Microsoft Corporation

05/28/2026 | Press release | Distributed by Public on 05/28/2026 15:05

Specialized Disclosure Report (Form SD)

MICROSOFT CORPORATION

CONFLICT MINERALS REPORT

FOR 2025 REPORTING YEAR

Contents

I.   Introduction

2

II. Due Diligence Framework

3

OECD Step #1: Establish Strong Company Management Systems

3

1.  Company Policies

3

2.  Internal Management Team and Corporate Approval

4

3.  System of Supply Chain Controls, Data Disclosure, and Due Diligence Assurance

4

4.  Leveraging Industry Partnerships for Greater Impact

5

5.  Supplier Engagement to Ensure Conformance

6

6.  Grievance Mechanism

7

OECD Step #2: Identify and Assess Risk in the Supply Chain

7

Figure 1. CMRT Response Rate (2013-2025 Reporting Years)

8

OECD Step #3: Design and Implement a Strategy to Respond to Risks

8

7.  Microsoft Supplier Specifications - H00594, H00642, and H02050

8

8.  Implementation of OECD Guidance

8

OECD Step #4: Independent Third-Party Audits of Supply Chain Due Diligence

9

OECD Step #5: Report on Supply Chain Due Diligence

9

III.  Conflict Mineral Disclosure

9

Reasonable Countries of Origin of 3TGs

9

Figure 2. Identified SORs by Audit Status (2013- 2025 Reporting Years)

11

3TG Countries of Origin

12

IV.  Microsoft Commitment

13
Appendix A: Eligible Smelters and Refiners for 2025 Reporting Year A-1

1

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

I.

Introduction

This Conflict Minerals Report ("CMR") for MICROSOFT CORPORATION ("Microsoft") is filed with the United States Securities and Exchange Commission (SEC) as an exhibit to Microsoft's Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, (the "Rule") for the 2025 Reporting Year ("RY") (January 1, 2025-December 31, 2025).1 The CMR covers all Microsoft majority-owned subsidiaries and variable interest entities that are subject to the Rule.2 During the 2025 Reporting Year, covered devices included the Surface line of computers, tablets, and accessories; Xbox gaming consoles, accessories, and select merchandise manufactured or contracted to manufacture by Microsoft; the HoloLens mixed reality device; and Nuance dictation devices.

Our commitment to the responsible sourcing of raw materials is established by Microsoft's Responsible Sourcing of Raw Materials ("RSRM") Policy, which guides our work to ensure that all raw materials used in our devices, unbounded by specific materials or locations, are sourced from responsible suppliers. We commit to the responsible sourcing of tin, tantalum, tungsten, and gold ("3TGs") from Conflict Affected and High-Risk Areas ("CAHRAs"), including the Democratic Republic of the Congo ("DRC") or DRC-adjoining countries (each a "Covered Country" under the Rule), rather than restricting or avoiding sourcing from such regions. We do this in recognition of the harmful societal and economic impacts that curtailing 3TG mineral sourcing from such regions might cause.

Based on our supply chain due diligence, we determined that 3TGs that were necessary to the functionality or production of devices we manufactured or contracted to manufacture during the 2025 Reporting Year may have originated in a Covered Country. Microsoft found no reasonable basis for concluding that any 3TG Smelter or Refiner ("SOR") that was identified in the Microsoft Devices supply chain for the 2025 Reporting Year sourced 3TGs in a manner that directly or indirectly financed or benefitted armed groups in a Covered Country.

1

This CMR contains links to internal and external websites for informational purposes only. References to such websites and information available through such websites are not incorporated into this CMR. Additionally, this CMR includes forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. These forward-looking statements are based on current expectations and assumptions regarding the future implementation of our responsible sourcing program and are subject to change. Statements in this CMR are based on due diligence activities that were performed in good faith and to the best of our ability at the time of this filing. Factors that could affect the accuracy of such statements include, but are not limited to, incomplete or incorrect data submitted by suppliers, amendments to the Rule or SEC guidance.

2

Throughout this CMR, we use "Microsoft," "Microsoft Devices," "we," "our," "us" and similar terms to refer to Microsoft Corporation and its subsidiaries and various interest entities subject to the Rule (collectively, "Microsoft"), unless otherwise indicated.

2

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

II.

Due Diligence Framework

This CMR is based on Microsoft Devices' Due Diligence Framework ("Due Diligence Framework"), which conforms to 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 and its related Supplements ("OECD Guidance").

Our Microsoft Devices supply chain contains many layers of upstream suppliers positioned between Microsoft and 3TG raw material mines and SORs. We use contractual provisions to require our direct suppliers to disclose 3TG sourcing information through the Responsible Minerals Initiative ("RMI") industry standard Conflict Minerals Reporting Template (CMRT) and meet audit requirements regarding the sources and chains of custody of 3TGs necessary for the functionality or production of our covered devices. We also require our direct suppliers to cascade Microsoft requirements regarding 3TG sources and chains of custody to their own suppliers. In this manner, we work to promote responsible sourcing across our direct and cascading supply chains.

Our due diligence actions align to the OECD Guidance and fulfill the Rule including several quality assurance steps. We review all supplier responses to identify and address any inaccuracies or inconsistencies in the 3TG sourcing data that is reported to us. We engage a third party to review all 3TG sourcing data reported to us and to conduct due diligence on identified SORs. If a non-conformant SOR is reported by a supplier, we work with the supplier to engage with the SOR to bring them into conformance. If the SOR is not interested or not able to become conformant, we instruct suppliers to remove the SOR from their supply chain and source from conformant alternatives or face business termination with Microsoft.

We also survey our supply chain for minerals beyond 3TGs and beyond the Covered Countries consistent with our RSRM Policy, which is unbounded by specific materials or location. In addition to the CMRT survey, which is focused on 3TGs, we request our in-scope suppliers to report on their use of cobalt and other priority minerals, including aluminum, copper, gallium, lithium, nickel, silicon, germanium, graphite, and rare earth elements leveraging industry reporting templates. Through this process, we are able to discern additional risks in our supply chain.

OECD Step #1:

Establish Strong Company Management Systems

1.

Company Policies

Microsoft's commitment to corporate responsibility and integrity guides everything we do as a company. We have established high ethical standards to govern the way we conduct our business, which also apply to our suppliers and business partners. Microsoft policies include the Microsoft Global Human Rights Statement, Microsoft Supply Chain Human Rights Policy Statement, Trust Code, and our Supplier Code of Conduct. These policies establish Microsoft expectations for our suppliers concerning legal and regulatory compliance; business practices and ethics; human rights and fair labor practices; health and safety; environmental protection; and data and privacy protection.

As previously described, our RSRM Policy describes our commitment to responsibly sourcing raw materials. This pledge extends to the harvesting, extraction, and transportation of raw materials, unbounded by specific material or location, and supports implementation of programs that advance the use of responsibly sourced minerals in our manufactured devices.

3

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Our policies are based on internationally recognized standards, including the following declaration and covenants: Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and International Covenant on Economic, Social and Cultural Rights. Our business operations are informed by human rights guidelines described in the following documents: International Labor Organization's ("ILO") Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, and the United Nations Global Compact. As a global Information and Communications Technology company operating in more than 100 countries, we respect all human rights - civil, political, economic, social, and cultural; and our supplier requirements reflect the same level of commitment.

2.

Internal Management Team and Corporate Approval

A cross-functional internal team supports our program and CMR development. Microsoft's Director of Supply Chain Responsibility and Resilience sponsors the team, which consists of representatives from Microsoft Devices Operations; Responsible Sourcing Assurance; Corporate, External and Legal Affairs; and Trade. The team assesses program progress, identifies steps needed to meet our compliance obligations, and identifies areas for continuous improvement. The team annually develops, reviews, and submits the final CMR to Microsoft's President for approval and signature before being filed as an Exhibit to Microsoft's Form SD and posted on the Microsoft website pursuant to the Rule.

3.

System of Supply Chain Controls, Data Disclosure, and Due Diligence Assurance

Our Due Diligence Framework is based on a system of supply chain controls, data disclosure, and due diligence assurance. Our contracts require our suppliers to meet Microsoft specifications. Our environmental compliance specifications - H00594, Restricted Substances for Hardware Products; and H00642, Microsoft Restricted Substances Control System for Hardware Products (both available at this link) - require the disclosure of every substance contained in the materials, components, and products supplied to us, including 3TGs, by weight.

We require suppliers to annually submit a CMRT that provides source and chain of custody information for 3TGs that are contained in the products and components they supply to us. Our contracts also require suppliers to obtain the same information from their upstream suppliers. We collect these supply chain disclosures, conduct controls to ensure data integrity, and assess 3TG sourcing risk.

Microsoft supply chain mineral disclosure requirements go beyond 3TGs and cover additional prioritized minerals. Since 2019, we have required suppliers to report on their use of cobalt, using the Responsible Minerals Initiative's Extended Minerals Reporting Template ("EMRT") which includes copper, cobalt, mica, graphite, lithium, and nickel. Since 2024, we have utilized the RMI's Additional Minerals Reporting Template ("AMRT"), formerly known as the Pilot Reporting Template ("PRT"), for

4

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

all other prioritized minerals, including: aluminum, gallium, silicon, germanium and rare earth elements. These additional minerals are prioritized through an extensive internal review and risk analysis of the minerals present in our products. This regular prioritization exercise ensures that the minerals on which we focus are representative of identified need, and thus this list is dynamic over time.

Microsoft Supplier Social and Environmental Accountability Manual Excerpt ("H02050") provides an operational framework for Microsoft to achieve supplier conformance with Microsoft's Supplier Code of Conduct and other responsible sourcing requirements. H02050 establishes a minimum set of requirements that suppliers must meet, including compliance with all applicable laws and regulations with respect to labor, ethics, occupational health and safety, and protection of the environment. Suppliers are encouraged to go beyond legal compliance by meeting relevant international standards (e.g., ILO and relevant United Nations Conventions) and commit to a process of continuous improvement.

H02050 requires all in-scope suppliers to:

•

Adopt a company policy for raw material sourcing, including a commitment to source raw materials from responsible sources and clearly communicate such policy to their suppliers and the public;

•

Exercise due diligence on the source and chain of custody of high-risk raw materials, including 3TGs, contained in materials, products, or parts supplied to Microsoft;

•

Require SORs to participate in the Responsible Mining Assurance Process ("RMAP") or an equivalent independent, third-party audit program for 3TGs;

•

Timely communicate potential sourcing risks to Microsoft and propose a contingency plan and mitigation strategy to achieve conformance; and

•

Establish a system to gather, examine, and verify sourcing information for raw materials, including 3TGs, contained in products supplied to Microsoft and request their upstream suppliers to do the same. This supply chain transfer of audit data, source and chain of custody information, and risk assessment enables and facilitates raw material due diligence, mapping, and transparency.

Microsoft works with its suppliers to use SORs that are conformant to RMAP or another equivalent independent, third-party audit program for 3TGs. If we find that a supplier has introduced responsible sourcing risk to the Microsoft supply chain, such as use of an upstream SOR that is not conformant, Microsoft engages such supplier to address the non-conformance. Risks are mitigated by supplier engagement, audits, training, and business termination when appropriate. These controls and related documentation are detailed in H02050 and Microsoft internal operating procedures.

4.

Leveraging Industry Partnerships for Greater Impact

We leverage partnerships with industry peers and partners to scale our responsible sourcing impact. Microsoft is a long-standing member of the Responsible Business Alliance ("RBA") and the RMI. The RMI is one of the most utilized and respected resources for supply chain minerals due diligence and is aligned to the OECD Guidance. The RMI operates and manages the RMAP, which uses independent, third-party audits to assess, monitor, and validate whether SORs process 3TGs from sources that directly or indirectly finance, or benefit armed groups in a CAHRA, including Covered Countries.

5

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

In 2025, Microsoft provided direct financial support to the RMI upstream smelter due diligence fund and ESG audit fund to further the reach and success of the RMAP and participated in Working Groups to support the RMI and to improve and expand the scope of responsible mineral sourcing activities. For example, Microsoft's participation in the Smelter Engagement Team (SET) helps support RMI's goals of ensuring more smelters are participating in the RMAP and that current smelters stay engaged in the program.

We also work outside of our supply chain to promote responsible mining practices in CAHRAs, including Covered Countries, by partnering with organizations, including the RMI, the Initiative for Responsible Mining Assurance ("IRMA"), the Public-Private Alliance for Responsible Minerals Trade ("PPA"), and others. In this manner, we go beyond the minimum due diligence established by the OECD Guidance to assess and reduce our supply chain sourcing risk and improve working conditions in raw material supply chains.

5.

Supplier Engagement to Ensure Conformance

We apply several supplier-focused strategies to promote responsible mining and sourcing, including the supplier engagement tools set forth below.

•

Supplier Requirements: We require our suppliers to meet our material disclosure requirements and related responsible sourcing policies through contractual provisions and product specifications. We communicate, monitor, and track supplier adherence to these requirements, ensuring conformance through the Microsoft Compliance Map System.

•

Training: We train suppliers on our responsible sourcing requirements through classes, educational forums, and direct communications. Existing suppliers and newly onboarded suppliers are required to complete training modules to understand and implement Microsoft Social and Environmental Accountability ("SEA") requirements. We leverage the online component of our "SEA Academy" to educate factory management, workers, and third-party auditors as well as internal Microsoft teams with the goal of promoting responsible sourcing across our supply chain.

•

Capability Building and Partnerships: We work closely with in-scope suppliers and third-party auditors to build suppliers' raw material due diligence capabilities and advance conformance to the RMAP or equivalent independent, third-party audit program for 3TGs. We invest in industry programs to increase suppliers' abilities and provide platforms for sharing best practices.

•

Supplier Audits and Conformance Assurance: Microsoft requires audits of its directly contracted suppliers to assess their conformance to our Supplier Code of Conduct requirements. Newly contracted suppliers undergo an Initial Capability Assessment prior to onboarding and Sustaining Maintenance Audits after onboarding to verify their initial conformance and to confirm their sustained conformance to our requirements.

6

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Microsoft selects and retains business partners that are committed to meeting these requirements. A failure by a supplier or their upstream suppliers to conform to these requirements may constitute a breach of the supplier's contractual agreement with Microsoft, resulting in possible business termination.

6.

Grievance Mechanism

Microsoft provides an anonymous grievance reporting mechanism for employees and other stakeholders who may be impacted by our operations. Microsoft's Integrity Portal allows employees and others to anonymously ask compliance questions or report concerns regarding Microsoft's business operations, including our responsible sourcing policies or those of our suppliers. Additionally, Microsoft continues to scale its Worker Voice Hotline Program3 across our supplier factories. This program provides workers with a reliable and anonymous reporting channel for raising workplace concerns. The Hotline is operated by a neutral third-party provider. We investigate and, where appropriate, take remedial action to address reported issues. We also participate in the development of industry grievance mechanisms that seek to address responsible sourcing of raw materials-related issues.

OECD Step #2:

Identify and Assess Risk in the Supply Chain

In order to make a Reasonable Country of Origin Inquiry ("RCOI") determination, Microsoft took the following steps, which are consistent with OECD Guidance and Microsoft procedure, to identify and assess 3TG sourcing risk in our supply chain during the 2025 RY:

•

We generated a list of in-scope suppliers and surveyed 79 Microsoft Devices direct suppliers to determine whether they used any 3TGs in the products or parts supplied to Microsoft by utilizing the CMRT and the services of a third-party solution provider. All in-scope suppliers responded to our survey request - a 100% response rate. For these suppliers, we reviewed their CMRT responses to validate completion and to identify any contradictions or inconsistencies.

•

We excluded suppliers who did not report the use of 3TG minerals.

•

Based on the CMRTs, 266 SORs were found to be affiliated with RMAP or an equivalent, independent, third-party audit program for 3TG minerals such as cross-recognized programs overseen by the London Bullion Market Association ("LBMA") or Responsible Jewelry Council ("RJC").

3

Please see page 32 of our Human Rights Transparency Report for more details regarding our Workers' Voice Hotline Program.

7

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Figure 1. CMRT Response Rate (2013-2025 Reporting Years)

OECD Step #3:

Design and Implement a Strategy to Respond to Risks

We determined that 3TGs that were necessary to the functionality or production of covered devices may have originated in one or more Covered Countries. Accordingly, we performed due diligence on the source and chain-of-custody of those 3TGs to assess our conflict minerals sourcing risk.

7.

Microsoft Supplier Specifications - H00594, H00642, and H02050

For the 2025 RY, Microsoft required its in-scope suppliers to conduct due diligence to address the potential sourcing of 3TGs from CAHRAs, including Covered Countries, through contract requirements (H00594, H00642, and H02050), incorporating Microsoft's supplier specifications and responsible sourcing requirements, as detailed above.

8.

Implementation of OECD Guidance

Microsoft screened its in-scope supplier CMRT data for the 2025 RY against the OECD Guidance "red flag" triggers4 to assess the in-scope suppliers that required due diligence per the OECD Guidance.

4

See p. 33 of the OECD Guidance.

8

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

OECD Step #4:

Independent Third-Party Audits of Supply Chain Due Diligence

Our due diligence program leveraged independent SOR audits to provide assurance that the 266 Eligible 3TG SORs that were identified in our supply chain for the 2025 Reporting Year conducted an appropriate level of conflict minerals due diligence. Microsoft obtained SOR data from the RMAP Conformant Smelter List5 using Reasonable Country of Origin Inquiry Data for member MSFT and used the SOR data to assess the conflict mineral audit status of our in-scope suppliers and to support our due diligence findings.

Recognizing the importance of broad and consistent participation in the RMAP, Microsoft proactively engages directly with certain SORs where it is believed that a SOR may be at risk of becoming non-conformant. Microsoft also asks its suppliers to engage directly with potentially non-conformant SORs to prevent potential non-conformance as a Microsoft supplier. Although Microsoft's Responsible Sourcing program operates an escalation and engagement process should non-conformant SORs be detected, taking a proactive approach to potentially non-conformant SORs helps prevent potential non-conformances from occurring.

OECD Step #5:

Report on Supply Chain Due Diligence

We have filed our CMR with the SEC and posted it on our Microsoft Supply Chain Integrity website. The website provides additional information about Microsoft's RSRM Program. These disclosures meet the fifth step of the OECD Guidance.

III.

Conflict Mineral Disclosure

A.

Reasonable Countries of Origin of 3TGs

Microsoft obtained Reasonable Country of Origin data through our RMI membership using the Reasonable Country of Origin Inquiry Data for member MSFT. We used this data to determine the 3TG country of origin for the 266 Eligible SORs identified in Microsoft Devices' supply chain for the 2025 RY.

5

The RMAP Conformant Smelter list identifies the SORs that have undergone conformance audits through the RMAP or equivalent independent, third-party audit programs for 3TGs.

9

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

The RMAP classifies SOR audit status in the manner described in the table below. The breakdown of the identified 266 Eligible 3TG SORs (for which minerals sourcing information was available from RMAP or an equivalent, independent, third-party audit program for 3TGs) by their RMI Status was as follows:

Audit Status

Audit Status Description

SOR Count Percentage

Conformant

SOR has been audited and found to conform with a relevant, third-party audit protocol, including RMAP, LBMA, or RJC 220 82.7 %

Active

SOR has been engaged but is not yet conformant 6 2.3 %

Non-Conformant

SOR was audited but found not to conform to a relevant, third-party audit protocol or failed to renew its assessment 14 5.3 %

Outreach Required

SOR is not yet active, and outreach is needed by RMAP member companies to encourage SOR participation in RMAP 7 2.6 %

In Communication

SOR is not yet active but is in communication with RMAP and/or member company 1 0.4 %

RMI Due Diligence Review

Unable to Proceed: SOR has not met the threshold for Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted 5 1.9 %

Not Applicable

Facility has suspended or ceased operations however inventory potentially still used 13 4.9 %

For the identified 266 Eligible 3TG SORs:

•

31 SORs sourced from Covered Countries, of which 31 (100%) were Conformant.

•

Out of 266 Eligible SORs, 226 (84.9%) were participating in a third-party audit program (either Conformant or Active); and

•

The remaining SORs were reasonably believed to have sourced 3TGs from outside the Covered Countries.

Microsoft found no reasonable basis for concluding that any SOR sourced 3TGs in a manner that directly or indirectly financed or benefitted armed groups in a Covered Country. Figure 2 depicts the SORs by 3TG audit status and Reporting Year.

10

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Figure 2. Identified SORs by Audit Status (2013- 2025 Reporting Years)

Appendix A provides the list of 266 Eligible SORs identified in Microsoft Devices' supply chain which processed 3TGs during the 2025 Reporting Year. Appendix A lists each SOR by mineral, official name, and country of operation.

11

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

3TG Countries of Origin

The table below lists the countries of origin for the 266 Eligible SORs identified in the Microsoft Devices' supply chain and which processed 3TG minerals during the 2025 RY.

Andorra Italy Tanzania
Australia Japan Thailand
Austria Kazakhstan Turkey
Belgium Korea, Republic of Uganda
Bolivia Malaysia United States of America
Brazil Mexico Uzbekistan
Canada Myanmar Vietnam
Chile Netherlands
China Peru
Colombia Philippines
Congo, Democratic Republic of the Poland
Czech Republic Rwanda
Estonia Singapore
France South Africa
Germany Spain
Hong Kong Sweden
India Switzerland
Indonesia Taiwan

12

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

IV.

Microsoft Commitment

Microsoft is committed to the responsible sourcing of raw materials in support of human rights; labor, health and safety; and environmental protection. We continue to advance implementation of our RSRM policy in our Microsoft Devices supply chain to promote supply chain identification, traceability, risk assessment, and due diligence.

Our 2025 RY achievements included the following:

•

We supported supplier efforts to increase their responsible sourcing capabilities through supplier forums, training, webinars, and by providing technical resources;

•

We continued our engagements with external responsible sourcing organizations, including but not limited to the RMI, that are committed to advancing responsible sourcing on a global basis;

•

We achieved a 100% supplier CMRT response rate through extensive supplier outreach, including a supplementary campaign to directly contact suppliers and encourage reporting;

•

We conducted a data validation and verification program to randomly audit CMRT information submitted to us by suppliers to validate and confirm that supplier data was accurate and complete;

•

Leveraged Full Material Disclosure and other supplier data to fine-tune supplier data requests and verify and confirm reported critical raw material information.

Going forward, Microsoft will remain focused on internal and external efforts to promote the responsible sourcing of minerals, including:

•

Expanding our knowledge about 3TGs, cobalt, and other critical raw materials to effectively implement our RSRM strategy to promote the responsible sourcing of raw materials across our hardware supply chains;

•

Requiring our in-scope suppliers to meet our requirements for responsibly sourcing raw materials and finding alternative upstream suppliers if they are found to be sourcing from non-conformant SORs;

•

Engaging with in-scope suppliers so that they utilize supplier best practices and tools for responsibly sourcing raw materials from CAHRAs, including Covered Countries;

•

Furthering engagement with industry organizations and external stakeholders to improve mineral traceability, establish global responsible sourcing standards, and support due diligence programs in the mineral supply chain; and

13

Appendix A

Eligible SORs for 2025 Reporting Year

This Appendix lists the 266 eligible SORs which processed 3TG minerals during the 2025 RY. Please note that Eligible SORs are listed for each 3TG they processed. Therefore, certain Eligible SORs may be represented more than once.

Gold

Smelter Name

Country

ABC Refinery Pty Ltd. Australia
Abington Reldan Metals, LLC United States of America
Advanced Chemical Company United States of America
Agosi AG Germany
Aida Chemical Industries Co., Ltd. Japan
Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan
AngloGold Ashanti Corrego do Sitio Mineracao Brazil
Argor-Heraeus S.A. Switzerland
ASAHI METALFINE, Inc. Japan
Asahi Refining Canada Ltd. Canada
Asahi Refining USA Inc. United States of America
Asaka Riken Co., Ltd. Japan
Aurubis AG, Hamburg Germany
Bangalore Refinery India
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines
Boliden Mineral AB (Ronnskar) Sweden
C. Hafner GmbH + Co. KG Germany
Caridad Mexico
Chimet S.p.A. Italy
Chugai Mining Japan
Coimpa Industrial LTDA Brazil
Daye Non-Ferrous Metals Mining Ltd. China
Dowa Japan
DSC (Do Sung Corporation) Korea, Republic of
Eco-System Recycling Co., Ltd. East Plant Japan
Eco-System Recycling Co., Ltd. North Plant Japan
Eco-System Recycling Co., Ltd. West Plant Japan
Elite Industech Co., Ltd. Taiwan
GG Refinery Ltd. Tanzania
GGC Gujrat Gold Centre Pvt. Ltd. India
Glencore Canada Corporation - CCR Refinery Canada

A-1

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Gold by Gold Colombia Colombia
Gold Corporation - The Perth Mint Australia
Great Wall Precious Metals Co., Ltd. of CBPM China
Hangzhou Fuchunjiang Smelting Co., Ltd. China
Heimerle + Meule GmbH Germany
Heraeus Germany GmbH Co. KG Germany
Heraeus Metals Hong Kong Ltd. Hong Kong
Hunan Chenzhou Mining Co., Ltd. China
Impala Platinum - Base Metal Refinery (BMR) South Africa
Impala Platinum - Platinum Metals Refinery (PMR) South Africa
Impala Platinum - Rustenburg Smelter South Africa
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China
Ishifuku Metal Industry Co., Ltd. Japan
Istanbul Gold Refinery Turkey
Italpreziosi Italy
Japan Mint Japan
Jiangxi Copper Co., Ltd. China
JX Advanced Metals Corporation Japan
Kazzinc Ltd Kazakhstan
Kennecott Utah Copper LLC United States of America
KGHM Polska Miedz Spolka Akcyjna Poland
Kojima Chemicals Co., Ltd. Japan
Korea Zinc Co., Ltd. Korea, Republic of
L'Orfebre S.A. Andorra
LS MnM Inc. Korea, Republic of
LT Metal Ltd. Korea, Republic of
Materion United States of America
Matsuda Sangyo Co., Ltd. Japan
Metal Concentrators SA (Pty) Ltd. South Africa
Metalor Technologies (Hong Kong) Ltd. China
Metalor Technologies (Singapore) Pte., Ltd. Singapore
Metalor Technologies (Suzhou) Ltd. China
Metalor Technologies S.A. Switzerland
Metalor USA Refining Corporation United States of America
Metalurgica Met-Mex Penoles S.A. De C.V. Mexico
Mitsubishi Materials Corporation Japan
Mitsui Mining and Smelting Co., Ltd. Japan
MKS PAMP SA Switzerland
MMTC-PAMP India Pvt., Ltd. India
Nadir Metal Rafineri San. Ve Tic. A.S. Turkey
Navoi Mining and Metallurgical Combinat Uzbekistan
NH Recytech Company Korea, Republic of
Nihon Material Co., Ltd. Japan

A-2

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Oegussa Oesterreichische Gold- und Silber-Scheideanstalt Gesm.b.H. Austria
Ohura Precious Metal Industry Co., Ltd. Japan
Planta Recuperadora de Metales SpA Chile
PT Aneka Tambang (Persero) Tbk Indonesia
PX Precinox S.A. Switzerland
Rand Refinery (Pty) Ltd. South Africa
REMONDIS PMR B.V. Netherlands
Royal Canadian Mint Canada
SAFINA A.S. Czechia
SEMPSA Joyeria Plateria S.A. Spain
Shandong Gold Smelting Co., Ltd. China
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China
Sichuan Tianze Precious Metals Co., Ltd. China
Solar Applied Materials Technology Corp. Taiwan
SOLEIL METALS (Chala One Plant) Peru
SOLEIL METALS (YAKARI Plant) Peru
Sumitomo Metal Mining Co., Ltd. Japan
SungEel HiMetal Co., Ltd. Korea, Republic of
T.C.A S.p.A Italy
Tanaka Kikinzoku Kogyo K.K. Japan
Tokuriki Honten Co., Ltd. Japan
TOO Tau-Ken-Altyn Kazakhstan
Torecom Korea, Republic of
Umicore S.A. Business Unit Precious Metals Refining Belgium
United Precious Metal Refining, Inc. United States of America
Valcambi S.A. Switzerland
WEEEREFINING France
WIELAND Edelmetalle GmbH Germany
Yamakin Co., Ltd. Japan
Yokohama Metal Co., Ltd. Japan
Zhongyuan Gold Smelter of Zhongjin Gold Corporation China
Zijin Mining Group Gold Smelting Co. Ltd. China

Tantalum

Smelter Name Country
AMG Brasil Brazil
Changsha South Tantalum Niobium Co., Ltd. China
CMT Rare Metal Advanced Materials (Hunan) Co., Ltd. China
D Block Metals, LLC United States of America
F&X Electro-Materials Ltd. China
FIR Metals & Resource Ltd. China
Global Advanced Metals Aizu Japan
Global Advanced Metals Boyertown United States of America

A-3

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Guangdong Rising Rare Metals-EO Materials Ltd. China
Hengyang King Xing Lifeng New Materials Co., Ltd. China
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China
Jiangxi Suns Nonferrous Materials Co. Ltd. China
Jiangxi Tuohong New Raw Material China
Jiujiang Janny New Material Co., Ltd. China
JiuJiang JinXin Nonferrous Metals Co., Ltd. China
Jiujiang Tanbre Co., Ltd. China
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China
KEMET de Mexico Mexico
Materion Newton Inc. United States of America
Metallurgical Products India Pvt., Ltd. India
Mineracao Taboca S.A. Brazil
Mitsui Kinzoku Company, Limited Japan
Ningxia Orient Tantalum Industry Co., Ltd. China
NPM Silmet OU Estonia
PowerX Ltd. Rwanda
STEREON Metals Hermsdorf GmbH Germany
QuantumClean United States of America
Resind Industria e Comercio Ltda. Brazil
RFH Yancheng Jinye New Material Technology Co., Ltd. China
Taki Chemical Co., Ltd. Japan
TANIOBIS Co., Ltd. Thailand
TANIOBIS GmbH Germany
TANIOBIS Japan Co., Ltd. Japan
TANIOBIS Smelting GmbH & Co. KG Germany
Telex Metals United States of America
Ulba Metallurgical Plant JSC Kazakhstan
XIMEI RESOURCES (GUANGDONG) LIMITED China
XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD. China
XinXing HaoRong Electronic Material Co., Ltd. China
Yanling Jincheng Tantalum & Niobium Co., Ltd. China

Tin

Smelter Name Country
Alpha Assembly Solutions Inc United States of America
Aurubis Beerse Belgium
Aurubis Berango Spain
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China
Chifeng Dajingzi Tin Industry Co., Ltd. China
China Tin Group Co., Ltd. China
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil

A-4

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

CRM Synergies EMEA, S.L.U. Spain
CV Ayi Jaya Indonesia
CV Venus Inti Perkasa Indonesia
Dongguan Best Alloys Co., Ltd. China
Dowa Japan
DS Myanmar Myanmar
Empresa Metallurgica Vinto Bolivia
Estanho de Rondonia S.A. Brazil
Fabrica Auricchio Industria e Comercio Ltda. Brazil
Feinhutte Halsbrucke GmbH Germany
Fenix Metals Poland
Gejiu Non-Ferrous Metal Processing Co., Ltd. China
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China
Global Advanced Metals Greenbushes Pty Ltd. Australia
Guangdong Hanhe Non-ferrous Metal Limited Company China
Hebei Anruisai Renewable Resources Recycling Co.,Ltd. China
HuiChang Hill Tin Industry Co., Ltd. China
Jiangxi New Nanshan Technology Ltd. China
Luna Smelter, Ltd. Rwanda
Magnu's Minerais Metais e Ligas Ltda. Brazil
Malaysia Smelting Corporation (MSC) Malaysia
Malaysia Smelting Corporation Berhad (Port Klang) Malaysia
Melt Metais e Ligas S.A. Brazil
Metallic Resources, Inc. United States of America
Mineracao Taboca S.A. Brazil
Mining Minerals Resources SARL Congo, Democratic Republic of the
Minsur Peru
Mitsubishi Materials Corporation Japan
O.M. Manufacturing (Thailand) Co., Ltd. Thailand
O.M. Manufacturing Philippines, Inc. Philippines
Operaciones Metalurgicas S.A. Bolivia
P Kay Metal, Inc United States of America
Precious Minerals and Smelting Limited India
PT Aries Kencana Sejahtera Indonesia
PT Arsed Indonesia Indonesia
PT Artha Cipta Langgeng Indonesia
PT ATD Makmur Mandiri Jaya Indonesia
PT Babel Inti Perkasa Indonesia
PT Babel Surya Alam Lestari Indonesia
PT Bangka Prima Tin Indonesia
PT Bangka Serumpun Indonesia
PT Bukit Timah Indonesia
PT Cipta Persada Mulia Indonesia

A-5

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

PT Masbro Alam Stania Indonesia
PT Menara Cipta Mulia Indonesia
PT Mitra Stania Prima Indonesia
PT Mitra Sukses Globalindo Indonesia
PT Premium Tin Indonesia Indonesia
PT Prima Timah Utama Indonesia
PT Putera Sarana Shakti (PT PSS) Indonesia
PT Rajawali Rimba Perkasa Indonesia
PT Rajehan Ariq Indonesia
PT Refined Bangka Tin Indonesia
PT Sariwiguna Binasentosa Indonesia
PT Stanindo Inti Perkasa Indonesia
PT Sukses Inti Makmur (SIM) Indonesia
PT Timah Tbk Kundur Indonesia
PT Timah Tbk Mentok Indonesia
PT Tinindo Inter Nusa Indonesia
PT Tommy Utama Indonesia
Resind Industria e Comercio Ltda. Brazil
Rui Da Hung Taiwan
Soft Metais Ltda. Brazil
Super Ligas Brazil
Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. Japan
Thai Nguyen Mining and Metallurgy Co., Ltd. Vietnam
Thaisarco Thailand
Tin Smelting Branch of Yunnan Tin Co., Ltd. China
Tin Technology & Refining United States of America
TRATHO Metal Quimica Brazil
White Solder Metalurgia e Mineracao Ltda. Brazil
Woodcross Smelting Company Limited Uganda
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China
Yunnan Yunfan Non-ferrous Metals Co., Ltd. China

Tungsten

Smelter Name Country
A.L.M.T. Corp. Japan
Asia Tungsten Products Vietnam Ltd. Vietnam
China Molybdenum Tungsten Co., Ltd. China
Chongyi Zhangyuan Tungsten Co., Ltd. China
Cronimet Brasil Ltda Brazil
Fujian Xinlu Tungsten Co., Ltd. China
Ganzhou Huaxing Tungsten Products Co., Ltd. China
Ganzhou Jiangwu Ferrotungsten Co., Ltd. China

A-6

EXHIBIT 1.01 - MICROSOFT CORPORATION CONFLICT MINERALS REPORT FOR 2025 REPORTING YEAR

Ganzhou Seadragon W & Mo Co., Ltd. China
Global Tungsten & Powders LLC United States of America
Guangdong Xianglu Tungsten Co., Ltd. China
H.C. Starck Tungsten GmbH Germany
Hubei Green Tungsten Co., Ltd. China
Hunan Chenzhou Mining Co., Ltd. China
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch China
Japan New Metals Co., Ltd. Japan
Jiangwu H.C. Starck Tungsten Products Co., Ltd. China
Jiangxi Gan Bei Tungsten Co., Ltd. China
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China
Jiangxi Xinsheng Tungsten Industry Co., Ltd. China
Jiangxi Yaosheng Tungsten Co., Ltd. China
Jing Yuan Tungsten Technology Co., Ltd. Taiwan
KENEE MINING VIETNAM COMPANY LIMITED Vietnam
Kennametal Fallon United States of America
Kennametal Huntsville United States of America
Lianyou Metals Co., Ltd. Taiwan
Lianyou Resources Co., Ltd. Taiwan
Malipo Haiyu Tungsten Co., Ltd. China
Masan High-Tech Materials Vietnam
Niagara Refining LLC United States of America
Philippine Bonway Manufacturing Industrial Corporation Philippines
Philippine Carreytech Metal Corp. Philippines
Philippine Chuangxin Industrial Co., Inc. Philippines
Shinwon Tungsten (Fujian Shanghang) Co., Ltd. China
TANIOBIS Smelting GmbH & Co. KG Germany
Tungsten Vietnam Joint Stock Company Vietnam
Wolfram Bergbau und Hutten AG Austria
Xiamen Tungsten (H.C.) Co., Ltd. China
Xiamen Tungsten Co., Ltd. China

A7

Microsoft Corporation published this content on May 28, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on May 28, 2026 at 21:06 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]