Apple : Specialized Disclosure Report

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

Apple Inc.

(Exact name of registrant as specified in its charter)

(State or other jurisdiction of incorporation or organization)

California

001-36743 (Commission File Number)

One Apple Park Way

Cupertino, California 95014 (Address of principal executive offices) (Zip Code)

Katherine Adams

Senior Vice President, General Counsel and Secretary

[phone]

(Name and telephone number, including area code, of the person to contact in connection with this report.)

94-2404110 (IRS Employer Identification No.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

☒

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.

Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

A copy of Apple Inc.'s ("Apple's") Conflict Minerals Report for the reporting period January 1, 2018 to December 31, 2018 is provided as Exhibit 1.01 hereto and is publicly available at investor.apple.com/sec.cfm.* Apple's determination and related disclosures relating to materials that may come from recycled and scrap sources are included in Apple's Conflict Minerals Report and incorporated by reference herein.

Section 2 - Exhibits

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2018 to December 31, 2018.

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* The reference to Apple's website is provided for convenience only, and its contents are not incorporated by reference into this Form SD and the Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.

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SIGNATURE

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

Apple Inc.

By: /s/ Katherine Adams

Date: February 15, 2019

Katherine Adams Senior Vice President,

General Counsel and Secretary

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Exhibit 1.01

CONFLICT MINERALS REPORT

Summary of Apple's Commitment to Responsible Sourcing

Apple is deeply committed to upholding human rights across its global network of suppliers that support the manufacturing of its mobile communication and media devices, personal computers, and related accessories. Apple works to safeguard the well-being of people involved in its supply chain and to protect the places where materials are sourced. Through its strict supplier standards, Apple commits to use minerals in its products that do not directly or indirectly finance armed conflict or benefit armed groups.

As of December 31, 2018-for the fourth straight year-100 percent of identified smelters and refiners 1 in Apple's supply chain for all applicable products 2 manufactured during calendar year 2018 participated in an independent third-party conflict minerals audit ("Third Party Audit") program for columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which presently are limited to tantalum, tin, and tungsten (collectively, "3TG"). In 2018, Apple directed its suppliers to remove from its supply chain five smelters and refiners not willing to participate in, or complete, a Third Party Audit or that did not otherwise meet Apple's requirements on the responsible sourcing of minerals. Of the 253 smelters and refiners of 3TG determined to be in Apple's supply chain as of December 31, 2018, Apple found no reasonable basis for concluding that any such smelter or refiner sourced 3TG that directly or indirectly finance or benefit armed groups.

Apple is committed to going beyond the minimum requirements in order to meet and exceed internationally accepted due diligence standards and protect people in its supply chain, with the ultimate goal of improving conditions on the ground in the Democratic Republic of the Congo ("DRC") and adjoining countries. First, Apple maintains a strict Supplier Code of Conduct ("Supplier Code") and Supplier Responsibility Standard on the Responsible Sourcing of Materials ("Responsible Sourcing Standard") that apply to all levels of its supply chain and require suppliers to engage with smelters and refiners in Apple's supply chain to assess and identify a broader range of risks beyond conflict risk, such as social, environmental and human rights risks. Second, Apple annually reviews reported incidents and public allegations of abuse that are potentially linked to certain smelters and refiners in its supply chain, and uses that information to help improve 3TG traceability and Third Party Audit programs. Third, Apple supports grassroots and whistleblower initiatives that empower independent, local voices to raise issues and report abuses at the mine-site level and throughout the supply chain. Finally, as part of its commitment to help to safeguard the well-being of people involved in its supply chain, Apple has integrated human rights impact measurements into its overall minerals due diligence program.

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253 in total as of December 31, 2018

2 Apple products that were manufactured, or contracted to be manufactured, during 2018 and that contain conflict minerals. These products are Apple's iPhone ® , iPad ® , Mac ® , iPod ® , Apple TV ® , Apple Watch ® , AirPods ® , HomePod™, Beats ® products, and Apple accessories.

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As the African Great Lakes region faces ongoing challenges to achieve lasting change, Apple remains committed to continue responsibly sourcing 3TG from the region. Apple believes that all stakeholders-governments, non-governmental organizations, industries, and local communities-should enhance their efforts to implement comprehensive due diligence programs and work together to measure impact and improve conditions in the region.

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