Apple (AAPL) SDConflict minerals disclosure

At Apple, our respect for human rights begins with our commitment to treating everyone with dignity and respect. Apple’s Board of Directors adopted and oversees our human rights policy — Our Commitment to Human Rights (“Human Rights Policy”) — which governs how we treat everyone, including our customers, employees, business partners, and people at every level of our supply chain. In alignment with our Human Rights Policy as well as Apple’s Supplier Code of Conduct (“Code”), which includes Apple’s Supplier Responsibility Standard on the Responsible Sourcing of Materials (“Responsible Sourcing Standard”), we conduct human rights and environmental due diligence in our supply chain to identify risks and work to mitigate them. We also work to identify and remedy potential adverse impacts, track and measure our progress, and report our findings. In support of these goals, we also aim to expand access to learning opportunities and skills development for people across our supply chain, including through our $50 million Supplier Employee Development Fund.

We seek to one day use only recycled and renewable minerals and materials in our products and packaging, and we are committed to achieving carbon neutrality for our entire footprint by 2030 — from our supply chain to the use of the products we make. Apple continues to make progress on its work to expand recycled materials across its products, with 20 percent of all material shipped in Apple products in 2022 coming from recycled or renewable sources. Tin, tungsten, tantalum, and gold (“3TG”) are among 14 materials prioritized in our initial efforts to transition to recycled and renewable materials, based on an evaluation of the environmental, social, and supply impacts of 45 mined elements and raw materials. The results of this evaluation and the related methodology (“Material Impact Profiles”) are available on Apple’s website for others to access and use.¹

As we make progress toward these ambitious goals, we continue to source 3TG and other minerals, such as cobalt and lithium, responsibly while working to improve conditions in and around mining communities, including in the Democratic Republic of the Congo (“DRC”) and adjoining countries. Although Apple does not directly purchase, procure, or source primary minerals, we are committed to meeting and exceeding internationally accepted due diligence standards for primary minerals and recycled materials in our supply chain. Our responsible minerals sourcing program includes requirements that apply to all levels of Apple’s supply chain. Conducting human rights and environmental due diligence in alignment with the Organisation for Economic Co-operation and Development’s (“OECD”) 2016 Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements (“OECD Due Diligence Guidance”) and the United Nations Guiding Principles on Business and Human Rights (“UN Guiding Principles”) is the foundation of Apple’s responsible sourcing programs for primary and recycled minerals and materials.

Apple’s Code and Responsible Sourcing Standard require suppliers, smelters, refiners, and recyclers in our supply chain to identify and assess a broad range of risks beyond conflict, including social, environmental, and human rights risks. Suppliers are also required to review reported incidents and public allegations linked to their smelters and refiners, and to participate in 3TG traceability and independent third-party audit programs to mitigate identified risks.

As of December 31, 2023 — for the ninth consecutive year — 100 percent of the identified smelters and refiners in our supply chain for all applicable Apple products manufactured during 2023 participated in an independent third-party conflict minerals audit for 3TG. These audits encompassed the identified smelters and refiners that provide materials for the following Apple product categories: iPhone^®, Mac^®, iPad^®, AirPods^®, Apple TV^®, Apple Watch^®, Apple Vision Pro^TM, Beats^® products, HomePod^®, HomePod mini^®, Apple Card^®, and all Apple^® accessories.

In 2023, we removed from our supply chain 14 smelters and refiners that were not willing to participate in, or complete, a third party audit or that did not otherwise meet Apple’s requirements for the responsible sourcing of minerals. Based on our due diligence efforts, including analyzing the information provided by third-party audit programs, upstream traceability programs, and our suppliers, we found no reasonable basis for concluding that any of the smelters or refiners of 3TG determined to be in our supply chain as of December 31, 2023 directly or indirectly financed or benefited armed groups in the DRC or an adjoining country.

In addition to our work to strengthen industrywide due diligence programs operating in areas where 3TG minerals are sourced, we engage with and support a broad range of multistakeholder and community initiatives. We provide funding for the Fund for Global Human Rights, a public foundation that supports human rights and environmental defenders around the world, including in the DRC. We also support whistleblower initiatives so independent, local voices can raise issues and report incidents at the mining level. Input from stakeholders and rights-holders in the DRC contributes to our robust due diligence program and drives industrywide progress.

We believe that all stakeholders (including governments, civil society, and industry) should enhance their efforts to implement comprehensive due diligence programs, measure impact, and work together with—and support—local communities to improve conditions and drive economic and social development in mining areas, including in the African Great Lakes region.

The below chart summarizes the comprehensive set of tools we utilize to drive progress throughout our supply chain.²

In alignment with Step 1 of the OECD Due Diligence Guidance, Apple has robust internal policies and management systems overseeing its efforts for the responsible sourcing of minerals.

Apple conducts business ethically, honestly, and in compliance with applicable laws and regulations. This applies to every business decision in every area of the company worldwide.

Apple’s Code, which includes Apple’s Responsible Sourcing Standard, applies to all levels of Apple’s supply chain, including traders, suppliers, sub-suppliers, mining companies, and operators of collection points for recycled minerals used in Apple products. The Code and Responsible Sourcing Standard are based on industry and internationally accepted principles, including the UN Guiding Principles, the International Labour Organization’s International Labour Standards, and the OECD Due Diligence Guidance.

Apple requires its suppliers to adhere to the Code and the Responsible Sourcing Standard, including any subsequent amendments or updates. Suppliers are also required to apply Apple’s requirements upstream to their own suppliers throughout all levels of the supply chain. In this way, and through direct outreach by Apple to all 3TG smelters and refiners identified in its supply chain, Apple implements its requirement that smelters and refiners in its supply chain comply with Apple’s strict standards, including participation in independent third-party audit programs.

We conduct third-party assessments of our suppliers who report to Apple the use of 3TG in their parts and products to confirm alignment with the OECD Due Diligence Guidance and the Code and Responsible Sourcing Standard. Additional information about these assessments is provided in Step 4 of this report. If we discover our standards are not being met, we provide support to help suppliers complete a corrective action plan, in line with the OECD Due Diligence Guidance framework of progressive improvement, to meet and exceed our requirements within the timeline identified as a result of the assessment or specialized audit. Timelines for corrective actions typically range between 30 and 90 days. If a supplier is unwilling or unable to meet Apple’s requirements, we will terminate applicable business relationships.

We also support industrywide grievance and allegations mechanisms at the smelter and refiner level and whistleblowing programs deeper in the supply chain at the mining level. These programs are discussed further in Step 2 of this report.

We are committed to working in collaboration with stakeholders beyond our own supply chain. As part of this commitment, we regularly review and gather feedback on Apple’s programs and wider industry initiatives by engaging with experts on human rights, the environment, and minerals sourcing from civil society, non-governmental organizations (“NGOs”), industry, academia, and government. We work with these groups to discuss strategies for increasing the effectiveness and innovation of approaches to the responsible sourcing of recycled and primary sourced minerals in supply chains.

In 2023, we continued our active participation and leadership in multiple industry associations and multistakeholder initiatives, including supporting the ongoing development of industrywide, responsible sourcing standards. Apple representatives were also featured on multiple panels at the annual Responsible Business Alliance’s (“RBA”) and Responsible Minerals Initiative’s (“RMI”) annual conference and continued to serve on:

Consistent with Step 2 of the OECD Due Diligence Guidance, we work at multiple levels in our supply chain to continuously identify and assess risks in our minerals supply chains. The 14 priority materials outlined in our Material Impact Profiles³ were identified based, in part, on their salient environmental and human rights supply chain risks. We use this analysis to inform our process to map and conduct heightened due diligence on priority materials in Apple’s supply chain, including high-risk materials, such as gold. We also work with industry to promote effective and transparent systems that allow these and other materials to be sourced responsibly by others.

In addition to conducting our own supply chain due diligence, we help strengthen and increase the transparency of independent third-party audit programs to help identify a broad range of social, environmental, human rights, and governance risks at the smelter, refiner, and mining levels. These include audit programs by the RMI and the London Bullion Market Association (“LBMA”) and mine level monitoring programs led by the International Tin Supply Chain Initiative (“ITSCI”) and RCS Global Group’s Better Mining program (“Better Mining”).

We continue to innovate, develop, and scale tools to enhance risk identification and assessment beginning at the mining level, and emphasize the importance of cross-industry and multistakeholder collaboration in the use and refinement of these tools in order to drive greater collective impact throughout global supply chains. This includes a variety of tools aimed at enhancing risk identification and assessment, such as:

In 2023, building on research Apple previously supported which assessed the human rights impacts of due diligence programs, we also supported initiatives aimed at:

Apple believes that supporting rights-holders at the mining level is critical to identifying and assessing risks in the 3TG supply chain. In 2023, this included our work on the following initiatives:

Several of the programs Apple supports include a specific focus on addressing concerns in and around artisanal and small-scale mining (“ASM”) communities. In 2023, these initiatives included:

In alignment with Step 3 of the OECD Due Diligence Guidance, we implement our due diligence program and conduct supply chain analysis by leveraging information gained from independent research, engaging with civil society groups and rights-holders, analyzing independent third-party audits, and working directly with smelters and refiners to respond to risks identified in our supply chain.

We closely monitor completion of independent third-party audits and corrective action plans by the smelters and refiners in our supply chain. If smelters or refiners delay implementation of corrective action plans developed by third-party audits, we conduct applicable smelter or refiner outreach to reiterate that completion and closure of corrective action plans are required in order to remain in our supply chain.

If smelters or refiners are unable or unwilling to meet our standards, we take necessary actions, through our suppliers, to terminate the applicable business relationships. As of December 31, 2023, we found that all identified smelters and refiners in our supply chain participated in an independent third-party audit that met Apple’s requirements for the responsible sourcing of minerals.

Each year, we analyze incident data provided by ITSCI and Better Mining, two upstream traceability and due diligence programs that monitor tin, tungsten, and tantalum mines in the DRC and across the African Great Lakes region. We work with these programs to help strengthen their incident review processes, and review and monitor incidents generated through their respective reporting systems, including reviewing mitigation actions and confirming incidents are closed in accordance with the programs’ standards and procedures.

In 2023, we continued to review incidents and accompanying analysis reported by both ITSCI and Better Mining. As part of this process, we also reviewed reported incidents that could have directly or indirectly benefited or financed armed groups in the DRC or adjoining countries. As of December 31, 2023, we found no reasonable basis for concluding that any of the reported incidents were connected to tin, tungsten, or tantalum included in Apple’s products. The challenges of tracking specific mineral quantities through the supply chain continue to impede the traceability of any specific mineral shipment through the entire product manufacturing process.

Apple continues to address remaining challenges in the global gold supply chain through its due diligence program, which is aligned with the OECD Due Diligence Guidance Supplement on Gold and other sources. As part of our risk assessment and due diligence efforts, we designed and implemented systems that focus specifically on the gold supply chain. Apple requires certification from the RMI’s RMAP or the LBMA’s Responsible Gold Program for gold refiners in our supply chain. We also prioritize gold in our efforts to transition to recycled and renewable materials in our products, and 100 percent of our recycled gold refiners are audited. In 2023, we reviewed gold refiners in our supply chain to identify potential risks and other sourcing challenges, and subsequently worked with suppliers to address such identified risks and challenges and to remove refiners as necessary.

Apple believes that innovative and data-driven solutions to sourcing help reduce risk and improve traceability and is leading on responsible gold sourcing innovation. This includes pioneering industry-leading traceability mechanisms for recycled materials to build a supply chain of exclusively recycled gold. In 2023, we expanded our use of certified recycled gold to the USB-C connector plating as well as the wire of all cameras in the iPhone 15 family, along with printed circuit boards across Apple products, including the latest iPhone, Apple Watch, Mac family, and MacBook Pro.

We continued to work with sustainability nonprofit RESOLVE to fund the Regeneration project, which focuses on re-mining and processing waste material from legacy mines to restore natural environments and support rehabilitation and biodiversity. Regeneration is an expansion of the Salmon Gold project, which we continued to fund and scale with RESOLVE in 2023. The Salmon Gold project works with small-scale miners and Indigenous Peoples in remote regions of the Yukon, Alaska, and British Columbia to support a mining practice that helps restore rivers and streams so that salmon and other fish can thrive. Since RESOLVE first introduced the Salmon Gold project in 2017, the organization has connected local placer miners, environmentalists, and government agencies to mitigate the damage done by historic mining activities.

The gold mined from this project is then traced from its origin to a refiner in Apple’s supply chain using blockchain technology. Apple believes that blockchain solutions are a tool to support — but not replace — supply chain due diligence. The interests of people working at the mining level and in surrounding communities should be taken into consideration when utilizing new technologies such as blockchain. As the use of new technologies increases, our goal is to ensure that data captured contributes to positive impacts along the supply chain.

Apple believes that the lessons learned from these programs will help support further innovation across the supply chains of additional minerals.

Since 2015, we have continued to reach a 100 percent rate of participation in independent third-party audit programs by identified 3TG smelters and refiners in our supply chain. Apple requires certification from the RMI’s RMAP or the LBMA’s Responsible Gold Program for 3TG smelters and refiners in our supply chain.

Apple believes independent third-party audits remain foundational to robust due diligence systems. In particular, third-party audits play a significant role in providing assurance that smelters and refiners have appropriate due diligence systems in place while helping to confirm that operations and sourcing practices are aligned with the OECD Due Diligence Guidance and do not support conflict, including in the DRC or adjoining countries.

In addition to smelter and refiner audits, part of Apple's supplier engagement program and Code assessment process includes working with an independent audit firm to conduct specialized responsible sourcing audits of select suppliers in order to have a deeper review of their internal management systems and implementation of Apple's requirements related to 3TG and other minerals. At the end of an Apple-managed assessment or specialized audit, the supplier is given a list of areas to strengthen with regard to the Code and Responsible Sourcing Standard, and the supplier is required to correct any identified nonconformances in a timely manner.

Apple reports annually on its due diligence requirements through its Conflict Minerals Report filed with the U.S. Securities and Exchange Commission. Apple also publishes a list of all identified 3TG, cobalt, and lithium smelters and refiners in its supply chain, 100 percent of which participated in independent third-party audits as of December 31, 2023, and publishes its Supplier List based on direct spend for materials, manufacturing, and assembly of Apple products worldwide.⁴ In addition, we publish the following:⁵

As of December 31, 2023, based on our due diligence efforts, including the information provided by our suppliers, Apple believes that the smelters and refiners listed in Annex I were used to process 3TG in our products at some point during 2023. Through our smelter and refiner identification and validation process, we have identified a total of 235 smelters and refiners that processed 3TG in our supply chain during 2023. Of these 235 smelters and refiners, 221 remained in Apple's 3TG supply chain as of December 31, 2023. 14 were removed for the following reasons: those that previously participated in but subsequently stopped participating in an independent third-party audit program; were not willing to participate in an independent third-party audit within given timelines; exceeded independent third-party audit corrective action plan timelines; or failed to meet Apple’s Code, Responsible Sourcing Standard, or 3TG mineral requirements.

Of all 221 smelters and refiners of 3TG determined to be in our supply chain as of December 31, 2023, Apple found no reasonable basis for concluding that any such smelter or refiner sourced 3TG that directly or indirectly financed or benefited armed groups in the DRC or an adjoining country.

This report has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2023 to December 31, 2023. Information contained on the websites referenced in this report is not part of, or incorporated by reference into, this filing. Information presented in this report is based on calendar years.

Apple believes it constitutes a “downstream” company in that Apple’s suppliers purchase cassiterite, columbite-tantalite (“coltan”), wolframite, gold, or their derivatives, which presently are limited to tin-, tungsten-, tantalum-, and gold-related materials after processing by smelters or refiners. Apple does not directly purchase or procure primary sourced minerals from mine sites.

This report relates to the process undertaken in accordance with OECD Due Diligence Guidance for Apple products that were manufactured, or contracted to be manufactured, during 2023 and that contain 3TG. These product categories are iPhone^®, Mac^®, iPad^®, AirPods^®, Apple TV^®, Apple Watch^®, Apple Vision Pro^TM, Beats^® products, HomePod^®, HomePod mini^®, Apple Card^®, and all Apple^® accessories. Third-party products that Apple retails but does not manufacture or contract to manufacture are outside the scope of this report.

The smelters and refiners identified in this report include those producing inputs for service or spare parts contracted for manufacturing in 2023 for use in connection with the subsequent service of previously sold products, including products serviced in subsequent years using those parts. This report does not include smelters of tin, tungsten, or tantalum or refiners of gold where such 3TG are included in end-of-life service parts for products that Apple no longer manufactures or contracts to manufacture.

This report’s use of the terms “smelters” and “refiners” refers to the facilities processing primary 3TG to retail purity. Apple suppliers have in some cases reported smelters and refiners that Apple believes are not operational or may have been misidentified as smelters and refiners. As a result, Apple continues to work with the RMI to determine accurate operational status of the smelters and refiners and to work with suppliers throughout its supply chain to revalidate, improve, and refine their reported information, taking into account supply chain fluctuations and other changes in status or scope and relationships over time. “Identified” smelters and refiners are those that (i) have been reported in a supplier’s CMRT, (ii) Apple believes are currently operational, were operational at some point during the applicable year, or, while inoperative, capable of re-engagement with minimal delay or effort, and (iii) otherwise meet the definition of a smelter or refiner, provided that Apple may determine to treat a third party as an identified smelter or refiner notwithstanding a reclassification of such third party or a change in its status. As part of its reasonable country of origin inquiry, Apple has determined that certain suppliers are utilizing at least some 3TG from secondary materials (i.e., scrap or recycled materials). Facilities that process only secondary materials (i.e., scrap or recycled materials) are excluded from the scope of this report.

Participating smelters and refiners are those that have agreed to participate in or have been found compliant with independent third-party conflict minerals audit programs confirming their 3TG sourcing practices. Such programs may also include audits of traceability requirements, conformity with the OECD Due Diligence Guidance, management systems, and/or risk assessments. Independent third-party 3TG audit programs include the RMI’s RMAP and the LBMA’s Responsible Gold Program. Throughout this report, the audits by these programs are included in references to “independent third-party audit” programs.

ANNEX I: Smelter and Refiner List

List of identified smelters and refiners of 3TG reported in Apple’s supply chain as of December 31, 2023.

* The smelter/refiner is believed to process at least some 3TG from recycled or scrap sources.

** The smelter/refiner has changed its compliance or operational status since December 31, 2023.

*** The smelter/refiner continues to be in the process of removal as of the filing of this report and/or is no longer approved to be in Apple’s supply chain.

* The DRC or an adjoining country.