05/29/2026 | Press release | Distributed by Public on 05/29/2026 12:24
Conflict Minerals Report
Benchmark Electronics, Inc. ("Benchmark" or "Company") has included this Conflict Minerals Report ("CMR") as an exhibit to its Form SD as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the "Conflict Minerals Rule"), including:
(collectively the "Interim Guidance").
In Nat'l Ass'n of Mfrs. v. SEC1, the U.S. Court of Appeals for the District of Columbia Circuit held that requiring companies to describe their products as having "not been found to be 'DRC conflict free'" violates the First Amendment. On April 3, 2017, the U.S. District Court for the District of Columbia entered final judgment setting aside those portions of Rule 13p-1 and Form SD, and remanding to the Commission.
In the Updated Statement, the Division of Corporation Finance stated that, in light of the uncertainty regarding the rule and related judicial and administrative developments, it would not recommend enforcement action against companies that comply only with Items 1.01(a) and (b) of Form SD, including companies that would otherwise be subject to Item 1.01(c). Items 1.01(a) and (b) require, among other things, a brief description of the issuer's reasonable country of origin inquiry and its results. Item 1.01(c) requires a company to conduct due diligence, file a Conflict Minerals Report as an exhibit, and, in certain circumstances, obtain an independent private sector audit. Notwithstanding this relief, the Company voluntarily provides this CMR, including the due diligence information described herein, to promote supply chain transparency and responsible sourcing of conflict minerals.
Unless otherwise defined herein, terms used in this Report have the same meaning found in the Conflict Minerals Rule, the Final Release and the Interim Guidance. The date of filing of this CMR is May 29, 2026.
References in this CMR to Benchmark, the Company or use of the words "we", "our" and "us" include Benchmark's subsidiaries unless otherwise noted. As used herein, "Conflict Minerals" or "3TG" are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin.