Glaukos : 2024 Form SD and Conflict Minerals Report

Published: 2025-06-01 20:50:44 ET GKOS

Published on 06/01/2025 at 20:50

FORM SD

Specialized Disclosure Report

Glaukos Corporation

(Exact name of registrant as specified in its charter)

Delaware

001-37463

33-0945406

(State or other jurisdiction

(Commission

(I.R.S. Employer

of incorporation)

File Number)

Identification No.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in the form applies:

☒ Rule 13 p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2024

◻ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .

Item 1.01 Conflict Minerals Disclosure and Report

This Specialized Disclosure Report on Form SD of Glaukos Corporation ("Glaukos" or the "Company" or "we" or "our") for the reporting period from January 1, 2024 to December 31, 2024 is submitted to comply with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"). Rule 13p-1 was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to "Conflict Minerals" as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (together with Rule 13p-1, the "Conflict Minerals Rule").

The description of the Company's reasonable country of origin inquiry ("RCOI") process, the results of our inquiry, and the determination we reached as a result of the RCOI are included in the Company's Conflict Minerals Report, attached as an exhibit to this Form SD.

This Form SD and our Conflict Minerals Report, filed as an Exhibit to this Form SD, are publicly available on Glaukos' Internet website under the "Investors" heading, which can be reached through the following link: https://http://investors.glaukos.com/investors/corporate-governance/Corporate-Responsibility/default.aspx. The content of any website referred to in this Form SD or the related Conflict Minerals Report is included for general information only and is not incorporated by reference in this Form SD or the related Conflict Minerals Report.

Item 1.02 Exhibit

The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

Item 3.01 Exhibits

The following exhibit is filed as part of this report.

1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

(Registrant)

By: /s/ Robert L. Davis Name: Robert L. Davis

Title: Senior Vice President, General Counsel &

Business Development

Date: May 30, 2025

Glaukos Corporation ("Glaukos," "the Company," "we," "our," and "us") has filed this Conflict Minerals Report ("CMR") for the year ended December 31, 2024 to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission ("SEC") issuers whose manufactured products contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten ("3TG" or "Conflict Minerals"). The Rule focuses on 3TG emanating from the Democratic Republic of Congo ("DRC") region and nine adjoining countries (together, the "Covered Countries"). If any Conflict Minerals contained in an issuer's manufactured products that are necessary to the functionality or production of such products may have originated in the Covered Countries, or if the issuer is unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals' source and chain of custody and submit a CMR to the SEC that includes a description of those due diligence measures.

This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, the Company's risk mitigation and improvement plans may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to conflict minerals; (b) the ability of our suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and we assume no obligation to update such statements.

The statements included in this Conflict Minerals Report are based on the Reasonable Country of Origin Inquiry process and due diligence performed in good faith by Glaukos. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect the accuracy of these statements. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules,

(iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) some suppliers and smelters are unfamiliar with the diligence process and information required to be provided, which could lead to inaccurate or incomplete responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in conflict-free smelter audits, (xi) materials sourced from the Covered Countries could be inaccurately declared as sourced from outside the Covered Countries, (xii) illegally tagged Conflict Minerals could be introduced into the supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business, and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult.

Introduction

Glaukos is an ophthalmic pharmaceutical and medical technology company focused on developing and commercializing novel therapies for the treatment of glaucoma, corneal disorders, and retinal disease. We first developed Micro-Invasive Glaucoma Surgery (MIGS) as an alternative to the traditional glaucoma treatment paradigm, launching our first MIGS device commercially in 2012, and continue to develop and advance a portfolio of novel, dropless platform technologies designed to meaningfully advance the standard of care and improve outcomes for patients suffering from chronic, sight-threatening diseases across the areas of glaucoma, corneal disorders such as keratoconus and dry eye, and retinal diseases. We have designed commercial and development-stage solutions to provide ophthalmologists with new treatment alternatives.

This CMR relates to the process undertaken for Glaukos products that were manufactured, or contracted to be manufactured, for commercial use during calendar year 2024 and that contain Conflict Minerals.

Executive Summary

We performed a Reasonable Country of Origin Inquiry ("RCOI") on our suppliers, including those we believe provided materials or components containing 3TGs necessary to the manufacturing of our commercial products during calendar year 2024. Our due diligence process included contacting each supplier requesting conflict minerals data using the Conflict Minerals Reporting Template ("CMRT"); 93% of these suppliers responded to our inquiries. Our suppliers identified 340 valid smelters and refineries ("Smelters"). Of these 340 Smelters, we identified 49 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Our due diligence review indicated that 34 of these Smelters have been audited and recognized as conformant to the Responsible Minerals Assurance Process ("RMAP"). This process was in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance"). Glaukos conducted risk mitigation on the remaining 15 Smelters. Based on this risk mitigation process, we believe that we do not purchase any products containing 3TG from the suppliers associated with two of the 15 high-risk Smelters.

Company Management Systems

Glaukos established strong management systems based on Step 1 of the OECD Guidance.

Step 1A - Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. We have adopted a conflict minerals policy as part of our Supplier Code of Conduct and Conflict Minerals Policy that is publicly available on our Investor website under the heading "Corporate Responsibility" at https://http://investors.glaukos.com. The Supplier Code of Conduct and Conflict Minerals Policy is communicated directly to our suppliers as part of the RCOI process.

Step 1B - Structure internal management to support supply chain due diligence. We maintain a cross-functional internal team to support our supply chain due diligence efforts. This team reports its findings to a senior member of the supply chain management organization.

Step 1C - Establish a system of transparency, information collection and control over the supply chain. We implemented a detailed process to collect required supplier and smelter RCOI and due diligence data. Full details on the supply chain data gathering are included in the RCOI and due diligence sections of this Report.

Step 1D - Strengthen company engagement with suppliers. We engage directly with suppliers during the RCOI process. Additionally, we have updated the terms and conditions that will apply to our

Disclaimer

Glaukos Corporation published this content on June 01, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on June 02, 2025 at 00:48 UTC.