Kimball Electronics Inc.

05/20/2026 | Press release | Distributed by Public on 05/20/2026 13:17

Specialized Disclosure Report (Form SD)


CONFLICT MINERALS REPORT OF KIMBALL ELECTRONICS, INC.
For the reporting period from January 1, 2025 to December 31, 2025
As used herein, the terms "Company," "Kimball Electronics," "we," "us," or "our," refer to Kimball Electronics, Inc., the Registrant, and its subsidiaries.
This Conflict Minerals Report (the "Report") of Kimball Electronics, Inc. has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the "Rule") promulgated under the Securities Exchange Act of 1934, as amended (the "1934 Act"), for the reporting period from January 1, 2025 to December 31, 2025 (the "Reporting Period"). Numerous terms in this Report are defined in Rule 13p-1 and Form SD and the reader is referred to those sources and to 1934 Act Release No. 34-67716 (August 22, 2012) for such definitions.
This Report has not been audited nor is an independent private sector audit required for this Report under the Rule or existing SEC guidance.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products ("Necessary Conflict Minerals"). The specified minerals, which we collectively refer to in this Report as the "Conflict Minerals," are gold, columbite-tantalite (coltan), cassiterite, and wolframite, including their derivatives, which are limited to tantalum, tin, and tungsten. The "Covered Countries" for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola. The reporting requirements of the Rule apply to us regardless of the geographic origin of our Necessary Conflict Minerals and whether or not such Necessary Conflict Minerals fund Armed Groups (as that term is defined by the Rule).
Company and Responsible Sourcing Overview
Kimball Electronics was founded in 1961 and incorporated in 1998. We deliver a package of value that begins with our core competency of producing durable electronics. We further offer contract manufacturing organization solutions which include operations such as precision molded plastics, complete device assembly, and cold chain management. Our design and manufacturing expertise coupled with robust processes and procedures help us ensure that we deliver the highest levels of quality, reliability, and service throughout the entire life cycle of our customers' products.
We manufacture or contract to manufacture many products that use Necessary Conflict Minerals. We are considered a "downstream" company, as described by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (the "OECD Guidance"). We primarily purchase component parts and generally do not purchase raw ore or unrefined Conflict Minerals. We are far removed from the mines, smelters, and refiners in our global supply chain. We source components and materials from suppliers, who source their components and materials from other, sub-tier suppliers. In addition, many of our customers require us to use their selected suppliers when manufacturing their products. We may not have direct contractual relationships with these customer-selected suppliers.
We believe that the smelters and refiners of the Conflict Minerals are best situated to identify the source of Conflict Minerals, and therefore have taken steps to identify the applicable smelters and refiners of Conflict Minerals in our supply chain. In accordance with the OECD Guidance, the internationally recognized framework on which our Company's Responsible Sourcing Policy is based, we support industry initiatives that audit Conflict Minerals smelters' and refiners' Due Diligence activities, primarily through our memberships in the Responsible Minerals Initiative ("RMI") and the Responsible Business Alliance ("RBA"). The data on which we relied for certain statements in this Report was obtained through our RMI membership. We set forth our expectations of our suppliers in our Sustainability Policy and our Supplier Code of Conduct. More information is available on our website at: https://www.kimballelectronics.com/sustainability. The content of, or accessible through, our website is not incorporated by reference into this Form SD or this Conflict Minerals Report and should not be considered part of this filing.
Description of Our Products Covered by this Report
We have determined that we manufacture or contract to manufacture products containing Necessary Conflict Minerals. This Report relates to our products: (i) that contain Necessary Conflict Minerals; (ii) that we manufactured or were contracted to manufacture; and (iii) that we produced during the Reporting Period (the "Covered Products").
Our Covered Products consist of a broad and diverse range of electronic assemblies and other products including medical devices, medical disposables, and precision molded plastics primarily in automotive, medical, and industrial applications, to the


specifications and designs of our customers. As a contract manufacturer, the specific products we produce vary based on customer specifications and programs.
The Company's Reasonable Country of Origin Inquiry Process and Results
As noted above, we determined that certain of our products covered by this Report during the Reporting Period contained Necessary Conflict Minerals. Because of this determination, the Rule requires us to conduct, in good faith, a Reasonable Country of Origin Inquiry ("RCOI") of our Necessary Conflict Minerals. We design the RCOI to determine whether any of the Necessary Conflict Minerals in our Covered Products originated or may have originated in a Covered Country or came from recycled or scrap sources.
If, based on our RCOI, we know, or have reason to believe, that (i) any of our Necessary Conflict Minerals originated in a Covered Country and (ii) such Necessary Conflict Minerals may not be from recycled or scrap sources, the Rule requires that we exercise Due Diligence on the source and chain of custody of those Necessary Conflict Minerals, in accordance with a nationally or internationally recognized Due Diligence framework, if such a framework is available for the particular Conflict Mineral. The Rule also describes further actions that we must take based on the results of our Due Diligence on the source and chain of custody of Conflict Minerals.
For Covered Products, we utilized the Responsible Minerals Initiative's ("RMI") Conflict Minerals Reporting Template ("CMRT") to request information from the suppliers we identified in our supply chain assessment about the sources of the Necessary Conflict Minerals in the products they supply to us. After collecting responses to our supplier inquiries, we evaluated the responses for completeness and plausibility, and we engaged in follow-up communications with suppliers as appropriate. Some suppliers provided us with "company-level" CMRT responses that include Conflict Minerals information for all products sold by that supplier to its customers even though we may have purchased only a limited subset of such products from that supplier.
Based on our RCOI described above, we have reason to believe that some of these Conflict Minerals may have originated from the Covered Countries and may not be from recycled or scrap sources.
Our Due Diligence Process
Based on the results of our RCOI, and as required by the Rule, we conducted Due Diligence on the source and chain of custody of our Necessary Conflict Minerals ("Due Diligence") to ascertain whether these Conflict Minerals originated in the Covered Countries and finance or otherwise benefited Armed Groups.
Design of Our Due Diligence Framework
As required by the Rule, we designed our Due Diligence to conform, in all material respects, with the Due Diligence framework set forth in the OECD Guidance as a basis for responsible supply chain management of all minerals and as applicable to downstream companies (as the term is defined in the OECD Guidance). The design of our Due Diligence incorporates the OECD Guidance's five-step framework:
1.Establish strong company management systems.
2.Identify and assess risk in the supply chain.
3.Design and implement a strategy to respond to identified risks.
4.Carry out independent third-party audits of smelters'/refiners' Due Diligence practices by participating in industry-driven initiatives.
5.Report annually on supply chain Due Diligence.
Due Diligence Activities Performed
For the Reporting Period, as part of our Due Diligence we surveyed approximately 2,915 direct suppliers of components who potentially contributed Necessary Conflict Minerals for the Covered Products, representing 100% of our direct suppliers relevant for Conflict Minerals inquiry for the Reporting Period. We requested that each of them complete version 6.5 of the RMI CMRT released in April 2025. As with our RCOI, we used the CMRT responses to collect information regarding the sources of the Necessary Conflict Minerals in the products they supplied to us, including the processing smelters and refiners ("SORs") and countries and mines of origin of such Conflict Minerals from our direct suppliers and in their supply chains. We review the CMRT responses for completeness, internal consistency, plausibility, smelter/refiner identification, RMI CID validity, RMAP status, and apparent inconsistencies regarding mineral content, recycled or scrap sourcing, and reported countries of origin. To the extent possible, we followed up with direct suppliers who did not respond to our survey or who provided incomplete or inconsistent information. For example, we followed up with suppliers surveyed to collect or correct missing and inconsistent information, implausible statements regarding the presence of Conflict Minerals, responses that did


not identify SORs, and where the reported sourcing country is not a known reserve for the specified Conflict Mineral. We compared the smelter information provided by our direct suppliers in our supply chain surveys to multiple sources including the CMRT's Smelter Reference List and the Conformant and Active Smelter & Refiner Lists from RMI. We followed up with direct suppliers who indicate high risk smelters in their supply chain via their CMRT as appropriate to request additional data analysis and verification.
If a supplier did not provide the information requested, we initiated an escalation process. The escalation process included contacting alternate persons at the supplier, enlisting help from our manufacturing locations engaged with the supplier, obtaining assistance from our global sourcing team, and working with our customers to contact the suppliers. Of the suppliers we surveyed, approximately 69.16% responded to the survey with reliable responses, representing approximately 87.82% of the total number of unique in-scope parts purchased and 85.21% of our direct materials spend on in-scope parts for the Reporting Period. We are retaining supporting documentation regarding our Due Diligence for the Reporting Period in accordance with our data retention policy.
Company Level Grievance Mechanism
As an additional means of communication regarding Conflict Minerals, our employees and other stakeholders can escalate concerns using an anonymous, confidential, third-party ethics "hotline" reporting system. This can be accessed 24 hours a day, 7 days a week at https://hotline.kimballelectronics.com, as outlined in our Code of Conduct.
In addition, Due Diligence that we performed during the Reporting Period included the following:
•Our internal compliance team that conducts Due Diligence reported progress directly to our Chief Legal & Administrative Officer and executive leadership team, as well as to leaders throughout our global procurement, manufacturing, quality, and finance functions.
•We conducted training to educate our compliance team and our other internal teams on the requirements of the Rule.
•We communicated our Sustainability Policy and our Supplier Code of Conduct to our customers and suppliers along with our expectations under those Policies.
•We worked with our suppliers and our customers to seek remedies for non-compliance, identified risks, or inconsistencies in accordance with our Responsible Sourcing Policy.
•We continued to embrace and support industry initiatives that audit Conflict Minerals smelters' and refiners' Due Diligence activities, since we generally do not have direct contractual relationships with the originating mines, or with the smelters or refiners of the Conflict Minerals that our products contain.
•We reported to our Board of Directors the results of our Due Diligence processes and activities.
Our Due Diligence Determination
Based on our Due Diligence, we were unable to determine whether the Necessary Conflict Minerals contained in such products (not including Conflict Minerals that originated from recycled or scrap sources) originated in the Covered Countries, or, if they did originate in the Covered Countries, whether the mining of or trade in such Conflict Minerals directly or indirectly finance or otherwise benefit Armed Groups.
Smelters and Refiners; Countries of Origin of Conflict Minerals
The declarations we received from our suppliers described above include a total of 563 SORs that processed Conflict Minerals used in the production of such suppliers' products. Among these 563 SORs provided in the declarations, 234 either have been certified as conformant with the Responsible Minerals Assurance Program's ("RMAP") (formerly known as the Conflict-Free Smelter Program) assessment protocols ("RMAP Conformant") or have committed to undergo a RMAP audit ("RMAP Active"), per the current version of the CMRT. The remaining SORs were listed on the Smelter Look-up list tab of the current version of the CMRT, but are not listed as "Conformant" or "Active." The RMI website notes that, due to the eligibility criteria for an RMAP assessment, smelters and refiners are sometimes removed from the Conformant list because they are no longer operational and not because they are non-conformant to the standard.

Additionally, many of the declarations we receive are company-wide and not product specific, so we believe these declarations may include SORs and countries of origin for Conflict Minerals that are not applicable to the Conflict Minerals used in our products. The inclusion of a SOR in a country on the list from RMI is not a final indicator that the Company utilized materials sourced from a SOR in this country. Due to the many such company-wide declarations and the multiple levels of suppliers in our supply chain, we are unable to determine with certainty at this time which SORs, which facilities, which countries of origin, or which mines or locations of origin listed in the declarations actually provide the specific Conflict Minerals used in our products.



The SORs identified by our suppliers in their declarations are set forth in the Appendix to this Report.
Steps Taken and Being Taken to Mitigate Risk
We have taken or are taking the following steps, among others, to mitigate the risk that our Necessary Conflict Minerals benefit Armed Groups and to improve the results of our Due Diligence measures:

•We communicate our Sustainability Policy and our Supplier Code of Conduct to our customers and suppliers along with our expectations under that Policy;
•We improve the efficiency and quality of our supplier onboarding, outreach, and education;
•We engage with suppliers to obtain updated, accurate, and complete information about our supply chain;
•We actively support industry initiatives to encourage smelters and refiners to participate in audits of their Conflict Minerals Due Diligence activities;
•We send requests when appropriate to certain high risk smelters to provide Country of Origin information;
•We reconsider our partnerships with suppliers who do not comply with our Responsible Sourcing Policy;
•We cooperate with industry groups seeking to identify best practices for a good faith RCOI and related Due Diligence; and
•We encourage suppliers to implement responsible sourcing and effective traceability measures.
Kimball Electronics Inc. published this content on May 20, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 20, 2026 at 19:17 UTC. If you believe the information included in the content is inaccurate or outdated and requires editing or removal, please contact us at [email protected]