05/22/2026 | Press release | Distributed by Public on 05/22/2026 04:01
Conflict Minerals Report of NetApp, Inc.
For the Calendar Year Ended December 31, 2025
This Conflict Minerals Report contains forward-looking statements. These statements include statements regarding NetApp's goals for its Conflict Minerals policy and the actions that NetApp intends to take to improve transparency and reporting. All forward-looking statements involve risk and uncertainty. When considering these statements, you should also consider the important factors described in reports and documents NetApp files from time to time with the Securities and Exchange Commission ("SEC"), including the factors described under the sections titled "Risk Factors" in NetApp's most recently filed Annual and Quarterly Reports on Forms 10-K and 10-Q, respectively. Except as required by law, NetApp disclaims any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.
Unless otherwise stated herein, any documents, third-party materials or references to websites (including NetApp's) are not incorporated by reference in, or considered to be a part of, this Conflict Minerals Report unless expressly incorporated by reference herein.
This is the Conflict Minerals Report for NetApp, Inc. ("NetApp") for calendar year 2025 prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1").
Introduction
NetApp helps customers make their data infrastructure more seamless, more dynamic, and higher performing. NetApp provides a full range of enterprise-class software, systems and services that customers use to transform their data infrastructures across data types, workloads, and environments to realize business possibilities.
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the rules promulgated thereunder (together "Section 1502") require NetApp to perform certain due diligence procedures and disclose information about the use and origin of certain minerals if these minerals are deemed to be necessary to the functionality or production of a product manufactured or contracted to be manufactured by NetApp. The NetApp products that contain these minerals are its hardware products (hardware storage systems and subsystems) that NetApp contracts to manufacture and sells directly or through resellers. The specific minerals covered by these rules consist of tin, tantalum, tungsten and gold and are referred to as "Conflict Minerals" or alternatively as "3TG."
Conflict Minerals are necessary to the functionality or production of the hardware storage systems and subsystems that NetApp contracts with third parties to manufacture. Components and subassemblies that are made in part using Conflict Minerals are sourced from a global supply base that includes distributors, value-added resellers, original equipment manufacturers, original design manufacturers and contract manufacturers.
Reasonable Country of Origin Inquiry
In accordance with Section 1502, NetApp has performed a good faith "reasonable country of origin inquiry" ("RCOI") using the steps described below on the Conflict Minerals contained in the NetApp products the manufacturing of which was completed during calendar year 2025 to determine whether these minerals were sourced from the Democratic Republic of the Congo or adjoining countries (collectively the "Covered Countries"). Based on the RCOI, NetApp had reason to believe that some of the applicable Conflict Minerals may have originated from the Covered Countries; therefore, in accordance with Section 1502, NetApp performed additional due diligence on the source and chain of custody of these Conflict Minerals, as described below.
Due Diligence Procedures
In accordance with Rule 13p-1, NetApp undertook due diligence procedures to determine the source and chain of custody of the Conflict Minerals used in its products. NetApp designed its due diligence measures for each of the Conflict Minerals to conform, in all material respects, with the due diligence framework 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 (OECD 2016) ("OECD Framework") and related supplements. NetApp's due diligence measures concerning Conflict Minerals included:
STEP 1: Establish strong company management systems
STEP 2: Identify and assess risks in the supply chain
STEP 3: Design and implement a strategy to respond to identified risks
STEP 4: Support industry associations that carry out independent third-party audits of smelter and refiner due diligence practices
As a member of the Responsible Business Alliance or "RBA," NetApp will continue to participate in the RMI to assist in increasing the number of smelters and refiners directly and indirectly in its supply base that are conformant with the applicable RMI RMAP standard or a cross-recognized scheme. NetApp has not voluntarily elected to describe any of its products as "DRC conflict free," and for this reason, pursuant to SEC guidance issued on April 29, 2014 and the SEC order issued on May 2, 2014, an independent private sector audit of the report presented herein has not been conducted.
STEP 5: Report annually on supply chain due diligence
NetApp's Conflict Minerals policy, Form SD and this Conflict Minerals Report are available on NetApp's public website: https://www.netapp.com/company/about-us/conflict-minerals/.
Results of Due Diligence
NetApp, as a purchaser, is many steps removed from the mining of Conflict Minerals and does not purchase raw ore or unrefined Conflict Minerals, nor does it purchase bulk Conflict Minerals in the form of ingots or bullion for use in its products. The origin of NetApp's Conflict Minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other derivatives. The smelters and refiners are consolidating points for raw ore and are in the best position in the total supply chain to know the origin of the ores. In addition, the majority of CMRTs received from the in-scope suppliers were made on a company- or division-level basis, rather than on a product-level basis, and therefore NetApp cannot identify with certainty which smelters or refiners actually processed the Conflict Minerals contained in NetApp products.
As a result of NetApp's due diligence, NetApp's suppliers identified 316 smelters and refiners from which they source Conflict Minerals that appear on the RMI's Standard Smelter List, and of those smelters and refiners, 207 smelters and refiners, or approximately 65.51%, have successfully completed an assessment against the applicable RMI RMAP standard or a cross-recognized scheme. The remaining 109 smelters and refiners have not, at this time, successfully completed an assessment against the applicable RMAP standard or a cross-recognized scheme. NetApp is continuing to engage with its suppliers to encourage participation by non-conformant and unenrolled smelters and refiners in the RMAP or an equivalent program. The information contained in this paragraph is based on supplier responses received through May 14, 2026, and smelter and refiner status is provided as of May 14, 2026.
Since a majority of NetApp's suppliers provided smelter and refiner information at a company or division level, rather than at a product level, and a number of identified smelters and refiners have not successfully completed an assessment under the applicable RMAP standard or a cross-recognized scheme, NetApp was not able to determine the country of origin of the Conflict Minerals in its products or whether portions of such products contain recycled or scrap sources. Accordingly, NetApp has not voluntarily elected to describe its products as "DRC conflict free" and for this reason, pursuant to the SEC guidance issued on April 29, 2014 and the SEC order issued on May 2, 2014, an independent private sector audit of the report presented herein has not been conducted.