Ford Motor Company

05/29/2026 | Press release | Distributed by Public on 05/29/2026 14:30

Specialized Disclosure Report (Form SD)

Ford Motor Company
Conflict Minerals Report
For The Year Ended December 31, 20251

Ford Motor Company is a global company based in Dearborn, Michigan. Our global value chain is extensive and complex. Driven by a desire to build a better world where every person is free to move and pursue their dreams, we strive for the materials that power our vehicles to be safe, sourced responsibly, and to respect the fundamental human rights of all. To achieve this, we maintain a deep focus on understanding the journey of every material-from its origin to our assembly lines.
We believe in using our purchasing power as a force for good. Where possible, we leverage our scale to enable responsible sourcing that strengthens communities and protects the planet we all share. Guided by our We Are Committed to Protecting Human Rights and the Environment policy and our Supplier Code of Conduct, we integrate our values into every partnership, promoting our high standards for human rights to be cascaded throughout our entire supply base.
Transparency is the foundation of our approach to working better together. We collaborate closely with our suppliers to gain visibility into our value chain, launching investigations when necessary to ensure our partners meet or exceed Ford's expectations.
Because sustainability is a long-term strategy built on collaboration, we recognize that we cannot do this work alone. We actively partner with industry peers through organizations such as the Initiative for Responsible Mining Assurance, the Responsible Minerals Initiative (RMI), and the Responsible Business Alliance (RBA). By sharing best practices and aligning our approach, we work to identify and immediately address human rights issues in our supply chain.
We are dedicated to building the capacity of our partners to drive progress. We provide comprehensive training and engage in direct, annual dialogue with our top suppliers to advance our shared sustainability goals. In 2025, we collaborated with over 1,600 supplier representatives on critical topics-including anti-corruption, fair labor, and environmental protection practices.
In this report, "Ford," the "Company," "we," "our," "us," or similar references mean Ford Motor Company, our consolidated subsidiaries, and our consolidated variable interest entities of which we are the primary beneficiary, unless the context requires otherwise.

1.Overview
Since 2013, public companies in the United States have been required to conduct due diligence to determine the origin of conflict minerals in their products and to report annually with the Securities and Exchange Commission. The disclosure rules are intended to further the humanitarian goal of ending violent conflict in the Democratic Republic of Congo (DRC) and adjoining countries - Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia - collectively referred to as the "Covered Countries." The rules consider tin, tungsten, tantalum, and gold to be "conflict minerals" regardless of where they are sourced. We use the term "3TG" when discussing these minerals. By increasing the transparency of 3TG sources, the expectation is that funds from the mineral trade will not directly or indirectly benefit armed groups in the Covered Countries. Instead, these funds will be redirected to responsible sources of 3TG both in the Covered Countries and other conflict-affected and high-risk areas (CAHRAs).
Ford utilizes the RMI Conflict Minerals Reporting Template (CMRT) to support our annual due diligence in alignment with the Organization for Economic Co-Operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from CAHRAs. We identify potential 3TG smelters and refiners in our supply chain, conduct additional due diligence, and conduct outreach as members of the Smelter Engagement Teams of both RMI and the Automotive Industry Action Group (AIAG) to encourage them to participate in the RMI Responsible Minerals Assurance Process (RMAP).
1 This report includes forward-looking statements. Forward-looking statements are based on expectations, forecasts, and assumptions by our management and involve a number of risks, uncertainties, and other factors that could cause actual results to differ materially from those stated. For a discussion of these risks, uncertainties, and other factors, please see "Item 1A. Risk Factors" in our Annual Report on Form 10-K for the year ended December 31, 2025, as updated by subsequent Quarterly Reports on Form 10-Q and Current Reports on Form 8-K.









We prioritize supply chain due diligence based on vehicle content and known environmental and social risks of raw material sourcing as identified on Material Insights, a collaborative platform from TDi Sustainability and the RMI. The following are highlights from the platform regarding risks associated with 3TG:
Tin is used throughout our vehicles, including in electronics, solder, as an alloy with other metals, or as an oxidation-resistant metal coating material. Many sustainability risks are associated with the artisanal and small-scale mining of tin in the Democratic Republic of Congo (9% of global production), including violence and conflict, corruption, pollution, community rights violations, and child labor.
Tantalum is largely used in vehicle electronics. Within the Democratic Republic of Congo, artisanally mined tantalum accounts for the largest share of tantalum production in the world (39%). Sustainability risks associated with tantalum are similar to those associated with tin.
Tungsten is primarily used in vehicle braking systems, engine parts, turbocharger blades, and electrical contacts for electrified vehicles. While most of the global supply of tungsten is produced in China (80%), a small percentage is artisanally mined in the Democratic Republic of Congo, where there are risks including child labor, human rights abuses, and conflict. However, the share of tungsten supply that is associated with these risks is relatively low.
Gold is used in vehicle electronics. It is strongly associated with many sustainability risks, including pollution, community rights violations, violence and conflict, labor rights, child labor, corruption, and non-payment of taxes. Gold's ability to move easily in small, high-value amounts makes it far harder to trace than other 3TG minerals. These traceability gaps create significant challenges for downstream users trying to ensure their supply chains are free from gold linked to CAHRA risks.
In aggregate, our in-scope suppliers represent a significant percentage of our direct expenditure on components or parts. Through our analysis, we can confirm that more than 43,000 parts in our vehicles contain some level of 3TG content. Of our in-scope parts, 99% contain tin, 22% contain tungsten, 8% contain tantalum, and 56% contain gold, with many parts containing more than one of the 3TG materials. All our vehicles include components containing at least one 3TG material.
While we do not directly source any of the 3TG in our products, we work to enable the 3TG used in our vehicles to be responsibly sourced. We define a responsible source of 3TG as a smelter or refiner that provides 3TG material and has been validated as conformant to (i.e., successfully completed) or is active in (i.e., currently participating in) a third-party audit of its management systems and sourcing practices according to one of the following schemes: the RMI RMAP, the London Bullion Market Association (LBMA), Responsible Jewelry Council (RJC), or the Tungsten Industry-Conflict Minerals Council (TI-CMC) chain of custody audit protocols. We expect the use of responsibly sourced 3TG in our supply chain to support the development of a "DRC conflict free" 3TG mineral trade in the Covered Countries.

2.Reasonable Country of Origin Inquiry (RCOI)
Since we are layers removed from the smelters and refiners in our supply chain, we rely on our direct suppliers to survey their suppliers who are expected to continue the cascade of reporting requirements until they identify information concerning the origin of the 3TG contained in the products they supply us. In some cases, information provided by our in-scope suppliers may be incomplete or over-inclusive, resulting in missing or additional Reasonable Country of Origin Inquiry (RCOI) data determination. As our in-scope suppliers are often unable to confirm 3TG country of origin information, we conduct due diligence on the country of origin related to reported smelters and refiners. Our RCOI determination is based on the aggregated smelter and refiner data received from our in-scope suppliers and compared to the RMI RCOI database, which includes the origins of 3TG from RMAP, RJC, LBMA, and TI-CMC conformant smelters and refiners.
RCOI Approach
To determine our in-scope direct suppliers, we performed a risk-based assessment of all suppliers of components or parts to our plants based on 3TG content as reported through the automotive industry's International Material Data System (IMDS) and expected expenditure. We require these suppliers to complete the CMRT, an industry-leading tool developed by the RMI. Suppliers submit their completed CMRT for analysis through a designated link directly into our third-party online platform.
The CMRT includes a list of suppliers to identify 3TG smelters and refiners that may be in our supply chain. Smelters and refiners procure minerals that are processed into usable metals and are a key chokepoint for due diligence in our complex mineral supply chain. If our suppliers identify smelters or refiners that are not conformant to or active in a








third-party responsible mineral sourcing validation program, we ask suppliers to contact reported, non-participating smelters and refiners and encourage them to participate in RMAP or consider alternate sourcing arrangements.
For the 11th year in a row, we received responses from 100% of the in-scope suppliers surveyed. When we receive supplier CMRTs, we review them and, if necessary, provide corrective action plans and risk assessments to suppliers for any of the following reasons: incomplete reports, reports inconsistent with information previously reported through IMDS, less than 100% response rates from their sub-suppliers, and/or their CMRT contained smelters or refiners that are not RMAP, RJC, LBMA, and TI-CMC conformant smelters and refiners.
Starting in 2022, we implemented a stricter quality review and standard for CMRT acceptance. If a completed CMRT contains all required information and is consistent with the information submitted in IMDS, we consider it a "quality" response. With the support of our corrective action communications and training, this action led in 2025 to a 100% quality response rate for the third year in a row, supporting a more complete set of 3TG data disclosures and better due diligence from our supply chain.

3.Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the 5-step framework in the 3rd Edition of the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) (OECD Guidance) and the related supplements for 3TG.

4.Due Diligence Measures Performed
4.1.Establish Strong Company Management Systems
Our conflict minerals management system includes the following actions:
▪Established an Executive Steering Team for conflict minerals compliance led by our Chief Supply Chain Officer. The team includes the following members:
•Chief Government Affairs Officer
•Chief Policy Officer and General Counsel
•Vice President, Chief Sustainability, Environment & Safety Officer
•Chief Communications Officer
•Vice President, Vehicle Hardware Engineering
•Chief Accounting Officer
▪Established a cross-functional working level team to manage conflict minerals compliance. The working level team meets biweekly and holds an annual meeting with the Executive Steering Team to review our conflict minerals compliance status, strategy, continuous improvement objectives, performance to metrics, and legislative updates.
▪Established Responsible Materials Sourcing Policy including Conflict Minerals (RMS Policy) requiring our direct suppliers of components containing 3TG to conduct due diligence to understand the origins of 3TG in their components, source 3TG responsibly (as described in Section 1), and not knowingly provide us with 3TG parts that contribute to conflict.
▪Established our Supplier Code of Conduct (Supplier Code) and integrated within our Production Purchasing Global Terms and Conditions as a requirement to conduct business with us, including contractual obligations for conflict minerals reporting requirements.
▪Integrated key performance indicators, including supplier CMRT survey response rate and quality of responses, into suppliers' Sustainability Scorecard which is utilized as part of our sourcing process.
•Established and enforced a process to allow for supplier sourcing hold if conflict mineral compliance requirements were not met.
▪Utilized standardized tools and templates (e.g., CMRT) to improve efficiency and response rates and increase 3TG smelter and refiner participation in responsible assurance programs.








▪Built supply base knowledge capacity by developing training modules and conducting training sessions to enable our suppliers to understand our reporting and due diligence requirements, assisting them in their continuous improvement efforts to increase reporting transparency, and promoting procurement from conformant smelters and refiners.
▪Executed internal capacity building training for relevant employees outlining our supplier reporting requirements, reporting process, and timeline.
▪Implemented an external grievance site with suppliers utilizing the Responsible Business Alliance Worker Voice platform to provide external stakeholders (e.g., supply chain employees, community members) with instructions and information on reporting grievances in regard to Ford or any of our suppliers, including information in twenty (20) different languages. External stakeholders may also report grievances by emailing [email protected].
▪Actively tracked grievances submitted through the RMI Grievance Mechanism that involve SoR facilities reported by our suppliers to determine if additional actions to mitigate risk would be needed, such as direct outreach and engagement with smelters and refiners or notification to suppliers to conduct additional due diligence regarding reported smelters and refiners in their supply chain.
▪Actively tracked smelter conformance status to RMAP, RJC, and LBMA standards. If a smelter or refiner status changes from Conformant or Active to Non-Conformant, a red flag is placed in our system and suppliers submitting these facilities in subsequent submissions are requested to remove the refiner from the reported supply chain.
▪Facilitated the confidential reporting of known or potential violations of the law or of our policies by our employees who can report violations directly to Human Resources or the Compliance, Ethics and Integrity Office as well as the Office of the General Counsel. Violations can also be reported using the SpeakUp reporting mechanism, telephone hotlines, websites, or email, some of which allow for anonymous reporting. A cross-functional committee reviews allegations and oversees any investigations and subsequent corrective or disciplinary actions.
▪Actively participated in collaborative efforts, such as RMI and AIAG work groups, to stay up to date with regulatory requirements, align with industry and cross industry best practices, and continuously improve our conflict mineral due diligence management system.
4.2.Identify and Assess Risk in the Supply Chain
We have dedicated resources and a cross-functional team managing our conflict mineral compliance and responsible sourcing efforts to identify, assess, and mitigate risk in our 3TG supply chain. We reviewed in-scope supplier CMRTs for supplier compliance with our reporting requirements such as:
•Completion of all required reporting elements
•Manual review and reconciliation of any CMRT reporting inconsistencies
•Consistency between the expected 3TG metals reported as being intentionally added to the supplier's products and the metals reported in IMDS
•Presence of a smelter and refiner list that includes expected metals based on IMDS reporting
•Suppliers' sub-tier response rate reported from each CMRT supplier survey
•Identification of smelters and refiners not participating in required third-party validation programs reported in suppliers' supply chains
•Supplier conflict mineral sourcing policies
We then conduct training sessions on how various recommended corrective actions can be addressed and implemented within the supply chain. Corrective action plans resulted in 124 or 21% of suppliers improving
Ford Motor Company published this content on May 29, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 29, 2026 at 20:31 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]