Snap (SNAP) SDConflict minerals disclosure

Exhibit 1.01

Snap Inc.

Conflict Minerals Report

For the Year Ended December 31, 2020

Snap Inc. has included this report as an exhibit to its Form SD for the year ended December 31, 2020 to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and Form SD (collectively, the “Conflict Minerals Rule”).

Unless the context indicates otherwise, all references to “Snap,” “the company,” “we,” “its,” “us,” and “our” refer to Snap Inc. and its consolidated subsidiaries. As used in this report, and consistent with the Conflict Minerals Rule, “conflict minerals” or “3TG” are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives tantalum, tin, and tungsten, without regard to their location of origin.

Forward-Looking Statements

This report contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Exchange Act that involve substantial risks and uncertainties. All statements other than statements of historical facts contained in this report are forward-looking statements. 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 finance or benefit armed groups in the Democratic Republic of the Congo (the “DRC”) or its adjoining countries (the “Covered Countries”). In some cases, you can identify forward-looking statements because they contain words such as “believe,” “continue,” “could,” “estimate,” “expect,” “may,” “will,” or “would” or the negative of these words or other similar terms or expressions. Actual results may not materialize and are subject to risks and uncertainties that could cause actual results to be materially different. These risks and uncertainties may include, but are not limited to, (1) whether our direct and indirect suppliers implement satisfactory traceability and other compliance measures on a timely basis or at all; (2) whether smelters and refiners (collectively, “SORs”), and other market participants, responsibly source 3TG; and (3) political, regulatory, and economic developments, whether in the Covered Countries, the United States, or elsewhere. Any forward-looking statements contained in this report are based on assumptions that we believe to be reasonable as of this date. We undertake no obligation to update any forward-looking statements in this report to reflect events or circumstances after the date of this report or to reflect new information or the occurrence of unanticipated events, except as required by law.

Overview; Applicability of the Conflict Minerals Rule to Snap

Our flagship product, Snapchat, is a camera application that helps people communicate visually with friends and family through short videos and images called Snaps. We generate revenue primarily from advertising on Snapchat. In 2020, our only products that were in-scope for purposes of the Conflict Minerals Rule were our Spectacles products, which are sunglasses that make Snaps, along with the associated charging cases and cables (the “Products”). The Products include each of the 3TG.

Spectacles are manufactured by third parties on our behalf. Accordingly, we do not source 3TG in raw form, do not have relationships with mines or SORs, and believe that we are many levels removed from these market participants. However, through the efforts described in this report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below, and to encourage responsible sourcing of 3TG by our supply chain.

Snap’s Conflict Minerals Policy

It is our policy to fully comply with laws and guidance, in the United States and abroad, regarding conflict minerals. Our aim is to go above and beyond to ensure no products we make play any role in financing armed conflict.

1

Consistent with these goals, we require our suppliers to agree to a Supplier Code of Conduct that sets forth 3TG sourcing and compliance standards. Those standards provide, among other things, that the suppliers must adhere to the OECD Guidance (as defined below), must exercise diligence on the source and chain of custody of 3TG used in their products, and must provide details of their diligence measures on request. Our policy is available on our website at www.snap.com under the heading “Other Terms & Policies.” Information contained on or accessed through our website is not incorporated by reference into this report and should not be considered part of this report.

We do not seek to embargo responsible sourcing of 3TG from the Covered Countries and we do not condone a general embargo on sourcing from the region.

Reasonable Country of Origin Inquiry

As provided for in the Conflict Minerals Rule, for 2020, we conducted a reasonable country of origin inquiry (“RCOI”). In connection with our RCOI, we reached out to 70 tier-one suppliers (the “Suppliers”) that we believed may have provided parts or components for the Products that contained 3TG necessary for the Products’ functionality or production. Our RCOI was reasonably designed to determine in good faith whether any of the 3TG in the Products originated in a Covered Country or from recycled or scrap sources. For our RCOI, we utilized the management systems contemplated by step one of the OECD Guidance and the supplier engagement process contemplated by step two of the OECD Guidance. These steps and the related activities are discussed under the section titled “Due Diligence” below. The results of our RCOI are discussed below under “RCOI and Due Diligence Results.”

Based on our RCOI, we had reason to believe that some of the 3TG in the Products may have originated from the Covered Countries. Therefore, in accordance with the Conflict Minerals Rule, we performed due diligence on the source and chain of custody of the 3TGs in question.

Due Diligence

We designed our due diligence measures to conform, in all material respects, with the framework in

the Organisation for Economic Co-operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold and tin, tantalum, and tungsten (collectively, the “OECD Guidance”). Selected elements of our due diligence are discussed below.

Step 1: Management Systems

2

Step 2: Identifying and Assessing Risk in the Supply Chain

We identified and assessed risk in our supply chain as described below.

The Service Provider requested that the Suppliers complete a CMRT. The Service Provider followed up by email or phone with Suppliers that did not respond within a specified time-frame. Ninety-seven percent of the Suppliers submitted CMRTs.

The Service Provider reviewed the completed responses received from the Suppliers. The Service Provider verified and validated responses for accuracy and completeness, using specific validation criteria. Under the Service Provider’s written procedures, incomplete or unsupported supplier declarations are returned to suppliers for correction. In addition, when the information provided by a supplier is found to be inconsistent or wrong, the supplier is re-contacted and asked to clarify or correct the information.

The Service Provider identified risks by assessing the due diligence practices of SORs listed in CMRT responses. The Service Provider compared the processing facilities listed to the list of SORs published by the RMI. The Service Provider also reviewed whether each SOR is Conformant (as defined below) with the RMI’s Responsible Minerals Assurance Process (“RMAP”). It assessed each identified SOR using five factors: (1) geographic proximity to the Covered Countries; (2) RMAP audit status; (3) credible evidence of unethical or conflict sourcing; (4) known mineral source country of origin; and (5) peer assessments conducted by third-party sources that it believed to be credible. It also evaluated suppliers on program strength using criteria from the OECD Guidance.

Based on the information furnished by the Suppliers and the Service Provider, we assessed the risks of adverse impacts, which informed our risk mitigation activities, as discussed below.

Step 3: Risk Mitigation

Our compliance team reported the findings of its supply chain risk assessment to our Chief Compliance Officer.

As part of our risk management, in addition to the measures discussed elsewhere in this report, to the extent that an SOR listed on a CMRT by a Supplier triggered a red flag, the Service Provider requested that the Supplier submit a “product level” or “user defined” CMRT, to enable us to identify whether the SOR processed 3TG contained in the

3

Products. None of the Suppliers provided us with a product level or user defined CMRT that listed an SOR with credible evidence of unethical or conflict sourcing. However, we did not conclude that the Products were “DRC conflict free” within the meaning of the Conflict Minerals Rule.

In addition, the Service Provider directed Suppliers that listed an SOR that triggered a red flag to the Service Provider’s educational materials on mitigating SOR risk in the supply chain. Through our membership with the RMI, we also encourage SORs to participate in the RMAP. The Service Provider contacted any SORs reported by Suppliers that were not already part of the RMAP to encourage them to participate in the RMAP. We utilize information provided by the Service Provider, and by the RMI to its members, to monitor SOR improvement.

We determine other steps to address identified risks on a case-by-case basis. This flexible approach enables us to tailor the response to the risks identified and take additional steps to the extent we determine to be appropriate under the circumstances.

Step 4: Audits of Smelter and Refiner Due Diligence Practices

In connection with our due diligence, we and the Service Provider utilize and rely on information made available by the RMI concerning independent third-party audits of SORs. We support independent third-party audits through our membership in the RMI.

Step 5: Public Reporting on Supply Chain Due Diligence

We filed this report as an exhibit to a Form SD with the Securities and Exchange Commission and made this report available on our website.

RCOI and Due Diligence Results

Smelters and Refiners

In connection with our RCOI or due diligence, as applicable, our Suppliers identified a total of 281 SORs that may be part of our supply chain for the Products for 2020, as reflected in the table below. Of these SORs, as of May 5, 2021, 235 are listed as Conformant by the RMI and nine are listed as Active (as defined below). A majority of the CMRTs we received were completed at a company level. We are therefore generally unable to determine whether the identified SORs are actually in our supply chain.

Please see the notes accompanying the table for additional information. Due to our position in the supply chain, which is discussed above, we rely on our suppliers for accurate SOR information. Our due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in the Products.

Smelter and Refiner and Country of Origin Information⁽¹⁾

4

Additional Steps to be Taken to Mitigate Risk

For 2021, we have taken or intend to take the following steps to improve the due diligence conducted to further mitigate the risk that the necessary 3TGs in the Products directly or indirectly finance or benefit armed groups in the Covered Countries:

5