Spectrum Brands : 2025 Conflict Minerals Report

Published: 2025-07-02 12:09:11 ET SPB

Published on 07/02/2025 at 12:09

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☒ Rule 13p-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 September 30, 2024.

RG Draft 5.27.25

As contemplated by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report for the reporting period from January 1 to December 31, 2024 is provided as an Exhibit to this Form SD and is available on our website at https://spectrumbrands.com/about-us/our-company/global-sustainability-statement.html.

Our website is not incorporated by reference and should not be considered part of this Form SD or our Conflict Minerals Report.

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

Not applicable Section 3 - Exhibits Item 3.01. Exhibits

The following exhibit is filed as part of this report:

Conflict Minerals Report pursuant to Items 1.01 and 1.02 of this Form.

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 duly authorized undersigned.

SPECTRUM BRANDS HOLDINGS, INC. SB/RH HOLDINGS, LLC

By: /s/ Ehsan Zargar Date: May 30, 2025 Name: Ehsan Zargar

Title: Executive Vice President, General Counsel, and Corporate Secretary

This is the Conflict Minerals Report of Spectrum Brands Holdings, Inc. and its consolidated subsidiaries, including SB/RH Holdings, LLC and its consolidated subsidiaries (the "Company," "Spectrum Brands," "we," "us," or "our"), for January 1, 2024 through December 31, 2024 ("Calendar Year 2024") in accordance with Rule 13p-1 ("Rule 13p-1") under the Securities Exchange Act of 1934, as amended (the "1934 Act"). As used herein, "Conflict Minerals" or "3TG" is defined as, consistent with the Conflict Minerals Rule, cassiterite, columbite-tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten. Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions of the other terms used in this Report, unless otherwise defined herein.

The Securities and Exchange Commission's (the "SEC") conflict minerals rule requires a three-step compliance approach. The first step is determining applicability of the conflict minerals rule to Spectrum Brands; the second step is a reasonable country of origin inquiry ("RCOI") to determine whether we have reason to believe that conflict minerals from the Democratic Republic of the Congo (the "DRC") or adjoining countries (the "Covered Countries") that are necessary to the functionality or production of products manufactured by us, or contracted to be manufactured by us, are present in our products; and the third step (referred to as "due diligence" in the SEC rule) is to determine the source and origin of any such conflict minerals and the facilities in which they were processed.

As a downstream company, Spectrum Brands is several tiers removed from mining operations and smelters or refiners ("SORs") in dealing with its direct suppliers. Spectrum Brands hired a third-party provider to assist it in performing conflict mineral supply chain due diligence (the "Provider"). Using our Provider as well as our supply chain due diligence processes and focusing on accountability within the supply chain by using the industry standard Responsible Minerals Initiative's ("RMI") Conflict Minerals Reporting Template ("CMRT") and reaching out to our suppliers, we seek to gain greater transparency in our supply chain. Certain of the activities described below were performed by the Provider on our behalf.

As an initial matter, Spectrum Brands considered whether conflict minerals were necessary to the production or functionality of its products. In conducting its due diligence, Spectrum Brands implemented the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Framework"), an internationally recognized due diligence framework, and related supplements for each of the conflict minerals. Accordingly, the steps taken by Spectrum Brands in preparing this Conflict Minerals Report were in accordance with the OECD Framework. As such, we used the RMI's CMRT, which includes standard supply chain survey and information tracking methods, as part of: (i) determining if our manufactured products contained conflict minerals necessary to their functionality or production,

(ii) performing a RCOI to determine whether such minerals originated in the DRC or a Covered Country, or are from recycled or scrap sources, and (iii) assessing our supply chain's adherence to due diligence measures stated by the OECD Framework.

Our Steering Committee reviewed the products manufactured or contracted to be manufactured by the Company in order to determine which products might contain conflict minerals that are necessary to their functionality or production; the list of products is contained on Attachment A to this Conflict Minerals Report. The Company conducted this review at a product level. A list of the suppliers determined to be in-scope for purposes of the conflict minerals rules was compiled and the RCOI was conducted as follows:

Spectrum Brands sent initial inquiries to 78 suppliers and instructed them to complete the CMRT and return it to Spectrum Brands.

For 2024, Spectrum Brands hired the Provider to engage its suppliers to collect information about the presence and sourcing of conflict minerals used in the products and components supplied to Spectrum Brands in the Calendar Year 2024 and by doing so add more transparency to Spectrum Brands' supply chain with the ultimate goal of identifying the related smelters or refiners and associated mine countries of origin.

Spectrum Brands or the Provider conducted follow-up inquiries of the initially unresponsive suppliers.

Spectrum Brands or the Provider also conducted follow-ups with suppliers for further information if initial responses were incomplete or unclear.

Spectrum Brands or the Provider performed follow-ups with suppliers who returned an incomplete CMRT; all issues were addressed.

The Provider also evaluated the completed CMRTs for plausibility, consistency and gaps. Additional supplier contacts were conducted to attempt to resolve "quality control" flags, such as:

(a) SORs were not provided for a used metal, (b) the supplier listed one or more SORs for an unused metal, (c) the supplier indicated that it had not identified all SORs for the in-scope products, (d) the supplier indicated it had not received conflict minerals data for each metal from all of its relevant suppliers, or (e) the supplier indicated that all of its conflict minerals were from recycled or scrap sources, but one or more of the SORs listed are not known to be exclusive recyclers.

After follow-up, Spectrum Brands had a 65% supplier response rate for those suppliers indicating that one or more of the conflict minerals are necessary to the functionality or production of the products they supply to Spectrum Brands.

Steps Taken to Establish Strong Company Management Systems

Spectrum Brands continued disseminating conflict minerals information and updates internally through its Steering Committee, which implements and manages Spectrum Brands' conflict minerals compliance program.

Spectrum Brands is committed to sourcing components and materials from companies that share its values about human rights, ethics and environmental responsibility. Spectrum Brands' employees and the Steering Committee continue to enforce its Conflict Minerals Policy, which is available on the Company's website at https://spectrumbrands.com/about-us/our-company/corporate-compliance/conflict-minerals.html. As required by our Conflict Minerals Policy, all of our suppliers are required to sign Spectrum Brands' Supplier Code of Conduct, which includes requirements relating to conflict minerals and responsible sourcing. A copy of Spectrum Brands' Supplier Code of Conduct can be found at https://www.spectrumbrands.com/about-us/suppliers/supplier-code-of-conduct.html. Spectrum Brands' Supplier Code of Conduct (the "Code") incorporates requirements related to conflict minerals so that current and future suppliers are obligated to comply with Spectrum Brands' policies on conflict minerals, including participation in related due diligence activities.

Spectrum Brands educates its relevant employees and, in addition the Steering Committee, disseminates conflict minerals information through sourcing leads, supply chains, and sales forces.

Spectrum Brands maintains a grievance mechanism to enable the reporting of grievances related to conflict minerals and other supply chain matters.

Disclaimer

Spectrum Brands Holdings Inc. published this content on July 02, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on July 02, 2025 at 16:08 UTC.