Adient (ADNT) SDConflict minerals disclosure

Adient is one of the world’s largest automotive seating suppliers and has relationships with the largest global auto manufacturers. Adient designs, manufactures and markets a full range of seating systems and components for passenger cars, commercial vehicles and light trucks, including vans, pick-up trucks and sport and crossover utility vehicles. Adient’s proprietary technologies extend into virtually every area of automotive seating solutions, including complete seating systems, frames, mechanisms, foam, head restraints, armrests, and trim covers.

Adient operates 208 wholly-owned and majority-owned manufacturing or assembly facilities in 33 countries, and employs approximately 75,000 employees worldwide. Its products are incorporated into more than 20 million vehicles each year.

As used in this Report, and except where the context otherwise requires, the terms “we” and “our” refer to Adient and its majority-owned subsidiaries and variable interest entities that are required to be consolidated.

As noted above, our products include complete seating systems, frames, mechanisms, foam, head restraints, armrests, and trim covers.

As a large multinational company, Adient has a complex, multi-tiered supply chain. The products that Adient manufactures are typically highly engineered, complex, and contain thousands of parts sourced from a vast network of globally dispersed suppliers.

As a downstream consumer with many tiers in its supply chain, Adient generally does not have a direct relationship with smelters and refiners. In most instances, Adient obtains products containing 3TG from unrelated third-party

suppliers with their own independent supply chains. Accordingly, Adient must rely on its first-tier suppliers to provide information regarding the origin of any Conflict Minerals contained in the components and parts they supply to Adient.

Adient elected to use the unaltered CMRT and a survey tool to facilitate its RCOI. The questions on the CMRT include, but are not limited to, the use of Conflict Minerals and their necessity to product functionality or production, the origin of such Conflict Minerals, and whether smelters have been validated as compliant in accordance with the RMI. Adient communicated with In-Scope Suppliers (as defined below), notifying them of the RCOI and Adient’s expectations, and also provided such suppliers with instructions to assist with the completion of the CMRT.

In addition to the RCOI efforts described above, Adient undertook the following measures to determine the mine or country of origin of any Conflict Minerals:

Consistent with the additional steps outlined above, Adient continued to work with particular attention on suppliers that reported sourcing from Russian smelters that could potentially be subject to U.S. economic sanctions programs. Adient strictly prohibits sourcing from any sanctioned countries or parties, and the CMRTs identifying such smelters included smelters that were not present in Adient’s own supply chain. Nonetheless, Adient undertook a review process to request additional information from suppliers, evaluate potential exposure to sanctioned smelters, and better understand its suppliers’ supply chains. Suppliers responding to Adient’s information requests consistently indicated that they were unable to determine whether they sourced products indirectly from such smelters given the complex, multi-layered, and highly-attenuated nature of their supply chains.

Adient determined there were 1091 In-Scope Suppliers for calendar year 2021. Adient sent communications to its In-Scope Suppliers notifying them of the RCOI and received delivery confirmation receipts from 94% of those In-Scope Suppliers.

The overall response rate among the In-Scope Suppliers surveyed was 66%, including 670 responses that were received and accepted (representing 65% of the suppliers who confirmed receipt of the survey). Adient considers a response as received and accepted when a completed CMRT has been returned to Adient and the CMRT has been validated as accurate by its compliance specialists. Below are the results of the RCOI survey:

Adient designed and implemented a compliance framework that conforms to the primary principles of the OECD Guidance, which is the internationally recognized due diligence framework developed by the OECD. Our compliance framework includes elements drawn from those principles and the corresponding supplements for each of the four conflict minerals. These include: 1) establishing strong company management systems; 2) identifying and assessing risk in the supply chain; 3) designing and implementing a strategy to respond to identified risks; 4) carrying out an independent third-party audit of smelters’/refiners’ due diligence practices; and 5) reporting annually on supply chain due diligence. We described each of these elements further below.

Adient is committed to the responsible sourcing of Conflict Minerals and it supports the humanitarian goal of ending violent conflict in the Covered Countries. Our Conflict Minerals Policy Statement expresses that we continue to promote and encourage suppliers to conduct conflict-free sourcing from the Covered Countries, and to use responsible sourcing practices. We expect our suppliers to conduct due diligence on their respective supply chains and to assist us with our compliance efforts. To the extent that a supplier refuses to cooperate with our compliance efforts or does not conduct conflict-free sourcing from the Covered Countries, we may reconsider our supply arrangement and/or implement remedies available to us. Our Conflict Minerals Policy Statement is publicly available on Adient’s website at:

https://www.adient.com/wp-content/uploads/2021/11/AdientConflictMineralsPolicyStatement2021.pdf.

Adient maintains an internal management system where senior management with the necessary expertise, knowledge, and experience oversee the RCOI and due diligence process. These managers continuously seek new ways to evaluate and address potential risk in our supply chain process through initiatives that often involve stakeholder engagement or consultation with outside experts.

This Report was also shared with Adient’s Disclosure Committee, which is comprised of Adient’s Chief Executive Officer; Chief Financial Officer; Chief Legal and Human Resources Officer; Chief Accounting Officer; Vice President and General Counsel, Commercial Transactions; Vice President, Finance; Vice President, Tax; Vice President, Internal Audit; Vice President, Investor Relations, Treasury and Communications; Vice Presidents and Executive Directors, Regional Finance; and Vice President, Global Financial, Planning and Analysis.

Due to the complexity of Adient’s global supply chain, Adient relies on its first-tier suppliers to provide information on the origin of Conflict Minerals potentially present in materials supplied to Adient. Adient’s RCOI and due diligence processes are designed to gather information on the chain of custody of the necessary Conflict Minerals potentially included in Adient’s products.

Adient provides an online training for suppliers as part of the initial communication package to the In-Scope Suppliers that explains the relevant requirements of the Rule, Adient’s obligations under the Rule, and Adient’s

expectation that our suppliers support our Conflict Minerals compliance efforts. The training is posted on our website at: https://www.adient.com/suppliers/corporate-responsibility. Adient encourages its suppliers to confer with its compliance team and strengthen their understanding of the Rule and our expectations. Adient also provides additional training to suppliers on request.

Adient publicly shares its position on responsible sourcing of Conflict Minerals through its Conflict Minerals Policy Statement. Where appropriate, Adient also includes a Conflict Minerals compliance provision when it renews or enters into new agreements with suppliers. The provision requires suppliers to conduct and document inquiries of smelters and refiners of any Conflict Minerals incorporated into the products supplied to Adient, including inquiries into the country of origin. Adient’s Global Supplier Standards Manual further reflects and reinforces these expectations.

Adient maintains a web-based training module designed specifically for employees within its Sales, Procurement and Engineering Departments. This training educates employees about the relevant requirements of the Rule, Adient’s obligations under the Rule, and the processes Adient uses to evaluate and respond to related supply chain risks. Training sessions are mandatory for new employees at Adient facilities that perform engineering and design activities related to the use of Conflict Minerals.

Adient retains relevant Conflict Minerals documentation in accordance with its existing corporate records retention procedures.

Adient maintains a web- and telephone-based, 24-hour Integrity Helpline (information is available at: https://adient.ethicspoint.com/). The Integrity Helpline provides any interested party (e.g., employees, customers, suppliers, or other external third parties) with a confidential mechanism to report potential violations of the law, regulations, professional standards, and policies (including Adient’s Ethics Policy and its Conflict Minerals Policy Statement), as well as concerns regarding Adient’s supply chain. Credible reports follow Adient’s internal investigations protocol, whereby incoming reports are either investigated by Adient’s Legal Department or transferred to another responsible group inside Adient for investigation. The Legal Department monitors these internal investigations and the resolution of cases escalated through other channels.

Adient’s RCOI was designed to determine whether the Conflict Minerals necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by Adient originated in the Covered Countries or were from recycled or scrap sources. Through communications with the In-Scope Suppliers, Adient attempted to identify smelters and refiners of Conflict Minerals that may be used in its products.

Adient followed-up, and continues to follow-up, with suppliers who indicated that they might be sourcing Conflict Minerals from the Covered Countries or non-certified smelters in order to exercise due diligence on the source and chain of custody of the Conflict Minerals, asking such suppliers whether they:

Adient has established due diligence guidelines to be followed if it identifies information indicating that a supplier may have sourced Conflict Minerals from the Covered Countries through a review of the received CMRT.

Once an In-Scope Supplier indicates that it might be sourcing Conflict Minerals from the Covered Countries, Adient initiates due diligence procedures to collect more detailed information from that supplier. This included engaging with such supplier and validating information with other reliable sources. Suppliers reporting RMI-certified smelters from the Covered Countries were generally exempt from further due diligence as long as there were no incident reports available from NGOs or other reliable sources regarding the listed smelter(s) or refiner(s).

Any findings from the due diligence procedures are discussed with Adient’s Procurement Department. Based on this information, Adient created a list of suppliers identified as using Conflict Minerals from a Covered Country as well as the indicated smelters. This list was then compared to the RMI smelter listing to verify the accuracy of the supplier responses as well as the source of the Conflict Minerals, and then shared with the responsible procurement team.

In addition to these measures, Adient engaged and actively cooperated with industry groups, including RMI and AIAG. Adient provides its smelter list to the RMI to support RMI’s risk assessments.

Adient does not purchase raw ore or unrefined Conflict Minerals, and, to the best of its knowledge, conducts no purchasing activities directly in the Covered Countries. Instead, Adient is a downstream consumer of Conflict Minerals and is many steps removed from the mining of Conflict Minerals. In order to meet its obligations under the Rule, Adient supports independent third-party audits by being a member of the RMI and relies on the RMI’s Conflict-Free Smelter Program in connection with our due diligence efforts.

This program helps Adient to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. Adient evaluates the supplier reports it receives using the RMI smelter database and then reports any unknown smelter or smelters that have not been certified to the RMI for further investigation and inclusion in the smelter certification scheme.

This Report (and the related Form SD) was filed with the SEC and is available on our website at: https://www.adient.com/suppliers/corporate-responsibility.

Each of the measures described above was designed to provide Adient with information on the smelters and refiners that the In-Scope Suppliers used to process Conflict Minerals incorporated into the products they supply to Adient. As previously discussed, Adient is a downstream consumer of 3TG and generally does not have a direct relationship with smelters and refiners. Consequently, it must rely on responses from its suppliers in order to determine the facilities used to process Conflict Minerals. Much like Adient, our suppliers generally have their own highly attenuated global supply chains and do not have direct relationships with the smelters or other facilities that process Conflict Minerals.

Due to changes in the supplier CMRT evaluation process, the amount of CMRTs still in process at the end of the RY has been reduced to zero. Adient’s updated evaluation rules enabled the internal Conflict Minerals team to re-categorize CMRTs as “3TG origin uncertain or unknown’” in those instances where suppliers did not provide RCOI information for uncertified smelters on the smelter list, and in cases where supplier RCOI data appears to be incorrect.

In RY 2021, only 2 suppliers responded they were unable to provide smelter and refiner information – an amount that accounts for less than 1% of our In-Scope Suppliers. 160 suppliers (24%) reported not certified smelters and were consequently rated as “3TG uncertain or unknown”. Only 31 suppliers (5%) stated that they do not source from DRC or adjoining countries. Given this response and the low response rate for this reporting period, Adient does not know all of the countries of origin or the facilities used to process all the Conflict Minerals incorporated into its products.

Another 5% acknowledged that they sourced 3TG from one or more Covered Countries. The suppliers sourcing from the Covered Countries indicated that they only sourced from smelters that the RMI identifies as DRC conflict free, except for one supplier who reported a smelter that lost its certification during the reporting year. None of the responses acknowledged that 3TG was sourced from smelters or mines that financed or benefited armed groups, after reviewing information from NGOs and other sources.

As explained above, Adient compared the smelter lists provided in responses from its In-Scope Suppliers with the RMI list of compliant smelters to determine which smelters the RMI identifies as DRC conflict free. The information provided by our suppliers was used to conduct our due diligence, including assessing reports for completeness and consistency.

Adient’s current processes and procedures for mitigating Conflict Minerals supply chain risks include the following:

The purpose of these processes is to encourage smelters to make responsible sourcing decisions, and to reduce the likelihood that the sale of these Conflict Minerals will benefit armed groups in the Covered Countries.

Adient is committed to promoting these same objectives by complying with the OECD Guidance and the Rule in a manner consistent with our Conflict Minerals Policy Statement. To that end, Adient will continue its efforts with its In-Scope Suppliers to improve the response rate and the completeness of the surveys. These efforts include:

Adient has made statements in this Report that are forward-looking and, therefore, are subject to risks and uncertainties. All statements in this Report other than statements of historical fact are statements that are, or could be, deemed “forward looking statements” within the meaning of the Private Securities Litigation Reform Act of

1995. In this document, statements regarding Adient’s future plans, objectives, outlook, targets, guidance or goals are forward-looking statements. Words such as “may,” “will,” “expect,” “intend,” “estimate,” “anticipate,” “believe,” “should,” “forecast,” “project” or “plan” or terms of similar meaning are also generally intended to identify forward-looking statements. Adient cautions that these statements are subject to numerous important risks, uncertainties, assumptions and other factors, some of which are beyond Adient’s control, that could cause Adient’s actual results to differ materially from those expressed or implied by such forward-looking statements. These risks and uncertainties are difficult to predict accurately and may include (but are not limited to) regulatory changes and other developments relating to Conflict Minerals disclosures, changes in or developments related to Adient’s products or Adient’s supply chain, changes to Adient’s supplier base and industry developments relating to supply chain diligence, disclosure and other practices. A detailed discussion of risks related to Adient’s business is included in the section entitled “Risk Factors” in Adient’s Annual Report on Form 10-K for the fiscal year ended September 30, 2021 and in its quarterly reports on Form 10-Q as well as other filings with the SEC, available at www.sec.gov. The forward-looking statements included in this Report are made only as of the date of this Report and, except as required by law, Adient assumes no obligation, and disclaims any obligation, to update such statements.