05/22/2026 | Press release | Distributed by Public on 05/22/2026 11:00
Strattec Security Corporation
Conflict Minerals Report
For The Year Ended December 31, 2025
This Conflict Minerals Report ("CMR") for Strattec Security Corporation (the "Company", "Strattec", "we", or "us") covers the reporting period from January 1, 2025 to December 31, 2025, and is filed in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("SEC Rule") and the requirements of Form SD.
The SEC Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting requirements related to conflict minerals, defined by the SEC as columbite-tantalite ("coltan"), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten ("3TG"), and any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country ("Covered Countries"). The SEC Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of said products.
This CMR is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD.
Introduction
Strattec designs, develops, manufactures, and markets automotive security, access control, and user interface controls products and solutions.
Our supply chain is a broad and complex global network of tiered suppliers that directly or indirectly supply raw materials, components, and services to our global facilities. There may be multiple tiers of suppliers between the smelters or refiners that process 3TG and the first-tier (i.e., direct) suppliers that deliver components, parts, and raw materials to us. Accordingly, we rely on the suppliers with whom we have direct contracts to provide information on the origin of, and the facilities used to process, the 3TG contained in the components, parts, and raw materials supplied to us.
We conducted an internal assessment of our product materials and concluded that 3TG may be found in various components, parts, and raw materials used in the manufacture of our products. Applicable products include electronic control modules, printed circuit board assemblies, electric motors, electric actuators and electrical clutches, switches and solenoids, metallic inserts and metal fasteners and terminals, coatings on metal parts, and raw metal steel strips with tin coating (collectively, "Company Products").
Reasonable Country of Origin Inquiry
For our reasonable country of origin inquiry ("RCOI"), we developed a targeted list of our first-tier (i.e. direct) suppliers that we believe provide products that may contain 3TG which are necessary to the functionality or production of Company Products. We identified these suppliers based on information in the International Material Data System and from information previously provided by suppliers regarding conflict minerals.
We then used the Conflict Minerals Reporting Template ("CMRT"), a standardized industry reporting template developed by the Responsible Minerals Initiative, to obtain information from these suppliers regarding the facilities used to process the necessary 3TG and the country of origin of such minerals. To obtain relevant information for Strattec's products, we requested that our direct suppliers cascade these CMRT reporting requirements through their supply chains to the mineral processors.
For 2025 we received a completed CMRT from 100% of the fifty-two direct suppliers identified through our analysis of data in the International Material Data System. The CMRT responses identified six smelters or refiners that have sourced or are sourcing from a Covered Country. All six of these smelters or refiners were conformant to the Responsible Minerals Assurance Process.
Based on these findings, Strattec performed a reasonable country of origin inquiry and due diligence measures on the source and chain of custody of the 3TG contained in the components, parts, and raw materials supplied to us.
Due Diligence
Our due diligence process has been designed to conform, in all material respects, to the framework provided by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas, Third Edition and the related supplements for Tin, Tantalum, Tungsten and Gold (collectively, the "OECD Guidance").
The following sections describe how each step of this framework was implemented, demonstrating Strattec's policies, procedures, and activities during the year, structured in accordance with the five-step framework detailed in the OECD Guidance.
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(4) Carry out independent third-party audit of supply chain due diligence: Because we do not have a direct relationship with 3TG smelters and refiners, we do not perform direct audits of those entities within our supply chain.
(5) Reporting on Strattec's supply chain due diligence process. Strattec is committed to annual reporting of its conflict minerals due diligence.
The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.
Determination
With respect to 2025, Strattec had 350 direct suppliers. Of those, 52 direct suppliers were identified through our analysis of data in the IMDS stating that they may contribute necessary conflict minerals to our products. The overall response rate to the IMDS identified suppliers was 100%. In response to our supply-chain survey, our suppliers identified 129 operational smelter or refinery facilities which may process the necessary Conflict Minerals contained in the materials and components provided to Strattec. Of those facilities, as of December 31, 2025:
Based on our good faith efforts, we are unable to determine origin of all the 3TG used in Company Products. Despite our good faith efforts and due diligence, we are unable to conclude with certainty the origin of the conflict minerals contained in the products we manufacture, remanufacture, and contract to manufacture, or procure via distributors. We have not concluded that we manufacture or contract to manufacture products that are DRC conflict free. Accordingly, we have not obtained an independent private sector audit. The uncertainty creates residual risks in our supply chain, which we have carried forward for continued due diligence.
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Because most of the information we received from our direct suppliers in our due diligence processes was reported at an "enterprise" or corporate level, and because the quality of the responses we received varied, we are unable to determine whether the 3TG reported by our suppliers was present in the actual components or materials supplied to us, or to validate that any of these smelters or refiners are actually in our supply chain. As a result, we are not providing an aggregated list of the smelters and refiners in our supply chain or an aggregated list of the potential countries of origin from which those smelters and refiners collectively source 3TG.
Our efforts to determine the mine or location of origin of the necessary Conflict Minerals in our products that are DRC conflict undeterminable with the greatest possible specificity consisted of the due diligence measures described in this Report.
Planned Risk Mitigation Steps
The due diligence process discussed above is an ongoing and evolving process. We intend to continue to implement and improve the due diligence measures described above, in addition to continuing to engage with suppliers and direct them toward training resources to increase our response rate and improve the content of supplier responses to our inquiries concerning 3TG. We believe these efforts will mitigate the risk that the necessary 3TG in our products could benefit armed groups in the Covered Countries.