supply 3TG to us that are responsibly sourced, including from conformant smelters in the Covered Countries, by which we mean to include (a) any 3TG necessary to the functionality and production of supplied materials do not directly or indirectly finance armed groups through mining or mineral trading in the Covered Countries, or (b) any 3TG in supplied materials including from recycled or scrap sources; and

adopt policies with respect to 3TG in support of our Responsible Minerals Policy and, throughout the supply chain, to require their suppliers to adopt similar policies.

The RMI has a cross-recognition program that incorporates certain information published by the London Bullion Market Association and the Responsible Jewellery Council, where applicable.

OECD Step #1: Establish and maintain strong company management systems

We have a team of senior staff who are members of the working group responsible for the management and continued implementation of our 3TG compliance strategy. This team reports to senior leadership of our Company. The following functional areas are represented on the working group or are otherwise involved with our compliance process: legal; corporate sustainability; global supply chain and procurement; and quality. Leadership of the compliance program resides with our Chief Supply Chain Officer. The Governance Committee of our Board of Directors also reviews our Company’s corporate responsibility, sustainability and human rights policies and programs.

Members of the Global Supply Chain and Procurement (Responsible Supply Chain) team participate in RMI conferences and working groups to expand and upskill knowledge and consistently receive training from the RMI on the Conflict Minerals Rule, the OECD Guidance, our compliance program and our procedures for reviewing and validating supplier responses to our inquiries. We have internal procedure documents addressing various aspects of our compliance program, including our review and validation of supplier responses. These documents are communicated to the members of the working group.

We utilize specialist outside counsel and other consultants to assist us with our compliance efforts.

We have a Responsible Minerals Policy, which includes our position on conflict minerals, including our commitment to responsible sourcing from Covered Countries. Our Responsible Minerals Policy is posted on our website at https://www.westerndigital.com/company/corporate-responsibility/ and is distributed electronically to supplier-facing employees and all suppliers of materials that we believe contain 3TG.

We utilize the RMI’s Conflict Minerals Reporting Template to identify smelters and refiners in our supply chain. We request in-scope suppliers to complete the Conflict Minerals Reporting Template in order to provide information concerning the usage and source of 3TG in their components, parts and products, as well as information concerning their related due diligence and compliance efforts. We encourage our suppliers to consult the information contained on the RMI website and to participate in appropriate third-party training to enhance the accuracy and quality of the information that they provide to us.

We are actively engaged with the RBA and the RMI through our participation in working groups and with RMI’s smelter engagement teams (“SETs”), which engage in outreach with existing and new smelters and refiners to encourage them to participate in audit processes. Our membership in the RBA and the RMI allows us to stay abreast of regulatory guidance and further align our internal procedures with industry best practices.

We have procedures to maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, on a computerized database for at least six years.

Certain of our forms of purchase order terms and conditions, as well as our component purchase agreements with suppliers, contain a requirement that our suppliers comply with environmental specifications for materials, components and products, which specifically require 3TG to be DRC conflict free and reference the RBA Code of Conduct, which requires the responsible sourcing of minerals generally.

We review selected supplier policies to determine whether they call or advocate for an embargo of 3TG from Covered Countries. Policies were selected for review based on the information provided by suppliers in their Conflict Minerals Reporting Templates. If any reviewed suppliers were suspected of embargoing Covered Countries, we followed up with such suppliers to urge them to amend their policies.

With the annual dissemination of the Conflict Minerals Reporting Template, we provide all in-scope suppliers with a copy of our Responsible Minerals Policy and indicate third-party resources that they can refer to for additional information.

We discuss our assessment of our suppliers’ conflict minerals responses during our supplier business reviews. In addition, we maintain smelters risk evaluations for all smelters reported in WD’s supply chain. We request that our suppliers follow these same procedures in their supply chain.

As a grievance mechanism, we have a third-party managed Ethics Helpline available for employees, suppliers and other interested parties to report potential violations of our Responsible Minerals Policy. We communicate to these stakeholders the availability of our Ethics Helpline for reporting potential violations of our company policies, which include our Responsible Minerals Policy. Our Ethics Helpline is available 24 hours a day online at www.ethicshelplinewdc.com in nine languages, or by phone, in all countries of operation in over 200 languages. A link to make a report online is also included in our Responsible Minerals Policy. It is our policy that if concerns about our 3TG sourcing or potential violations were to be reported, we would investigate appropriately.

OECD Step #2: Identify and assess risk in the supply chain

We sent requests to all of our suppliers that we identified as having provided us with components, parts or products containing 3TG, or that we believe may have provided us with components, parts or products containing 3TG, in 2025, and asked them to provide us with a completed Conflict Minerals Reporting Template. We requested that our suppliers furnish us with a completed template at the product level (i.e., specific to the products that they sold to us, rather than pertaining to the products sold to all of their customers). We managed our follow-up process through a compliance software program, and suppliers that did not respond to the request for a completed Conflict Minerals Reporting Template received follow-up emails until it was completed. We also provide one-on-one technical training via conference call as necessary to help suppliers complete the Conflict Minerals Reporting Template.

As part of the supplier on-boarding process, we required that new suppliers acknowledge and comply with our Responsible Minerals Policy before we made purchases from them. Next, we asked the supplier to complete a Conflict Minerals Reporting Template or otherwise made inquiries concerning the 3TG content of the components, parts and/or products we are purchasing to determine whether they are in-scope suppliers for purposes of our conflict minerals program. We continue to survey suppliers annually thereafter if they are identified as an in-scope supplier.

Conflict Minerals Reporting Templates are sorted in the compliance software program based on our internally-approved review criteria, which identifies “red flags” such as incomplete responses, potential errors, inaccuracies and potential Covered Country sourcing. As part of our review, we checked whether smelters and refiners disclosed by suppliers processed the types of metals contained in the components, parts and products sourced from those suppliers. We followed up by email or phone with suppliers that submitted a response that contained red flags or that otherwise provided a written response we determined to be unsuitable. We followed up with other suppliers as we deemed appropriate.

We reviewed the smelters and refiners identified by our suppliers against those contained on the Smelter Look-up tab list of the Conflict Minerals Reporting Template and those referenced in the RMI facility database. To the extent that they were not on that list or included in the database, we (i) requested that the supplier confirm that the listed entity is a smelter or refiner and/or (ii) through publicly available information, attempted to determine whether the listed entity is a smelter or refiner and whether it has ceased operations.

When a completed Conflict Minerals Reporting Template from a supplier identified a smelter or refiner, we also reviewed that information against the lists of conformant and active (or the equivalent) smelters and refiners and country of origin information published by the RMI. When a completed Conflict Minerals Reporting Template from a supplier identified a smelter or refiner that was not listed as conformant or active (or the equivalent) by these independent third parties, we consulted information that the RMI makes available to its members to attempt to determine whether the diligence practices of that smelter or refiner relating to minerals sourcing conform to the RMI’s Responsible Minerals Assurance Process’s assessment protocols and whether those smelters and refiners have ceased operations.

Suppliers are categorized by internally-developed supplier risk levels, which assign risk across multiple criteria, including smelter or refiner status, red flags identified and the supplier relationship. Suppliers that are identified as being in higher risk categories are escalated in accordance with our risk mitigation procedures, which are described below.

As part of our participation in RMI’s SETs, we worked to research and reach out to certain entities that have been referred to as smelters or refiners but that are not known to fit the RMI’s definition of a smelter or refiner under the RMAP (as defined below) standard (“alleged smelter or refiner”) to identify whether such alleged smelters or refiners meet the definition of smelter or refiner and should be referred to the RMI for consideration to be added to the RMI program.

Our internal compliance procedures and reporting metrics are refined regularly to better ensure we are effectively using program resources and collecting data that is useful to assessing and mitigating risk.

OECD Step #3: Design and implement a strategy to respond to identified risks

We have established a risk mitigation plan that includes due diligence reviews of relevant suppliers and smelters or refiners. Pursuant to this plan, we establish a timeline and monitoring program to address any supplier whose response contained red flags or whose response was otherwise determined to be unsuitable. An action plan to address the risk is then executed with the supplier and internal stakeholders, which may include reaching out and working directly or indirectly with the supplier, smelter, customer or other companies within industry working groups to mitigate the risk. We subsequently follow up with the supplier to review the implementation of the action plan until the smelter is returned to conformant status by the RMI or until all impacted suppliers have responded. The findings of our compliance efforts in 2025 were also reported to senior personnel at our Company, including leadership for our 3TG compliance program, and the Audit Committee of the Board of Directors.

We have written risk mitigation procedures, pursuant to which we sent requests to higher management levels in certain suppliers’ organizations where it was deemed advisable to encourage them to respond to our inquiries and to help incentivize suppliers to cooperate with our requests. Our risk mitigation procedures provide for increasing levels of escalation to specified internal personnel and allow for a flexible response that is commensurate with the risks identified.

To the extent that identified smelters and refiners were, according to the RMI information, neither conformant nor active, we work through the RMI’s SETs to encourage such smelters and refiners to become conformant, except where the smelters or refiners have, according to the RMI information, permanently or temporarily ceased operations.

As part of our participation in RMI’s SETs, we work together with RMI and other RMI member companies and determine the single point of contact with certain smelters and refiners, and in such role we reached out to certain of our existing tungsten and tantalum smelters to encourage them to continue participating in independent third-party audits under the RMI program.

We utilize information provided by the RMI to its members to monitor smelter and refiner improvement. We urge our suppliers to transition to exclusively sourcing from conformant smelters and refiners and monitor their progress toward that objective.

OECD Step #4: Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain

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 also support independent third-party audits of smelters and refiners through our membership in the RMI. In addition, certain of our personnel were members of or participated in various RMI committees, including the SETs. We also directly or indirectly engaged with 45 smelters or refiners in our supply chain and urged them to participate in a Responsible Mineral Assurance Process program.

OECD Step #5: Report annually on supply chain due diligence

Tantalum

Tin

Tungsten

Gold

If a smelter or refiner sourced from multiple sources, it is included in the table under each applicable category.

Smelter or refiner status information can change at any time. The RMI-provided smelter or refiner status information in the table is as of December 31, 2025.

As of the date of this filing, all smelters identified as “Non-Conformant” in our supply chain were either RMAP active or have been removed from our supply chain.

Further updated our reasonable country of origin inquiry and due diligence procedures to align with the latest revision of the Conflict Minerals Reporting Template.

Continued developing our program to utilize the RMI’s e-learning platform with selected suppliers to enhance their knowledge about responsible minerals practices.

Continued to update the conflict minerals portion of the supplier rating system used in our supplier business review to include recognition of suppliers that make conflict minerals policies publicly available to further disseminate responsible sourcing expectations throughout the supply chain.

Enhancing our compliance software program to incorporate Reasonable Country of Origin Inquiry data to validate suppliers’ declarations in an updated version of the Conflict Minerals Reporting Template.

Metal

Standard Smelter Name

Country

RMAP

Audit

Status

Metal

Standard Smelter Name

Country

RMAP

Audit

Status

Metal

Standard Smelter Name

Country

RMAP

Audit

Status

Metal

Standard Smelter Name

Country

RMAP

Audit

Status

Metal

Standard Smelter Name

Country

RMAP

Audit

Status

Metal

Standard Smelter Name

Country

RMAP

Audit

Status

We note the following in connection with the information contained in the foregoing table:

The smelters and refiners listed in the table were identified by our suppliers as those that may be part of our 2025 supply chain, including those that sourced only recycled or scrap content. Some of our suppliers may have reported to us smelters and refiners that were not actually in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. In addition, the smelters and refiners reflected above may not be all of the smelters and refiners in our 2025 supply chain, because many of our suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our products.

The table only includes entities that were identified by our suppliers as those that may be part of our 2025 supply chain and that were listed as smelters or refiners by the RMI, as of December 31, 2025.

Smelter or refiner status information can change at any time. The smelter or refiner status information in the table is provided by the RMI and is as of December 31, 2025.

“Conformant” means that a smelter or refiner was listed as conformant with the Responsible Minerals Assurance Process’s (“RMAP”) assessment protocols, including through mutual recognition and those indicated as “re-audit in process.” Included smelters and refiners were not necessarily conformant for all or part of 2025 and may not continue to be conformant for any future period. We do not have information on the origin of the 3TG processed by any of the conformant smelters and refiners prior to their respective certification dates.

“Active” means that the smelter or refiner is a participant in the RMAP and has committed to undergo an audit or is participating in a cross-recognized certification program.

Smelter or refiner status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us.