Specialized Disclosure Report (Form SD)

ALPHATEC HOLDINGS, INC.

Conflict Minerals Report

For the Year Ended December 31, 2025

This Conflict Minerals Report ("Report") has been prepared by Alphatec Holdings, Inc. ("Alphatec," the "Company," "we," "us" or "our") for the reporting period January 1 to December 31, 2025 ("Reporting Period"). This Report is presented to comply with the final conflict minerals implementing rules (the "Rules") promulgated by the U.S. Securities and Exchange Commission ("SEC"), as modified by SEC guidance issued on April 29, 2014 and the SEC Order issued on May 2, 2014. The Rules were adopted by the SEC to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank"), as codified in Section 13(p) of the Securities Exchange Act of 1934. The Rules impose certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The specific minerals at issue are cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, "Conflict Minerals").

To comply with the Rules, we conducted due diligence on the origin, source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of the products that we manufactured or contracted to manufacture during the Reporting Period to ascertain whether these Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country (collectively, "Covered Countries") and financed or benefited armed groups (as defined in Section 1, Item 1.01(d)(2) of Form SD) in any of these Covered Countries.

Pursuant to SEC guidance issued on April 29, 2014 and the SEC Order issued on May 2, 2014, Alphatec is not required to describe any of our products as "DRC conflict free" (as defined in Section 1, Item 1.01(d)(4) of Form SD), "DRC conflict undeterminable" (as defined in Section 1, Item 1.01(d)(5) of Form SD) or "having not been found to be 'DRC conflict free,'" and therefore makes no conclusion in this regard in the Report presented herein. Furthermore, given that Alphatec has not elected to describe any of its products as "DRC conflict free," an independent private sector audit of the Report presented herein has not been conducted.