Specialized Disclosure Report (Form SD)

EATON CORPORATION plc

CONFLICT MINERALS REPORT

FOR THE YEAR ENDED DECEMBER 31, 2025

This Conflict Minerals Report (this "Report") of Eaton Corporation plc ("Eaton", the "Company", "we", "us", or "our") for the reporting period from January 1, 2025 to December 31, 2025 is provided pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule").

Eaton is required to perform a reasonable country of origin inquiry into the sources of necessary conflict minerals in our products and disclose the results of such diligence. Conflict minerals have been defined as tin, tantalum, tungsten, and gold (the "Conflict Minerals"). The design of our due diligence program and related results are described below.

A copy of Eaton's Conflict Minerals Report is publicly available at www.eaton.com under "Responsible Sourcing of Conflict Minerals" at: https://www.eaton.com/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html. The contents of our website referred to in this Report are not incorporated by reference into this Report.

1.COMPANY OVERVIEW

Eaton Corporation plc is an intelligent power management company dedicated to protecting the environment and improving the quality of life for people everywhere. We make products for the data center, utility, industrial, commercial, machine building, residential, aerospace and mobility markets. We are capitalizing on the megatrends of the electrification, digitalization and the reindustrialization of and growth of megaprojects in North America and increased global infrastructure spending, all of which are expanding our end markets and positioning Eaton for growth for years to come. We are strengthening our participation across the entire electrical power value chain and benefiting from momentum in the data center and utility end markets as well as a growth cycle in the commercial aerospace and defense markets. We are guided by our commitment to operate sustainably and with the highest ethical standards. Our work is helping to solve the world's most urgent power management challenges and building a more sustainable society for people today and for future generations.

Founded in 1911, Eaton has evolved to meet the changing and expanding needs of our stakeholders. With revenues of $27.4 billion in 2025, the Company serves customers in 180 countries.

During 2025, Eaton had five business segments: Electrical Americas, Electrical Global, Aerospace, Vehicle, and eMobility. During the first quarter of 2026, Eaton re-segmented certain reportable operating segments due to a reorganization of the Company's businesses. The new reportable segment is Mobility, which consists of the legacy Vehicle and eMobility segments. For this Report, we have not used the new reportable Mobility segment as the re-segmentation occurred subsequent to the calendar year 2025.

In 2025, Eaton considers all products to be in-scope and include, but are not limited to:

Electrical Americas and Electrical Global

The Electrical Americas segment consists of electrical components, industrial components, power distribution and assemblies, residential products, single phase power quality and connectivity, three phase power quality, wiring devices, circuit protection, utility power distribution, power reliability equipment, and services that are primarily produced and sold in North and South America. The Electrical Global segment consists of electrical components, industrial components, power distribution and assemblies, single phase and three phase power quality, and services that are primarily produced and sold outside of North and South America; as well as hazardous duty electrical equipment, emergency lighting, fire detection, intrinsically safe explosion-proof instrumentation, and structural support systems that are produced and sold globally.

Aerospace

The Aerospace segment is a leading global supplier of aerospace fuel, hydraulics, and pneumatic systems for commercial and military use, as well as filtration systems for industrial applications. Products include hydraulic power generation systems for aerospace applications including pumps, motors, hydraulic power units, hose and fittings, electro-hydraulic pumps; controls and sensing products including valves, cylinders, electronic controls, electromechanical actuators, sensors, aircraft flap and slat systems and nose wheel steering systems; fluid conveyance products, including hose, thermoplastic tubing, fittings, adapters, couplings, sealing and ducting; fuel systems including air-to-air refueling systems, fuel pumps, fuel inerting products, sensors, valves, adapters and regulators; mission systems including oxygen generation system, payload carriages, and thermal management products; high performance interconnect products including wiring connectors and cables. The Aerospace segment also includes filtration systems including hydraulic filters, bag filters, strainers and cartridges; and golf grips.

Vehicle

The Vehicle segment is a leader in the design, manufacture, marketing, and supply of: drivetrain, powertrain systems and critical components that reduce emissions and improve fuel economy, stability, performance, and safety of cars, light trucks and commercial vehicles. Products include transmissions and transmission components, clutches, hybrid power systems, superchargers, engine valves and valve actuation systems, locking and limited slip differentials, transmission controls, and fuel vapor components for the global vehicle industry.

eMobility

The eMobility segment designs, manufactures, markets, and supplies mechanical, electrical, and electronic components and systems that improve the power management and performance of both on-road and off-road vehicles. Products include high voltage inverters, converters, fuses, circuit protection units, vehicle controls, power distribution, fuel tank isolation valves, and commercial vehicle hybrid systems.

In 2025, Eaton completed its acquisition of Fibrebond Corporation and Resilient Power Systems Inc. and, for the avoidance of doubt, their Conflict Minerals information is not included in this Report.

2.REASONABLE COUNTRY OF ORIGIN INQUIRY

Purchased raw materials and parts are varied and are sourced from many suppliers. Eaton has a substantial number of suppliers globally that span across our business segments. Our supply chain is multi-tiered, and Eaton is typically many levels removed from the mines, smelters, and refiners. Therefore, Eaton must rely on its suppliers to provide information about the origin of the Conflict Minerals in its products for our reasonable country of origin inquiry ("RCOI"). Some of Eaton's products may contain Conflict Minerals either from recycled sources or in their processed form.

For the reporting period from January 1 through December 31, 2025, Eaton conducted a good faith RCOI of the Conflict Minerals that are necessary to the functionality or production of the products that Eaton manufactured or contracted with others to manufacture during the reporting period. Based on this RCOI, Eaton was unable to conclude that these Conflict Minerals did not originate from the Democratic Republic of the Congo (the "DRC") or adjoining countries. Accordingly, Eaton undertook further due diligence measures on the source and chain of custody of the identified necessary Conflict Minerals.

3.CONFLICT MINERALS DUE DILIGENCE

3.1 Design of Due Diligence Program and Overview

Our due diligence program measures were designed to conform, in all material respects, with the internationally recognized due diligence framework set forth in The Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, and the related supplements on tin, tantalum, tungsten and gold. Pursuant to this framework, we undertook to: (a) establish strong company management systems, (b) identify and assess risks in our supply chain, (c) design and implement a strategy to respond to the identified risks, (d) carry out independent third-party audit of smelter/refiner's due diligence practices, and (e) report annually on supply chain due diligence.

3.2 Due Diligence Measures Performed

a. Establish Strong Company Management Systems

Eaton has taken steps to develop strong company management systems pertaining to the use of Conflict Minerals in our products and supply chain. These include the adoption of a responsible sourcing of conflict minerals policy, which is available at http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html.

In addition, we have implemented an internal management reporting structure to manage and oversee Eaton's Conflict Minerals activities consisting of a dedicated Conflict Minerals team and executive-level Conflict Minerals Steering Committee chaired by Eaton's Vice President for Global Supplier Performance and comprising members from Eaton's Sustainability, Supply Chain and Legal teams. The Steering Committee oversees and supports the Company's conflict minerals compliance efforts to meet the reporting requirements of the Rule. The Steering Committee meets periodically and regularly monitors and reviews compliance activities including the results of compliance activities against prior year's results.

We have also established formal requirements for suppliers related to the use and reporting of Conflict Minerals, including the implementation of a supplier Conflict Minerals solicitation process utilizing tools created by the Responsible Minerals Initiative ("RMI"), which includes the Conflict Minerals Reporting Template ("CMRT"). In this reporting period, Eaton requested that its suppliers use the CMRT version 6.5 (which was released in April 2025). Through our policy and participation in RMI, Eaton is committed to responsible sourcing of Conflict Minerals from the DRC and adjoining countries and requires suppliers and smelters or refiners to source responsibly from these regions. Through our RMI participation and in our due diligence program, we include Conflict Affected and High-Risk Areas ("CAHRA").

We retain relevant Conflict Minerals documentation and records in accordance with our record retention policy and procedures.

Finally, we maintain a global ethics e-mail address and telephone helpline (https://www.eaton.com/us/en-us/company/ethics-compliance.html), which can be used by employees, suppliers or other stakeholders to report any concerns relating to Eaton's sourcing activities. It is our policy that we investigate appropriately any reported concerns about Conflict Minerals sourcing.

b. Identify and Assess Risks in our Supply Chain

As a downstream user of Conflict Minerals, Eaton is many layers removed from the mine or location from which the Conflict Minerals originated and the smelters and refiners which processed the Conflict Minerals. Eaton does not purchase raw ore or unrefined Conflict Minerals, and, to the best of our knowledge, conducts no purchasing activities directly in the DRC or adjoining countries.

We solicited relevant suppliers using due diligence tools including the RMI's CMRT. Our solicitation letter included an explanation of Conflict Minerals, our policy and the related legal regulations, and a request for suppliers to comply with the regulations, our policy and Supplier Code of Conduct ("the Code") and to contact us for any questions. Additional solicitation requests, including in additional languages beyond English, were sent to suppliers that did not respond or provide sufficient information. Through this process, during 2025, we solicited approximately 950 suppliers.

We verified the information provided by our suppliers (to the extent possible) by comparing it to the information shared on the RMI website and monthly plenary calls, and against CMRT acceptance criteria for completeness and consistency of responses. Through this process, for suppliers who provided names of smelters and refiners, we determined the RMI conformance status of those supplier-reported smelters and refiners. For those suppliers who provided country of origin information for the Conflict Minerals, we confirmed the listed countries of origin for each smelter and refiner if that information was available from RMI. If there were discrepancies between the supplier information and RMI's, we made follow up inquiries with our suppliers following RMI's acceptance criteria guidance and rejected the relevant suppliers' CMRTs until any discrepancies were resolved.

c. Design and Implement a Strategy to Respond to Identified Risks

Eaton's strategy to respond to identified risks concerning Conflict Minerals includes the development of a responsible sourcing of conflict minerals policy, as referenced above. In line with our conflict minerals policy, our Code requires our suppliers to commit to the responsible sourcing of Conflict Minerals. The Code and the Conflict Minerals requirements are incorporated by reference into Eaton's Purchase Order Terms and Conditions. Both the Code and Purchase Order Terms and Conditions are used to communicate requirements to our suppliers, including expectations relating to the use and sourcing of Conflict Minerals. In particular, Eaton's Code and Purchase Order Terms and Conditions require our suppliers to perform due diligence into their respective supply chains to determine whether products sold to us contain Conflict Minerals, and whether, and to what extent, the Conflict Minerals are sourced from smelters and refiners conformant to RMI's Responsible Minerals Assurance Process ("RMAP"), and to report to Eaton the results of this due diligence. The Code and Purchase Order Terms and Conditions are available on our website at https://www.eaton.com/us/en-us/company/selling-to-eaton.html.

Eaton monitors the information received from suppliers in response to our solicitations and periodically shares summaries of this information with our Conflict Minerals Steering Committee. Eaton is a member of RMI (member Code EATN) and uses data from the RMI to determine the conformance status of supplier-reported smelters and refiners, as well as reported country of origin information related to the Conflict Minerals sourced from such smelters or refiners, if available. Through our membership in RMI, Eaton further supports several complementary programs such as the International Tin Supply Chain Initiative ("ITSCI"), the Independent Metals Authority ("LBMA") and the RCS Global Group's Better Mining Project, with which RMI collaborates to jointly address Conflict Minerals issues in CAHRAs including the DRC and adjoining countries.

Suppliers that are either non-responsive or provide incomplete or inconsistent responses to Eaton's solicitations are escalated within Eaton's Supply Chain Management organization for follow-up engagement. Responding suppliers reporting smelters and refiners that are non-conformant or have other identified red flags (risks from open-source information that merit further review) receive follow-up communication to remind them of Eaton's expectations relating to the use and sourcing of Conflict Minerals as well as support and resources available to them, including training, through our membership in RMI. Corrective action plans are assigned as needed to ensure suppliers improve on their due diligence practices and comply with Eaton's Code and Purchase Order Terms and Conditions.

d. Carry Out Independent Third-Party Audits of Smelter/Refiner's Due Diligence Practices

As a downstream user of Conflict Minerals, Eaton and its direct supply chain are many layers removed from the mine or location from which the Conflict Minerals originated and smelters and refiners that process the Conflict Minerals in our products. Through our membership and participation in the RMI, we collaborate at a cross-industry level, and we continue to support the development and implementation of due diligence practices, the RMI's RMAP and tools such as the CMRT. In addition, Eaton has previously contributed financially to RCS Global Group's Better Mining program, which has been recognized as a valid upstream assurance mechanism for its work to address risks associated with artisanal small mines.

e. Report Annually on Supply Chain Due Diligence

Eaton publicly communicates our responsible sourcing of conflict minerals policy, due diligence activities and related supplier expectations on our website and in our Conflict Minerals Report available at: http://www.eaton.com/content/eaton/us/en-us/company/policies-and-statements/responsible-sourcing-of-conflict-minerals0.html.

4.RESULTS OF REVIEW

For the reporting period of January 1 through December 31, 2025, Eaton solicited approximately 950 suppliers identified as potentially having Conflict Minerals in their products to gather detailed information regarding the existence of Conflict Minerals in products sold to us, as well as the origin and chain of custody of the Conflict Minerals in our products, using the CMRT.

Based on the information provided by Eaton's suppliers and our own due diligence efforts in the reporting period, we do not have sufficient information to conclusively determine the countries of origin or chain of custody of all Conflict Minerals in our products. A majority of our suppliers responded that their materials did not contain Conflict Minerals, they used recycled materials, they were unable to determine whether the products they sold to us contained Conflict Minerals, or they were still in the process of evaluating the source of Conflict Minerals in their products.

Based on the information provided by our suppliers, the smelters and refiners that may have been used to produce Conflict Minerals in Eaton's products are listed in Annex I. Based on information provided by our suppliers and information available from the RMI, the countries of origin of Conflict Minerals processed by these smelters and refiners may include the countries listed in Annex II. None of the responses acknowledged that Conflict Minerals were sourced from smelters/mines that financed or benefited armed groups in the DRC or adjoining countries. Eaton has no knowledge that any Conflict Minerals known to be in its supply chain directly or indirectly financed or benefitted armed groups in the DRC or adjoining countries.

5.STEPS TAKEN AND TO BE TAKEN TO MITIGATE RISK

Eaton intends to continue to evaluate its due diligence program in accordance with the provisions of the Rule. We will continue to annually review the criteria used to select suppliers for solicitation and engage with our suppliers to identify the Conflict Minerals used within our supply chain, as well as the origin and chain of custody of those Conflict Minerals. We intend to continue to engage with third party programs such as the RMI. Finally, to the extent that any Eaton supplier is found to be using non-conformant smelters or refiners within its supply chain, Eaton intends to engage that supplier and re-communicate our requirement for suppliers to commit to comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from the DRC or adjoining countries, as per Eaton's policy and Code.

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