Benchmark Electronics Inc.

05/29/2026 | Press release | Distributed by Public on 05/29/2026 12:24

Specialized Disclosure Report (Form SD)

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:

Release No. 34-67716 issued by the Securities and Exchange Commission ("SEC") August 22, 2012 (the "Final Release"),
Frequently Asked Questions regarding Conflict Minerals issued by the Staff of the SEC on May 30, 2013 and April 7, 2014;
Statement issued April 29, 2014 by the SEC's Director of the Division of Corporation Finance;
Statements issued April 7, 2017 by the SEC's Acting Chairman and the SEC's Division of Corporation Finance (the "Updated Statement"); and
Guidance issued by the SEC and its Staff from time to time concerning the Conflict Minerals Rule

(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.

Benchmark Electronics Inc. published this content on May 29, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 29, 2026 at 18:25 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]