EX-1.01
SEAGATE TECHNOLOGY HOLDINGS PLC
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2025
INTRODUCTION
This Conflict Minerals Report (“Report”) of Seagate Technology Holdings public limited company (together with its subsidiaries, the “Company,” “Seagate,” “we,” “us” or “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”), for the reporting period from January 1 to December 31, 2025. (the “Reporting Period”). This Report is being filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD and is also posted on our website at http://www.seagate.com/sustainability/. Information contained on, or accessible through, our website is not a part of this Report.
The Rule imposes certain reporting obligations on the registrants of the Securities and Exchange Commission (the “SEC”) whose manufactured products contain tin, tantalum, tungsten, or gold (“3TG,” also defined by the Rule as “Conflict Minerals”). The Democratic Republic of the Congo (“DRC”) and its adjoining countries have extensive reserves of 3TG, some of which are illegally sourced and traded by armed groups who are responsible for serious human rights violations (“armed groups”). The purpose of the Rule is to encourage companies whose products contain 3TG to endeavor to source from suppliers who do not directly or indirectly support such armed groups through their purchasing decisions. The DRC and its adjoining countries, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia, are collectively referred to in this Report as the “Covered Countries.”
Seagate recognizes the need for universal human rights protections and is dedicated to maintaining a supply chain that supports the dignity and innate rights of all persons. Seagate prohibits the use in its products of 3TG whose supply chains contribute to human rights abuses. This includes a commitment to not use 3TG that directly or indirectly finance armed conflict or benefit armed groups. Importantly, Seagate discourages the practice of avoiding 3TG sourcing from the Covered Countries as a way of fulfilling this objective. Seagate firmly believes that the use of validated responsibly-sourced 3TG from Conflict Affected and High Risk Areas (“CAHRAs”), including the Covered Countries, is a socially responsible practice.
COMPANY AND PRODUCT OVERVIEW
Seagate is a leading provider of data storage technology and infrastructure solutions. Our principal business is the design, manufacture, and sale of hard disk drives, commonly referred to as disk drives, hard drives or HDDs. In addition to HDDs, we produce data storage systems that incorporate our high-capacity HDD products and offer solid state drives (“SSDs”). HDDs are devices that store digitally encoded data on rapidly rotating disks with magnetic surfaces. HDDs continue to be the primary medium of mass data storage due to their performance attributes, reliability, high capacities, superior quality and cost effectiveness. We present our products and services under two end markets: Data center and Edge Internet of Things (“Edge IoT”). Data center comprises the majority of our business and primarily includes high-capacity nearline products for mass capacity data storage and systems sold to cloud and enterprise customers, as well as cloud-based video and image applications. Edge IoT primarily includes consumer and client-centric markets along with network-attached storage, mission critical and SSD.
APPLICABILITY OF THE RULE
Seagate is partially vertically integrated. We design and produce the most critical components, including recording heads and media, and procure other components to assemble into finished data storage devices. We do not buy 3TG directly from mines. We also do not buy 3TG directly from smelters or refiners (“SORs”, or “SOR” in the singular), except for sputtering targets used in deposition equipment during the manufacturing process. Instead, we source parts, components, materials, and subassemblies that contain these metals. As such, Seagate occupies the supply chain position of a downstream company as defined by the Organization 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 (the “OECD Guidance”).
We are subject to the Rule because certain products that we manufacture or contract to be manufactured contain 3TG that are necessary to the functionality or production of our products.
Accordingly, we are required under the Rule to conduct a reasonable country of origin inquiry (“RCOI”) designed to determine in good faith whether any of the 3TG in our products either originated in the Covered Countries or came from recycled or scrap materials. We performed due diligence, as set forth in the “Due Diligence Program Design” section below, to conduct the RCOI.
COLLABORATION
Our focus on responsible sourcing began well in advance of the adoption of the Rule. Seagate has been a member of the Responsible Business Alliance (“RBA”) since 2004 and our employees have worked closely with this organization to improve the social, ethical, and environmental practices of our global supply chain. The RBA is the world’s largest industry coalition dedicated to corporate social responsibility in global supply chains. Through the RBA’s Responsible Minerals Initiative (“RMI”), we have worked, and continue to work, with other companies focusing on responsible 3TG sourcing.
Seagate firmly believes that maintaining an ethical supply chain takes a collective effort. Through our membership in the RMI, we gather and assess information on the origin of 3TG in our products. We rely on our direct suppliers to provide this information for the 3TG contained in the parts, components, materials, and subassemblies supplied to us.
Seagate recognizes that robust and lasting business relationships are critical in building resiliency and reducing risk in the supply chain. We strive to build strong connections with our suppliers, industry peers, and customers. We contribute to industry progress by participating in conferences, workgroups, and trainings to engage with these stakeholders.
DUE DILIGENCE PROGRAM DESIGN
The OECD Guidance established a five-step framework for due diligence as a basis for responsible supply chain management of 3TG from CAHRAs. We outline select elements of our due diligence program design below. To determine the source and chain of custody of 3TG necessary for the production of our products, we conducted due diligence on our supply chain using measures developed to ascertain whether the 3TG originated from the Covered Countries and, if so, whether the purchase of such 3TG directly or indirectly finances or benefits armed groups.
Due Diligence Design Framework
Our Conflict Minerals due diligence measures have been designed to conform to the OECD Guidance for 3TG for “downstream companies” (as defined in the OECD Guidance) in all material respects. Our due diligence measures addressed these five steps as set forth below.
1.Establish strong Company management systems:
a. We have implemented a Responsible Sourcing of Minerals Policy (the “Policy”). The Policy is available on our corporate website (available at https://www.seagate.com/content/dam/seagate/assets/sustainability/files/seagate-responsible-sourcing-policy-2026.pdf and has been communicated to our suppliers, employees and internal consultants, including via hosting a webinar for suppliers.
b. We have senior-level employees, who are members of cross-functional working groups within the Company, who are responsible for the management and continued implementation of our Conflict Minerals compliance strategy. This group includes representatives from our supply chain, sustainability, financial reporting and legal organizations.
c. Employees at manufacturing sites receive training on the RBA Code of Conduct requirements.
d. We utilize the Conflict Minerals Reporting Template (the “CMRT”) developed by the RBA and Global E-Sustainability Initiative and administered by the RMI to identify SORs in our supply chain. The CMRT requires that suppliers provide information concerning the usage and sourcing of 3TG in their products.
e. We utilize internal counsel and internal consultants to assist with our compliance efforts.
f. Seagate is an active member of the RBA and the RMI, and is an active participant in the United Nations Global Compact.
g. Materials procurement contracts reference and require RBA Code of Conduct or Conflict Minerals compliance.
h. We have a third-party managed Ethics Helpline as a grievance mechanism for employees, suppliers, or other stakeholders where concerns can be reported, including concerns relating to our Conflict Minerals management program. Reports may be made in English, Spanish, French, Chinese, Korean, Malay, Portuguese, and Thai at +1 (800) 968-4925 or online at https://seagate.alertline.com/.
2. Identify and assess risks in our supply chain:
a. We require suppliers who provide parts, components, materials, or subassemblies containing 3TG to provide a CMRT unless the supplier has previously disclosed the 3TG is not intentionally added or used in the product or production process.
b. We review supplier CMRTs for completeness relative to our internal operating procedures and controls. We reject CMRTs that appear inaccurate, incomplete, or not aligned with established acceptance criteria and request the supplier to perform additional due diligence to address identified issues.
c. We use the Smelter List maintained by the RMI to assess whether SORs are validated as conformant with the Responsible Minerals Assurance Process (“RMAP”) standard1.
3. Design and implement a strategy to respond to identified risks:
a. Designated employees monitor and report risks to our senior management team.
b. Suppliers are requested to remove SORs that are not validated as conformant with the RMAP standard, or not actively pursuing validation, from the supply chain.
1 In this report, ‘conformant with the RMAP standard’ includes gold refiners recognized by the RMI as conformant under the Cross Recognition Policy, Version 4, dated July, 2021, administered jointly by the RMI, the LBMA (London Bullion Market Association), and the Responsible Jewellery Council.
4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain:
a. We support independent third-party audits through our RMI membership.
b. We assess information provided by the RMI to determine if a SOR is conformant with the RMAP standard.
c. Direct suppliers are required to undergo an RBA Validated Assessment Program audit once every two years.
5. Report on supply chain due diligence:
a.We file annually a Form SD and a Conflict Minerals Report with the SEC and make them publicly available on our website.
b.We publish annually a Sustainability Performance Report and make it publicly available on our website.
Due Diligence Measures Performed
Our due diligence measures for the Reporting Period included the following activities:
•We maintained an internal team to implement the management plan. Through cross-functional collaboration, the team undertook the following measures, which were designed to support our compliance with the Rule and our management plan:
1.Maintained requirements in supplier contracts to define Seagate’s expectations of suppliers regarding sourcing of 3TG and reporting of information to Seagate.
2.Conducted a review to identify direct (i.e., first tier) suppliers of parts, components, materials, and subassemblies containing 3TG necessary to the functionality or production of our products (“3TG Direct Suppliers”).
3.Requested that all 3TG Direct Suppliers provide information to us regarding their 3TG using the CMRT to ascertain, for each of the 3TG, the SOR(s) where it was processed.
4.Reviewed and endeavored to validate the information provided by our 3TG Direct Suppliers by establishing a process that includes an assessment of the completeness and reasonableness of the information provided, then conducting follow-up communications to address deficiencies, if any.
5.Compared the SORs identified by 3TG Direct Suppliers via the CMRT against the RMI list of SORs that are validated as conformant with the RMAP standard.
6.Supported the RMI through membership in the RBA, membership in the RMI, and requests of our 3TG Direct Suppliers to encourage the SORs in their supply chains to achieve conformance with the RMAP standard.
7.Made periodic reports to Seagate senior management.
ANALYSIS OF SUPPLIER DATA AND DUE DILIGENCE DETERMINATION
Reasonable Country of Origin Inquiry
To conduct our RCOI, we utilized the RMI’s RCOI data together with the data our suppliers provided on their CMRTs. The RMI RCOI data provides the countries from which SORs validated as conformant with the RMAP standard are known to source 3TG, and it is used to determine the possible origins of the 3TG in our products.
Based on our RCOI, Seagate knows or has reason to believe that its 3TG originated or may have originated in the Covered Countries. RMI discloses groupings, by SOR, of countries from which each of its 3TG minerals may originate. In addition, the country of origin of 3TG is not disclosed for every SOR recognized by RMI under the Cross Recognition Policy. Thus, the following list provides a view of countries from which 3TG in our products may be sourced but may not include every country from which our 3TG is sourced.
Possible Countries of Origin for Mined Material (excludes Recycled/Scrap sources)
| | | | | | | | | | | | | | |
| Argentina | Democratic Republic of the Congo | India | New Zealand | South Africa |
| Armenia | Dominican Republic | Indonesia | Nicaragua | Spain |
| Australia | Ecuador | Japan | Niger | Suriname |
| Austria | Egypt | Kazakhstan | Nigeria | Sweden |
| Azerbaijan | Eswatini | Kenya | Norway | Tajikistan |
| Benin | Ethiopia | Kyrgyzstan | Papua New Guinea | Tanzania |
| Bolivia | Fiji | Lao | Peru | Thailand |
| Brazil | Finland | Liberia | Philippines | Turkey |
| Bulgaria | France | Madagascar | Poland | Uganda |
| Burkina Faso | French Guiana | Malaysia | Portugal | Ukraine |
| Burundi | Georgia | Mali | Russia | United Kingdom |
| Cambodia | Germany | Mauritania | Rwanda | United States |
| Canada | Ghana | Mexico | Saudi Arabia | Uzbekistan |
| Chile | Greenland | Mongolia | Senegal | Viet Nam |
| China | Guatemala | Morocco | Serbia | Zambia |
| Colombia | Guinea | Mozambique | Sierra Leone | Zimbabwe |
| Costa Rica | Guyana | Myanmar | Slovakia | |
| Côte d'Ivoire | Honduras | Namibia | Solomon Islands | |
*Table compiled using RCOI data version 78 from the RMI, dated March 27, 2026
Smelters and Refiners
We carried out the actions described in the “Due Diligence Measures Performed” section above to ascertain the source and chain of custody of the 3TG used in our supply chain. Given the dynamic nature of the supply chain, we provide below the snapshot list of SORs understood to be operating and in our supply chain at the end of the Reporting Period. Our 3TG Direct Suppliers have named these SORs as their sources of 3TG in the products we buy from them. We have subjected each incoming CMRT to systematic scrutiny, often followed by additional supplier communication. Except for a few instances, the SOR lists provided to us were complete. Several suppliers indicated that their SOR lists were substantially complete but possibly not exhaustive. The list below includes 3TG SORs reported to be in our supply chain and understood to be in operation as of December 31, 2025. In addition, the inclusion of any name on our list does not imply that its 3TG necessarily comprise portions of our products. This is because some suppliers provide CMRTs at the supplier level instead of the part level, resulting in overinclusion. Inclusion on this list only implies that the 3TG in our products may come from these sources.
SORs in Operation and in the Seagate Supply Chain
| | | | | | | | |
| Metal | Smelter | Country |
| Gold | Advanced Chemical Company | UNITED STATES |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Agosi AG | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | Aurubis AG, Hamburg | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden Mineral AB (Ronnskar) | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | Glencore Canada Corporation - CCR Refinery | CANADA |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Yunnan Copper Southwest Copper Branch | CHINA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Dowa | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | JSC Novosibirsk Refinery | RUSSIA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| | | | | | | | |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | Asahi Refining USA Inc. | UNITED STATES |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIA |
| Gold | JSC Uralelectromed | RUSSIA |
| Gold | JX Advanced Metals Corporation | JAPAN |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | Kazzinc Ltd | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Materion | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. - Takehara Refinery | JAPAN |
| Gold | Moscow Special Alloys Processing Plant | RUSSIA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| | | | | | | | |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIA |
| Gold | MKS PAMP SA | SWITZERLAND |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIA |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIA |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Tongling Nonferrous Jinguan (Ausmelt) Copper Industry | CHINA |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Gold Corporation - The Perth Mint | AUSTRALIA |
| Gold | Yamakin Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Zijin Mining Group Gold Smelting Co. Ltd. | CHINA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | SAFINA A.S. | CZECH REPUBLIC |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| | | | | | | | |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Gold | T.C.A S.p.A | ITALY |
| Gold | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | Shirpur Gold Refinery Ltd. | INDIA |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Marsam Metals | BRAZIL |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Abington Reldan Metals, LLC | UNITED STATES |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA |
| Gold | Albino Mountinho Lda. | PORTUGAL |
| Gold | SAAMP | FRANCE |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | 8853 S.p.A. | ITALY |
| Gold | Italpreziosi | ITALY |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Bangalore Refinery | INDIA |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIA |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | Pease & Curren | UNITED STATES |
| Gold | JALAN & Company | INDIA |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA |
| Gold | Safimet S.p.A | ITALY |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | African Gold Refinery | UGANDA |
| Gold | Gold Coast Refinery | GHANA |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | QG Refining, LLC | UNITED STATES |
| | | | | | | | |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | Sovereign Metals | INDIA |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Gold | Augmont Enterprises Private Limited | INDIA |
| Gold | Kundan Care Products Ltd. | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| Gold | K.A. Rasmussen | NORWAY |
| Gold | Alexy Metals | UNITED STATES |
| Gold | MD Overseas | INDIA |
| Gold | Metallix Refining Inc. | UNITED STATES |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | WEEEREFINING | FRANCE |
| Gold | CI Gold by Gold Colombia SAS | COLOMBIA |
| Gold | Dongwu Gold Group | CHINA |
| Gold | NOBLE METAL SERVICES | UNITED STATES |
| Gold | Coimpa Industrial LTDA | BRAZIL |
| Gold | KP Sanghvi International Pvt Ltd | INDIA |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | CHINA |
| Gold | TITAN COMPANY LIMITED, JEWELLERY DIVISION | INDIA |
| Gold | GG Refinery Ltd. | TANZANIA |
| Gold | Impala Platinum - Base Metal Refinery (BMR) | SOUTH AFRICA |
| Gold | Impala Rustenburg(Gold) | SOUTH AFRICA |
| Gold | Impala Platinum - Rustenburg Smelter | SOUTH AFRICA |
| Gold | Attero Recycling Pvt Ltd | INDIA |
| Gold | SOLEIL METALS (Chala One Plant) | PERU |
| Gold | SOLEIL METALS (YAKARI Plant) | PERU |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) | SOUTH AFRICA |
| Gold | Elite Industech Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | Gasabo Gold Refinery Ltd | RWANDA |
| Gold | Minera Titan del Peru SRL (MTP) - Belen Plant | PERU |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | Ximei Resources (Guangdong) Limited | CHINA |
| | | | | | | | |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | AMG Brasil | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | QuantumClean | UNITED STATES |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIA |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | Telex Metals | UNITED STATES |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET de Mexico | MEXICO |
| Tantalum | TANIOBIS Co., Ltd. (Thailand) | THAILAND |
| Tantalum | TANIOBIS GmbH | GERMANY |
| Tantalum | STEREON Metals Hermsdorf GmbH | GERMANY |
| Tantalum | Materion Newton Inc. | UNITED STATES |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | ULVAC Inc. | JAPAN |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tantalum | 5D Production OU | ESTONIA |
| Tantalum | PowerX Ltd. | RWANDA |
| Tantalum | CMT Rare Metal Advanced Materials (Hunan) Co., Ltd. | CHINA |
| Tantalum | Jiangxi Suns Nonferrous Materials Co. Ltd. | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| | | | | | | | |
| Tin | Alpha Assembly Solutions Inc | UNITED STATES |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Tin | Dongguan Best Alloys Co., Ltd. | CHINA |
| Tin | Dowa | JAPAN |
| Tin | EM Vinto | BOLIVIA |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Jean Goldschmidt International (JGI Hydrometal) | BELGIUM |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Metallic Resources, Inc. | UNITED STATES |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Novosibirsk Tin Combine | RUSSIA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thailand Smelting and Refining Co. Ltd. | THAILAND |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| | | | | | | | |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Super Ligas | BRAZIL |
| Tin | Aurubis Beerse | BELGIUM |
| Tin | Aurubis Berango | SPAIN |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | Tin Technology & Refining | UNITED STATES |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | PT Masbro Alam Stania | INDONESIA |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Precious Minerals and Smelting Limited | INDIA |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | Conecsus LLC | UNITED STATES |
| Tin | CRM Synergies | SPAIN |
| Tin | Rian Resources SDN. BHD. | MALAYSIA |
| Tin | Fabrica Auricchio Ind. Com. De Metais Ltda | BRAZIL |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | JAPAN |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA |
| Tin | PT Mitra Graha Raya | INDONESIA |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | INDIA |
| Tin | WOODCROSS SMELTING COMPANY LIMITED | UGANDA |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | AUSTRALIA |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | CHINA |
| Tin | PT Arsed Indonesia | INDONESIA |
| Tin | P Kay Metal, Inc | UNITED STATES |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| | | | | | | | |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Masan High-Tech Materials | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Niagara Refining LLC | UNITED STATES |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIA |
| Tungsten | Uzbekistan Technological Metallurgical Complex JSC | UZBEKISTAN |
| Tungsten | Unecha Refractory metals plant | RUSSIA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Moliren Ltd. | RUSSIA |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIA |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIA |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| | | | | | | | |
| Tungsten | OOO “Technolom” 2 | RUSSIA |
| Tungsten | OOO “Technolom” 1 | RUSSIA |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM |
| Tungsten | Nam Viet Cromit Joint Stock Company | VIET NAM |
| Tungsten | Plansee Composite Materials GmbH | GERMANY |
| Tungsten | Lianyou Resources Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA |
| Tungsten | Philippine Carreytech Metal Corp. | PHILIPPINES |
| Tungsten | Kenee Mining Corporation Vietnam | VIET NAM |
| Tungsten | Jing Yuan Tungsten Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | S.P.T. spol.s r.o. | CZECH REPUBLIC |
| Tungsten | Tungamoy Metals Inc. | KOREA, REPUBLIC OF |
We use an in-house database, referred to as the Compliance Assurance System (“CAS2”), to maintain product-level compliance data. Our supply chain organization has continued to work on building resiliency in the supply chain by ensuring that, where possible, components are not sourced from a single supplier. Our sourcing practices improvements during the Reporting Period can be partially attributed to our supply chain organization having real-time visibility on Conflict Minerals program metrics and leveraging sourcing arrangements with suppliers to ensure that non-conformant SORs were removed from the supply chain if they failed to participate in the RMAP.
ONGOING DUE DILIGENCE AND SUPPLIER RESPONSIVENESS PROGRAM
Seagate expects to maintain a responsible supply chain, including via the following:
∙ Continue to seek supplier commitments to responsible sources of 3TG, to request that suppliers have their SORs engage in the validation audit process, and, if necessary, convert to other preferred sources.
∙ Continue to refine CAS2 to further automate our data management, better facilitate supplier communications, and provide improved metrics to guide our risk management.
∙ In calendar year 2026, we plan to refresh all our 3TG Direct Supplier data using the latest CMRT. We continue to work to improve processes that encourage responsible sourcing of 3TG in a manner that avoids de facto boycott of responsibly sourced minerals from CAHRAs.
∙ Review activities upstream of SORs as appropriate to gain better visibility on the real-world conditions in the localities that the 3TG in our products are sourced from.
CAUTIONARY NOTE REGARDING FORWARD-LOOKING STATEMENTS
This Conflict Minerals Report on Form SD, including the Conflict Minerals Report attached as Exhibit 1.01, contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. 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 fact. Forward-looking statements include, among other things, statements about our future plans to improve due diligence and supplier responsiveness and to seek supplier commitments in this regard, to explore expanding the scope of our due diligence efforts beyond 3TG, to continue to refine CAS2 and refresh our supplier data, to continue our commitment to responsible sourcing, and to focus on activities upstream of SORs. Forward-looking statements generally can be identified by words such as “expects,” “intends,” “plans,” “anticipates,” “believes,” “estimates,” “predicts,” “projects,” “should,” “may,” “will,” “will continue,” “can,” “could” or the negative of these words, variations of these words and comparable terminology, in each case, intended to refer to future events or circumstances. However, the absence of these words or similar expressions does not mean that a statement is not forward-looking. Forward-looking statements are subject to various uncertainties and risks that could cause our actual results to differ materially from historical experience and our present expectations or projections. These risks and uncertainties include, but are not limited to, those described under the captions “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations” in the Company’s latest periodic report on Form 10-Q filed with the SEC. Undue reliance should not be placed on the forward-looking statements in this Conflict Minerals Report on Form SD, which are based on information available to us on, and which speak only as of, the date hereof. Except as may be required by law, we undertake no obligation to update forward-looking statements to reflect events or circumstances after the date they were made.