06/01/2026 | Press release | Distributed by Public on 06/01/2026 14:32
Conflict Minerals Report of RH
For the Calendar Year Ended December 31, 2025
I.Introduction
1.Overview of our Conflict Minerals Report
This Conflict Minerals Report of RH (the "Company," "we," "us" or "our") is prepared in accordance with Rule 13p-1 (the "Rule") under the Securities Exchange Act of 1934, as amended (the "Exchange Act"), for the reporting period from January 1, 2025 to December 31, 2025 (the "reporting period"). RH is inclusive of its wholly-owned subsidiary Restoration Hardware, Inc. and its subsidiaries, including, but not limited to, the subsidiary that owns the business operating under the name "Waterworks." The information provided in this Conflict Minerals Report on behalf of RH is inclusive of Waterworks, its products and supply chain.
The Rule requires issuers that manufacture or contract to manufacture products that contain conflict minerals that are necessary to the functionality or production of those products to, among other things, disclose annually whether any of those conflict minerals originated in the Covered Countries (defined below) and, if so, to submit a report to the Securities and Exchange Commission (the "SEC") that includes a description of the measures they took to exercise due diligence on the conflict minerals' source and chain of custody. Conflict minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite and their derivatives, which are limited to tantalum, tin and tungsten (collectively, the "conflict minerals"). The "Covered Countries" for purposes of the Rule are the Democratic Republic of the Congo (the "DRC"), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
2.Overview of our Supply Chain, Verification Process and Conflict Minerals Policy
During the reporting period, RH did not own or operate any manufacturing facilities that manufacture products that contain conflict minerals that are necessary to the functionality or production of those products. Instead, RH contracted and had relationships with third-party suppliers who manufacture products for RH that contain conflict minerals that are necessary to the functionality or production of those products. These products that the Company "contracts to manufacture," as such term is referred to by the Rule, are herein referred to as the "Subject Products." The Subject Products are manufactured for the Company through such suppliers' own factories or factories with which such suppliers have commercial relationships. The Company must therefore rely on its third-party suppliers to provide information regarding the existence of conflict minerals in the Subject Products and their origin.
The Company relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from the smelters or refiners who may provide those minerals to companies in our supply chain. The Company is many steps removed from the mining of conflict minerals. The Company does not purchase raw or unrefined conflict minerals and does not conduct purchasing activities directly in the Covered Countries. The statements herein are based on the activities performed to date, in good faith, by the Company and on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions in the information provided by suppliers or smelters, ongoing identification of smelters in our supply chain, and incomplete information from industry or other third-party sources, among other factors.
We maintain a Conflict Minerals Policy that is incorporated into our Partner Operations Manual (the "Partner Manual"), which our suppliers are able to access via a secure website.
II.Description of Products Covered by this Conflict Minerals Report
RH offers merchandise assortments across a growing number of categories, including furniture, lighting, textiles, bathware, décor, outdoor and garden and children's furnishings. The Subject Products include products sold by the
Company in the following categories: furniture, bathware, plumbing fixtures, lighting fixtures, kitchen and bath hardware, décor, outdoor and garden and children's furnishings.
III.Reasonable Country of Origin Inquiry
In accordance with the Rule, we conducted in good faith a reasonable country of origin inquiry (the "RCOI") that was reasonably designed to determine whether any of the necessary conflict minerals in the Subject Products originated in the Covered Countries or were from recycled or scrap sources. Since 2021, RH has partnered with Assent, a supply chain data management company that enhances automation and accuracy when collecting, submitting or managing data related to ESG, product safety and vendor compliance. Assent coordinated RH's communications with its suppliers, including follow-up outreach and data gathering in support of its RCOI for this reporting year.
To conduct our RCOI, we used a conflict minerals reporting template (version 6.5) developed by the Responsible Minerals Initiative ("RMI") (formerly Conflict Free Sourcing Initiative ("CFSI")), an initiative founded by members of the Electronic Industry Citizenship Coalition ("EICC") and the Global e-Sustainability Initiative ("GeSI"). Assent, on RH's behalf, requested this information from our direct suppliers who manufacture our Subject Products.
Based on our RCOI, we have reason to believe that some of the necessary conflict minerals used in our Subject Products may have originated in the Covered Countries and may not have been from recycled or scrap sources. Accordingly, we conducted due diligence to determine the source and chain of custody of these conflict minerals.
IV.Due Diligence Process
We have designed our diligence efforts to generally conform to the Organization for Economic Cooperation and Development's (the "OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements (the "OECD Guidance").
The OECD Guidance identifies five due diligence steps: (i) Establish Strong Company Management Systems; (ii) Identify and Assess Risks in the Supply Chain; (iii) Design and Implement a Strategy to Respond to Identified Risks; (iv) Carry out Independent Third-Party Audit of Smelter/Refiner's Due Diligence; and (v) Report Annually on Supply Chain Due Diligence.
The due diligence steps that we executed included the following:
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Step |
OECD |
Due diligence activities performed by RH |
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1 |
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Establish Strong Company Management Systems |
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Maintained Conflict Minerals Policy |
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We maintained a Conflict Minerals Policy that is published online, in our Partner Manual.
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Maintained Conflict Minerals Compliance Team |
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We maintained an internal conflict minerals team composed of a representative from the legal/vendor compliance team and representatives from Waterworks and other subsidiaries of the Company (the "Conflict Minerals Compliance Team"). The team was structured to ensure our annual conflict minerals due diligence was executed.
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Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams.
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Step |
OECD |
Due diligence activities performed by RH |
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Internal Engagement |
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We educated and continue educating relevant employees on our conflict minerals compliance program and reporting obligations.
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Supplier Engagement |
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We provided our direct suppliers information on conflict minerals and our disclosure requirements.
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Our Conflict Minerals Compliance Team engaged Assent, a supply chain data management company that enhances automation and accuracy when collecting, submitting or managing data related to ESG.
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2 |
Identify and Assess Risks in the Supply Chain |
Identified Products in Scope |
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Our Conflict Minerals Compliance Team conducted a review of the products contracted to be manufactured during the reporting period to identify suppliers that manufacture product categories and Subject Products that may contain conflict minerals.
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Inquired about Due Diligence Measures Performed by Direct Suppliers |
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We used the responses from our direct suppliers to the RMI reporting template to review their due diligence activities, including whether they had adopted a conflict minerals policy, required their own suppliers to source from processing facilities validated by an independent audit firm, and implemented a review process that includes corrective action management.
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As deemed appropriate by us, we followed up by email or phone with the suppliers who did not respond to our request to complete the RMI reporting template, or who submitted incomplete responses or responses that we determined may have contained errors or inaccuracies.
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We employed a conflict minerals data management tool that tracks communications sent to direct suppliers and consolidates suppliers' responses to the RMI template for analysis and reporting.
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Identified Smelters |
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We collected a list of smelters/processors that are in our supply chain by utilizing the RMI reporting template via a web-based platform. We determined if the processing facilities adhere to responsible sourcing practices by reconciling that list to the list of facilities designated by the RMI Responsible Minerals Assurance Program ("RMAP") as RMAP Conformant Smelters & Refiners and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit. We have provided lists of smelters/processors that are reported in our supply chain in Appendix A.
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3 |
Design and Implement a Strategy to Respond to Identified Risks |
Internal Reporting System |
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Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the legal department and the Vendor Compliance and Product Compliance teams.
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Maintained Conflict Minerals Policy |
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We maintained a Conflict Minerals Policy that is published online, in our Partner Manual.
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Step |
OECD |
Due diligence activities performed by RH |
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Verified Smelters |
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As part of our risk mitigation process, we determined if the processing facilities identified in our supply chain adhere to responsible sourcing practices by reconciling the list of smelters collected from our direct suppliers to the list of smelter facilities that have been verified as complying with the RMAP and the RMI list of Active Smelters & Refiners that have committed to undergo the RMAP audit.
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4 |
Carry out Independent Third-Party Audit of Smelter/Refiner's Due Diligence |
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We relied on the RMI's published lists to verify the RMAP compliance status of smelters/processors that are reported in our supply chain.
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5 |
Report Annually on Supply Chain Due Diligence |
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This Conflict Minerals Report is filed with the SEC and publicly available on our website at ir.rh.com, by clicking on "Financials & Filings," and then "SEC Filings."
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V.Review of Due Diligence Results
1.Facilities Used to Process Conflict Minerals in Subject Products
Based on our due diligence process and the information received from our direct suppliers, we have identified, in Appendix A, facilities that may have been used to process conflict minerals used in the Subject Products.
2.Country of Origin of Conflict Minerals in Subject Products
Based on the information provided by our direct suppliers, we have reason to believe that some of the products RH sold during the reporting year contain necessary conflict minerals that may have originated from the Covered Countries. While many of our direct suppliers indicated that they do not use any conflict minerals in products supplied to RH, some may intentionally add conflict minerals necessary to the function and/or production of the product. In addition, a number of our direct suppliers did not respond to our survey. Accordingly, notwithstanding our due diligence efforts, we were unable to determine the origin of a portion of conflict minerals contained in certain of the Subject Products.
3.Efforts to Identify the Mine or Location of Origin of the Conflict Minerals
Our reasonable country-of-origin inquiry and due diligence process described above represent our efforts to identify the mine or location of origin for the conflict minerals contained in the Subject Products for this reporting period.
VI.Steps Taken to Mitigate Risk
RH intends to continue to require our suppliers to comply with our Conflict Minerals Policy and to keep it posted online in our Partner Manual for all suppliers to access. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of conflict minerals will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. We expect that our direct suppliers will comply with our Conflict Minerals Policy and (i) provide appropriate information and conduct necessary due diligence to facilitate our compliance with the Rule, (ii) implement and communicate to their relevant personnel and suppliers policies that are consistent with the Policy, (iii) put in place procedures and contractual provisions for the traceability of conflict minerals, working with their suppliers as applicable, (iv) use reasonable efforts to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third-party as DRC conflict free, and (v) adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with our Conflict Minerals Policy.
In addition to the due diligence steps that we took during the reporting period, which we intend to continue for 2026, as applicable, we intend to communicate to new suppliers our sourcing expectations, including by disseminating our Conflict Minerals Policy to them.
VII.Independent Private Sector Audit
Not required for the reporting period.