QVC, Inc. 6.375% Senior Secured (QVCD) SDConflict minerals disclosure

Exhibit 1.01

Conflict Minerals Report

QVC, Inc. has included this Conflict Minerals Report as an exhibit to its Form SD for 2020 as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is June 1, 2021.

Unless the context indicates otherwise, the terms “we,” “its,” “us” and “our” refer to QVC, Inc. and its consolidated subsidiaries. As used herein, “3TG” is tantalum, tin, tungsten and gold, without regard to the location of origin of the minerals or derivative metals.

Forward-Looking Statements

This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG finances or benefits armed groups.

Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) the accuracy and reliability of the information we receive and (3) political, legal and regulatory developments, whether in the Democratic Republic of the Congo and adjoining countries (the “DRC Region”), the United States or elsewhere. The term “adjoining countries” has the meaning contained in the Conflict Minerals Rule. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.

Applicability of the Conflict Minerals Rule to Our Company

We market and sell a wide variety of consumer products primarily through our televised shopping programs and via our websites and other interactive media. We are required to make a filing pursuant to the Conflict Minerals Rule for 2020 because we contracted to manufacture some products in 2020 where 3TG was necessary to the functionality or production of such products.

However, most of our products are not in-scope for purposes of the Conflict Minerals Rule, as we do not manufacture any products and we do not contract to manufacture most of the products that we sell.

We do not directly source any 3TG from mines, smelters or refiners, and believe that we are in most cases many levels removed from these market participants. We therefore have limited influence over them. Furthermore, because of the depth, geographic diversity and constant evolution of our supply chain, and due to competitive factors, we often have significant difficulty identifying suppliers upstream from our direct suppliers. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that we are in compliance with the Conflict Minerals Rule and that our suppliers meet the expectations of our Conflict Minerals Policy, which is discussed below.

Our Conflict Minerals Policy

We take seriously our compliance obligations under the Conflict Minerals Rule. Therefore, we have adopted and communicated to selected personnel, our suppliers and the public a policy regarding the supply of 3TG for products that we contract to manufacture (the “Conflict Minerals Policy”).

The Conflict Minerals Policy includes, but is not limited to, our expectations that the suppliers of products that we contract with them to manufacture:

Reasonable Country of Origin Inquiry Information

Prior to beginning our reasonable country of origin inquiry, the Conflict Minerals Working Group (as defined below) determined which of our products were potentially in-scope for purposes of the Conflict Minerals Rule through our degree of influence over the products’ manufacture and product specifications, visual inspection, supplier inquiries and other information known to us.

We then requested, as part of our reasonable country of origin inquiry, that the suppliers of these potentially in-scope products provide us with information concerning the origin of the 3TG in the products sourced from them. Based on the information provided to us by our suppliers, and the information that the RMI makes available to its members, we were unable to conclusively determine that any of the in-scope products we contracted to manufacture in 2020 contained only necessary 3TG that (1) did not originate in the DRC Region or we had no reason to believe may have originated in the DRC Region or (2) was from recycled or scrap sources or we reasonably believed came from recycled or scrap sources. Therefore, all of the products that we determined to be in-scope for 2020, and the related 3TG and direct suppliers, are discussed in this Conflict Minerals Report and those suppliers are referred to herein as the “Suppliers.”

The Suppliers identified 69 smelters and refiners as having processed the necessary 3TG contained in the products covered by this Conflict Minerals Report, as further discussed under “Product Information; Smelter and Refiner and Country of Origin Information.”

Pursuant to the Conflict Minerals Rule, based on the results of our reasonable country of origin inquiry, we were required to conduct due diligence for 2020 with respect to the 3TG in our in-scope products. These due diligence efforts are discussed below.

For our reasonable country of origin inquiry, to the extent applicable, we utilized the same processes and procedures as for our due diligence.

None of our in-scope products were determined by us to contain necessary 3TG that directly or indirectly financed or benefitted armed groups in the DRC Region. However, we did not conclude that any of our products covered by this Conflict Minerals Report were “DRC conflict free.” The terms “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.

Due Diligence Program Design

Design Framework

We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as supplemented by the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition 2016) (collectively, the “OECD Guidance”).

Selected Elements of Design Framework

The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our program design are discussed below. However, these are not all of the discrete elements of the program that we have put in place to help ensure that the 3TG contained in our products is responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took with respect to 2020 are discussed under “Due Diligence Program Execution on Products Contracted to be Manufactured During 2020.”

In connection with our due diligence, we utilize information made available by the RMI concerning independent third-party audits of smelters and refiners. We support the RMI through our membership in that organization. In the case of gold, we also utilize information made available in connection with the LBMA’s Good Delivery List and the RJC’s Chain-of-Custody Certification.

We file a Form SD, and to the extent applicable, a Conflict Minerals Report, with the Securities and Exchange Commission.

Due Diligence Program Execution on Products Contracted to be Manufactured During 2020

We performed the following 3TG due diligence on applicable 3TG in the in-scope products that were contracted to be manufactured for us during 2020. These were not all of the discrete measures that we took in furtherance of our 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance. For a discussion of the design of our due diligence measures, please see “Due Diligence Program Design.”

Product Information; Smelter and Refiner and Country of Origin Information

Our in-scope products for 2020 for purposes of the Conflict Minerals Rule are included within the following categories: (1) home, (2) beauty, (3) apparel, (4) jewelry, (5) accessories and (6) electronics. However, not all of our products in these categories are in-scope. For a further discussion of our products, see our Annual Report on Form 10-K for the 2020 fiscal year. The information contained in our Form 10-K is not incorporated by reference into the Form SD or this Conflict Minerals Report and should not be considered to be part of the Form SD or this Conflict Minerals Report.

In connection with our reasonable country of origin inquiry or due diligence, as applicable, the following facilities were declared by the Suppliers to be smelters or refiners used to process the necessary 3TG contained in our in-scope products. After reviewing those responses, we reasonably believe that these may be smelters or refiners in our supply chain for such 3TG. However, due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on the Suppliers for accurate smelter and refiner information, and our reasonable country of origin inquiry and due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products.

(1) “CFSP,” “LBMA” and “RJC” have the meanings provided earlier in this Conflict Minerals Report. CFSP, LBMA and RJC status is as of May 14, 2021.

We endeavored to determine the mine or location of origin of the 3TG contained in the in-scope products by requesting that the Suppliers provide us with a completed Survey concerning the source of the 3TG in the products sourced from them. In addition, to the extent that a completed response identified a smelter or refiner, we reviewed this information against the list of compliant smelters and refiners and country of origin information made available by the RMI to its members. If country of origin information for an identified smelter or refiner was not available from this independent third-party source, we reviewed publicly available information, to the extent reasonably available, to try to determine the mine or location of origin of the 3TG.

In addition to some recycled and scrap sources, the countries of origin of the gold and tin processed by the compliant smelters and refiners identified above are believed to have potentially included the following countries. The countries listed below are derived from the country categories used by the RMI to categorize compliant smelters and refiners.

Gold

Andorra, Argentina, Armenia, Australia, Austria, Azerbaijan, Bahamas, Belgium, Benin, Bolivia, Botswana, Brazil, Brunei, Burkina Faso, Cameroon, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Cote D’Ivoire, Croatia, Cuba, Cyprus, Czechia, Democratic Republic of the Congo, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Greece, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Iran, Ireland, Israel, Italy, Ivory Coast, Japan, Jordan, Kazakhstan, Kenya, Korea, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Liechtenstein, Lithuania, Luxembourg, Macau, Madagascar, Malaysia, Mali, Malta, Mauritania, Mauritius, Mexico, Monaco, Mongolia, Morocco, Mozambique, Namibia, Netherlands, New Caledonia, New Zealand, Nicaragua, Niger, Norway, Pakistan, Panama, Papua New Guinea, Paraguay, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Russian Federation, Rwanda, San Marino, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Slovenia, Solomon Islands, South Africa, South Korea, Spain, St. Vincent and Grenadines, Sudan, Suriname, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Zambia, Zimbabwe

Tantalum

Australia, Austria, Bolivia, Brazil, Burundi, Canada, China, Colombia, Democratic Republic of the Congo, Ethiopia, France, Germany, India, Indonesia, Ireland, Israel, Japan, Madagascar, Malaysia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Russian Federation, Rwanda, Sierra Leone, South Korea, Spain, Switzerland, Thailand, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Zimbabwe

Tin

Angola, Argentina, Australia, Austria, Bangladesh, Belarus, Belgium, Benin, Bolivia, Brazil, Bulgaria, Chile, China, Colombia, Democratic Republic of the Congo, Croatia, Cyprus, Czechia, Denmark, Egypt, El Salvador, Estonia, Finland, France, Gabon, Germany, Ghana, Greece, Guinea, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Japan, Jordan, Kazakhstan, Laos, Latvia, Lebanon, Libya, Lithuania, Luxembourg, Malaysia, Malta, Mexico, Mongolia, Myanmar, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Peru, Philippines, Poland, Portugal, Puerto Rico, Qatar, Romania, Russian Federation, Saudi Arabia, Senegal, Serbia, Singapore, Slovakia, Slovenia, South Africa, South Korea, Spain, Sudan, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Togo, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Venezuela, Vietnam, Yemen

Tungsten

Austria, Australia, Belgium, Bolivia, Brazil, Burundi, Canada, China, Czechia, Democratic Republic of the Congo, France, Germany, Hong Kong, Ireland, Israel, Japan, Kazakhstan, Latvia, Malaysia, Mexico, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, South Korea, Spain, Taiwan, Thailand, Uganda, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Vietnam, Zimbabwe

Further Risk Mitigation Efforts

We intend to take the following additional steps on in-scope products for 2021 to mitigate the risk that the 3TG contained in and necessary to the products we contract to manufacture finance or benefit armed groups in the DRC Region:

All of the foregoing steps are in addition to the steps that we took with respect to in-scope products for 2020, which we intend to continue to take with respect to in-scope products for 2021 to the extent applicable.