals may have originated in the Covered Countries and may not be from recycled or scrap sources.

Due Diligence Program Design

Design Framework

The Company’s due diligence measures were designed to conform to the framework in the Organization for Economic Cooperation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016) and accompanying Supplements (the “OECD Guidance”).

Five-Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain

The OECD Guidance identifies five due diligence steps:

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 Smelter/Refiner’s Due Diligence Practices

Step 5: Report Annually on Supply Chain Due Diligence

It is important to note that the OECD Guidance was written for both “upstream” (the mineral supply chain from the mine to smelters/refiners) and “downstream” (minerals supply chain from smelters/refiners to retailers) companies in the supply chain. As Benchmark is a downstream company in the supply chain, its due diligence practices are tailored accordingly. The headings below conform to the headings used in the OECD Guidance for each of the five steps.

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 Smelter/Refiner’s Due Diligence Practices

In connection with our due diligence, we utilize and rely on information made available by the RMI concerning independent third-party audits of smelters and refiners to assess smelter and refiner due diligence and to determine whether the smelter or refiner is Conformant. We believe that our utilization of RMI data is the most effective method of satisfying this step of the OECD Guidance.

Step 5: Report Annually on Supply Chain Due Diligence

We report on our supply chain due diligence through our Form SD filings, and the related CMRs, as well as by posting that information on our website.