Arrow Electronics Inc.

05/27/2026 | Press release | Distributed by Public on 05/27/2026 10:30

Specialized Disclosure Report (Form SD)

Arrow Electronics, Inc.

Conflict Minerals Report for the Year Ended December 31, 2025

This Conflict Minerals Report ("Report") for Arrow Electronics, Inc. covers the reporting period January 1, 2025 to December 31, 2025 and has been prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Rule"). The Rule imposes certain reporting obligations on Securities and Exchange Commission registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (collectively, "Conflict Minerals").

References in this Report to "Arrow," the "Company," "we," "us," or "our" refer to Arrow Electronics, Inc. and all our consolidated subsidiaries.

Operations and Products Covered by this Report

Arrow sources and engineers technology for thousands of leading manufacturers, service providers, and users of enterprise computing solutions.

In 2025, the following products, among others, were assembled or modified by Arrow: capacitors; resistors; inductors; diodes; circuit protectors; connectors; switches; wires; cables; batteries; magnetics; memory chips; workstations; hard drives; motherboards; processors; kiosks; power management; power supplies; and lighting assemblies (collectively, "Products").

The Company determined that some of the Products may contain Conflict Minerals necessary to their functionality or production.

Conflict Minerals Due Diligence Program

The Rule is based on considerations that mineral extraction and processing in conflict-affected and other high- risk regions may directly or indirectly contribute to armed conflict and human rights abuses in those areas. To identify and mitigate these risks in our supply chain, we designed our Conflict Minerals due diligence program around the framework set forth in the Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance"). Arrow is also a member of the Responsible Minerals Initiative ("RMI"), and utilizes the tools, data, and other resources available through this multi-industry coalition supporting responsible sourcing.

1. Strong company management systems:
a. Arrow's Conflict Minerals Program is designed and implemented by the Global Legal and Compliance department, the Global Material Data Management team, and the Arrow Supplier Quality team.
b. Arrow maintains a Conflict Minerals Policy that sets forth our commitment to transparency in supply chains, as well as our expectation that our suppliers will observe international standards for responsible sourcing. Our Worldwide Code of Business Conduct and Ethics (the "Code") and our Business Partner Code of Conduct and Ethics (the "Business Partner Code") further outline our standards for ethical business conduct and respect for human rights, both in our own operations and in our supply chain. These materials are publicly communicated at https://www.arrow.com/company/overview/governance-overview/corporate-governance/policies-and-reports.
c. Arrow collects information from suppliers via the RMI's Conflict Minerals Reporting Template ("CMRT"). The CMRT is designed to identify smelters and refiners processing any Conflict Minerals contained in, and necessary to the functionality or production of our Products ("Smelters").
d. We maintain records relating to our Conflict Minerals program in accordance with our Information Governance Policy and Global Record Retention Schedule and applicable law.
e. We maintain multiple grievance mechanisms for employees and third parties to confidentially raise concerns regarding our business operations and supply chain, including concerns related to Conflict Minerals. Our AlertLine is available globally and in multiple languages, 24 hours a day and 7 days a week. Reports may be raised anonymously, where permitted by local law. Employees are also encouraged to escalate concerns to the Global Legal and Compliance department or through other internal escalation channels. Any employee escalating concerns in good faith is protected from retaliation under the Code. Employees are reminded of available escalation channels, and our commitment to protection of "whistleblowers," on an ongoing basis through communications and training.
2. Identification and assessment of supply chain risk:
a. We identify the parts supplied to Arrow for the purpose of assembly and/or modification of the Products, and the direct suppliers of those parts ("Suppliers").
b. Arrow works with SiliconExpert Technologies, Inc.[1], a components database and service provider, to collect CMRTs from Suppliers, aggregate responses, and compile a list of identified Smelters.
c. We review the CMRT data along with any accompanying information received. Where appropriate, we engage with Suppliers to collect further information to address incomplete or potentially inaccurate responses.
d. We assess Smelters identified by our Suppliers' CMRTs against the RMI and other third-party standards to determine the conflict status of those entities and facilities.

1 SiliconExpert Technologies, Inc. is a wholly owned subsidiary of Arrow Electronics, Inc.

3. Risk management:
a. Our risk management plan includes conducting due diligence of Suppliers that may be sourcing or processing Conflict Minerals from the conflict-affected or high-risk regions. Arrow takes a risk-based approach to supplier due diligence, which may include:
◾ Screening Suppliers against various resources - including government sites, public records, and online media -- and monitoring these Suppliers on an ongoing basis;
◾ Reviewing self-assessments from key Suppliers;
◾ Confirming Suppliers' commitment to the principles of our Business Partner Code; and
◾ Engaging in enhanced due diligence where red flags or heightened risk factors are identified.
b. We implemented a risk mitigation response plan to track Suppliers and Smelters identified as not meeting the standards set forth in our Conflict Minerals Policy to monitor their progress toward meeting those requirements.
c. The Global Legal and Compliance department engages relevant stakeholders across functions to support risk mitigation efforts, as appropriate.
4. Independent supply chain audits:
a. Based on Arrow's downstream position in the supply chain, the Company is not positioned to directly audit Smelters. Arrow relies on organizations such as the RMI for information on certified smelters. Additionally, Arrow seeks to participate in and contribute to industry associations and other organizations involved in supply chain audit activities, in line with the standards and processes set out in the OECD Guidance.
5. Disclosure of Conflict Minerals due diligence:
a. This Report is publicly available on our company website at https://www.arrow.com/company/overview/governance-overview/corporate-governance/conflict-minerals. The Report is also provided to customers upon request.

Reasonable Country of Origin Inquiry and Results

Pursuant to the Rule, Arrow conducts due diligence to determine whether any of the necessary Conflict Minerals in our Products may have originated in the Democratic Republic of the Congo or an adjoining country (collectively, "Covered Countries"). We further review whether the Conflict Minerals originating in Covered Countries are sourced from Smelters who conform with third-party audit standards, or from recycled or scrap sources.

Arrow does not purchase raw or unrefined Conflict Minerals, and we are many steps removed from the mining of any minerals in our Products. As a downstream purchaser, we do not have direct visibility into raw materials sourcing in our supply chain. We rely on our Suppliers to provide us with information on the origin and chain of custody of Conflict Minerals in the Products, and we understand that these Suppliers must collect similar information within their own supply chains. Many of our Suppliers provide Conflict Minerals data at the company level, rather than the part level, and in these instances the data we receive is not limited to the parts that were incorporated into the Products.

Arrow identified 87,773 unique parts that were incorporated into the Products in 2025. Arrow obtained these parts from 413 Suppliers. As a result of our Supplier outreach, Arrow received CMRTs from 75.30% of our Suppliers, representing 88.06% of the unique parts that were incorporated into the Products. Based on our reasonable country of origin inquiry, Arrow determined that two Smelters identified by our Suppliers are located in Covered Countries and have not been certified as conforming with RMI or other recognized third-party audit standards.

We are unable to confirm whether any Conflict Minerals contained in the Products originated with the two non-conforming Smelters, due in part to the company-level data provided by many of our Suppliers. As part of the ongoing due diligence process, Arrow continues to encourage our Suppliers to preference conforming Smelters and transition any non-conforming Smelters out of the supply chain.

See Table 1 to Exhibit 1.01 for a list of Smelters identified in our country of origin inquiry and related due diligence.

Future Due Diligence Measures

To mitigate the risks associated with Conflict Minerals in the supply chain, Arrow has taken or will take the following steps, among others, to continue to enhance the Conflict Minerals compliance program:

● reiterate to our Suppliers the expectations in our Conflict Minerals Policy regarding responsible sourcing;
● expand the breadth and depth of our supply chain due diligence; and
● conduct other due diligence as referenced in this Report.
Arrow Electronics Inc. published this content on May 27, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 27, 2026 at 16:31 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]