Stoneridge : Conflict Minerals Disclosure 2023

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

STONERIDGE, INC.

(Exact name of the registrant as specified in its charter)

Ohio	001-13337
(State or other jurisdiction of incorporation)				(Commission file number)
39675 MacKenzie Drive, Suite 400, Novi, Michigan	48377
(Address of principal executive offices)				(Zip Code)

Matthew R. Horvath [phone]

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

Check the appropriate box to indicate the rule pursuant to which this form is being filed:

• Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.

• Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended
  _____.

Section 1 - Conflict Mineral Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Stoneridge, Inc. (the "Company") evaluated the product lines in its three reportable segments, and determined that some products it manufactured or contracted to manufacture in 2023 contained tantalum, tin, tungsten and/or gold, as defined by paragraph (d)(3) of Item 1.01 of Form SD, (collectively "Conflict Minerals"). These Conflict Minerals are necessary to the functionality or production of some Company products.

The Company conducted a reasonable good faith country of origin inquiry regarding Conflict Minerals included in parts sourced from our suppliers to determine whether these Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country, as defined by paragraph (d)(1) of Item 1.01 of Form SD, or arose from recycled or scrap sources. The Company has exercised due diligence on the source and chain of custody of its Conflict Minerals that conforms to the Organisation for Economic Cooperation and Development ("OECD") Due Diligence Framework for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas.

In accordance with paragraph (c) of Item 1.01 of Form SD, the Company's Conflict Minerals Report ("CMR") for the reporting period January 1, 2023 to December 31, 2023 is provided as Exhibit 1.01 hereto.

The CMR and Company's Conflict Minerals Policy are publicly available at https:// www.stoneridge.com/sustainability/. Information contained on the Company's website is not part of, nor incorporated by reference into, this Form SD or the CMR.

Item 1.02 Exhibit

A copy of the Company's CMR as required by Item 1.01 is filed as Exhibit 1.01 hereto.

Section 2 - Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure Report

Not Applicable.

Section 3 - Exhibits

Item 3.01 Exhibits

Exhibit 1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.

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.

	Stoneridge, Inc.
Date: May 30, 2024	/s/ Matthew R. Horvath
	Matthew R. Horvath
	Chief Financial Officer and Treasurer
	(Principal Financial Officer)

Exhibit 1.01

Stoneridge, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2023

This Conflict Minerals Report ("CMR") for the year ended December 31, 2023 by Stoneridge, Inc. and its subsidiaries (collectively, the "Company" or "we") is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Conflict Minerals Rule"), and 1.01(c) of Form SD. The Conflict Minerals Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to Conflict Minerals as directed by Section 1502 Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). The Conflict Minerals Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals that are necessary to the functionality or production of their products. Conflict Minerals are defined by the Conflict Minerals Rule to include cassiterite, columbite-tantalite, gold, wolframite, and their derivatives. The subject minerals are more commonly known as tin, tantalum, gold, and tungsten. The Company is committed to complying with the requirements regarding the use of Conflict Minerals under Section 1502 of the Dodd-Frank Act and the related rules issued by the SEC.

If a SEC registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or certain adjoining countries (the "Covered Countries") or from recycled or scrap sources, it must submit a Form SD, which describes the reasonable country of origin inquiry completed by the SEC registrant. If a SEC registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in any of the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the SEC registrant must exercise due diligence on the Conflict Minerals' source and chain of custody.

Forward-Looking Statements

Forward-looking statements contained in this CMR are made based on known events and circumstances at the time of release and, as such, are subject in the future to unforeseen uncertainties and risks. Statements in this CMR that express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements, including statements related to the Company's compliance efforts and expected actions identified in this CMR. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other matters, the Company's customers' requirements to use certain suppliers, the Company's suppliers' responsiveness and cooperation with the Company's due diligence efforts, the Company's ability to implement improvements in its conflict minerals program and the Company's ability to identify and mitigate related risks in its supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see the Company's other filings with the SEC, including its Annual Report on Form 10-K for the year ended December 31, 2023. The Company makes these statements as of the date of this disclosure, and undertakes no obligation to update them unless otherwise required by law.

1. COMPANY OVERVIEW

The Company is a global designer and manufacturer of highly engineered electrical and electronic systems, components and modules primarily for the automotive, commercial, off-

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highway and agricultural vehicle markets. Our products and systems are critical elements in the management systems to improve overall vehicle performance, convenience and monitoring in areas such as safety and security, intelligence, efficiency and emissions. Our product offerings consist of actuators, sensors, switches and connectors, driver information systems, vision and safety systems, connectivity and compliance products, electronic control units, vehicle tracking devices and monitoring services, vehicle security alarms and convenience accessories, in- vehicle audio and infotainment devices and telematics solutions. The Company's business and products are more fully described on the Company's public website (www.stoneridge.com).

This CMR relates to the Company's process undertaken with respect to the products that were manufactured or contracted to be manufactured during calendar year 2023 that may contain Conflict Minerals. Assessing the commercial vehicle and automotive industry supply chain is a very complex, interdependent undertaking. As a result, we rely on our direct suppliers to provide the Company with information about the source of Conflict Minerals contained in their parts/ products and their downstream supplier products.

The following is a list of our products for which source of origin information was solicited from our Company's suppliers regarding Conflict Minerals content or Conflict Minerals use in products, components or parts supplied to the Company:

Actuators, sensors, switches and connectors, driver information systems, vision and safety systems, connectivity and compliance products, electronic control units, vehicle tracking devices and monitoring services, vehicle security alarms and convenience accessories, in-vehicle audio and infotainment devices and telematics solutions.

2. DETERMINATION OF PRODUCTS LIKELY TO CONTAIN CONFLICT MINERALS

The Company has determined that Conflict Minerals necessary to the functionality or production of its products were likely present in some products, components or parts purchased from our suppliers.

3. REASONABLE COUNTRY OF ORIGIN INQUIRY

The Company does not purchase Conflict Minerals directly from smelters or mines in the Covered Countries, but purchases parts and components from suppliers that may contain Conflict Minerals, and therefore is several levels removed from the actual mining and smelting of Conflict Minerals. After our initial assessment that some supplier parts likely contain Conflict Minerals, we conducted a reasonable country of origin inquiry ("RCOI") to determine which products, components or parts purchased by the Company contain Conflict Minerals and whether such Conflict Minerals originated in the Covered Countries.

We rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to them from other suppliers. We engaged iPoint to contact each of our suppliers (whose products had the potential to contain Conflict Minerals), using the iPoint Conflict Minerals Platform ("iPCMP"), and asked them to provide information on (1) whether Conflict Minerals were present in the products, components or parts purchased from that supplier, (2) whether the source of the Conflict Minerals was from the Covered Countries and (3) if so, information about the smelters or refiners who directly purchased the Conflict Minerals in their supply chain and specific due diligence measures performed thereon. The tools used to conduct this survey were the Conflict Minerals Reporting Template ("CMRT") developed by the

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Responsible Minerals Initiative ("RMI") and the iPCMP. The due diligence framework used to support our reasonable country of origin inquiry, our outreach and data review process and our conclusions are discussed below in this Conflict Minerals Report.

4. DUE DILIGENCE FRAMEWORK

The Company designed its due diligence framework to conform with the five-step framework provided by 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, an internationally recognized due diligence framework.

1. Establish Strong Company Management Systems
2. • The Company identified a cross-functional management team consisting of representatives from Procurement, Legal and Finance functions to oversee the Conflict Mineral program.
   • The Company has adopted a Conflict Minerals policy, which is available on our website: https://www.stoneridge.com/sustainability/.
   • The Company distributed communications by way of training/educational materials and/or contract provisions to its supply chain informing suppliers of their obligation for reporting and disclosure of Conflict Minerals.
   • The Company also leveraged the work performed by industry working groups to assist with interpretation and execution to the Dodd-Frank Act and OECD Due Diligence Framework.
3. Identify and Assess Risks in Our Supply Chain
4. • Based upon the size and complexity of our supply base, the various markets we participate in, and the number of products we provide, we took a risk-based approach, which resulted in a supplier centric method for inquiry based upon the nature of the material supplied and the likelihood of Conflict Mineral content.
   • Because the Company does not purchase Conflict Minerals directly from smelters or mines, the Company relies on our suppliers, whose components may contain Conflict Minerals, to provide us with information about the source of Conflict Minerals contained in the components supplied to us. Many of our direct suppliers are similarly reliant upon information provided by their suppliers.
   • The Company leveraged the RMI CMRT and iPCMP to conduct our inquiry and gather information for our due diligence efforts.
   • The Company evaluated all supplier responses, with particular emphasis on those with responses identified as high-risk.
5. Design and Implement a Strategy to Respond to Identified Risks
6. • The Company designed a risk mitigation and corrective action plan through which the due diligence activities have been performed.

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1. • The Company performed periodic management tracking of supplier responses or lack thereof.
   • Unresponsive suppliers or inadequate responses were addressed utilizing follow-up communications.
   • The Company evaluated responses and assessed smelter information provided against the RMI member data.
2. Perform Independent Third-party Audit of Smelter/Refinery Due Diligence Practices
3. • The Company does not have a direct relationship with Conflict Minerals smelters and refiners, and therefore has not performed audits of these entities within its supply chain. However, as a member of RMI, the Company supports audits conducted by third parties by urging our suppliers to gather information from their suppliers to accurately complete the CMRT.
   • The Company relies upon industry-wide efforts to encourage smelters to be audited and to provide certifications through RMI's Responsible Minerals Assurance Process ("RMAP") and tracks which smelters have been audited via RMI.
4. Report Annually on Supply Chain Due Diligence
5. • In compliance with SEC rules, as directed by the Dodd-Frank Act, the Company files a Form SD and this Conflict Minerals Report with the SEC by May 31 of each year, covering the period of the prior calendar year, and makes these documents available on our website: https://www.stoneridge.com/sec-filings/.

5. RESULTS OF REASONABLE COUNTRY OF ORIGIN INQUIRY EFFORTS

For the calendar year 2023, the Company contacted 207 suppliers, some numerous times, to provide RCOI information and received acceptable responses from 76.8% of them.

Based on the information provided by our suppliers, the Company believes the smelters and refiners that may have been used to produce Conflict Minerals in the Company's products include those listed in Item 7.

6. STEPS TAKEN TO MITIGATE RISK

The Company continually works towards a conflict mineral-free supply chain. The Company is a member of the Responsible Minerals Initiative in order to enhance its due diligence framework. The Company regularly evaluates its due diligence program. In particular, the Company annually reviews the criteria used to select suppliers for inquiry and engages with our suppliers to identify the Conflict Minerals used within its supply chain, as well as the origin and chain of custody of those Conflict Minerals. The Company will continue to educate and train suppliers and encourage them to adopt their own Conflict Minerals program. The Company will also continue to communicate to its suppliers who have not satisfied our due diligence requests to provide complete and accurate responses and to perform due diligence procedures on their suppliers as well as promote that each of the smelters and refiners within their supply chain be certified. Finally, to the extent any Company supplier is found to be using not-yet-validated smelters and refiners within its supply chain, the Company intends to engage that supplier and re-communicate our requirement for suppliers to commit that parts supplied to the Company

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shall not be derived from sources that finance or benefit armed groups in the Covered Countries.

7. SMELTER/REFINER INFORMATION AND COUNTRY OF ORIGIN

Pursuant to guidance issued by the SEC Division of Corporation Finance on April 29, 2014, we are not required to describe any of our products as "DRC Conflict Free," as having "not been found to be 'DRC Conflict Free'" or as "DRC Conflict Undeterminable." Moreover, since we have not voluntarily elected to describe any of our products as DRC Conflict Free, the requirement for an independent private sector audit of this report is not applicable.

Table 1 reflects our RCOI and due diligence for tantalum, tin and tungsten. Table 2 reflects our RCOI and due diligence for gold. The countries listed in the tables are potential sources of origin of the Conflict Minerals that may be contained in the parts and components we purchase from our suppliers.

Table 1

	Tantalum			Tin			Tungsten
Australia	Madagascar		Australia	Russia		Australia	Nigeria
Brazil	Mozambique		Bolivia	Rwanda		Austria	Peru
Burundi	Nigeria		Brazil	Spain		Bolivia	Portugal
China	Rwanda		Burundi	Tanzania		Brazil	Russia
DRC	Sierra Leone		China	Thailand		Burundi	Rwanda
Ethiopia	Spain		Colombia	United Kingdom		China	Spain
France			DRC	Venezuela		DRC	Tanzania
			Indonesia	Vietnam		Kazakhstan	Thailand
			Laos			Kyrgyzstan	Uganda
			Malaysia			Malaysia	United Kingdom
			Myanmar			Mexico	USA
			Nigeria			Mongolia	Vietnam
			Peru			Myanmar	Zimbabwe

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Table 2

Gold

Argentina	Fiji	Mauritania	South Africa
Australia	Finland	Mexico	South Korea
Azerbaijan	French Guiana	Mongolia	Spain
Benin	Georgia	Morocco	Sudan
Bolivia	Ghana	Mozambique	Suriname
Botswana	Guatemala	Namibia	Sweden
Brazil	Guinea	New Zealand	Tanzania
Burkina Faso	Guyana	Nicaragua	Turkey
Cambodia	Honduras	Niger	USA
Canada	Indonesia	Oman	Uzbekistan
Chile	Japan	Panama	Zambia
China	Kazakhstan	Papua New Guinea	Zimbabwe
Colombia	Kenya	Peru
Côte d'Ivoire	Kyrgyzstan	Philippines
DRC	Laos	Russia
Dominican Republic	Liberia	Saudi Arabia
Ecuador	Malaysia	Senegal
Egypt	Mali	Serbia
Table 3

We believe that, to the extent determinable, the facilities that were used to process the Conflict Minerals contained in our products include the smelters/refiners listed below. The information in this list is an aggregation of data provided by our suppliers and not a confirmation of Conflict Minerals contained in our products.

Metal	Smelter or Refiner Name	Country	Smelter ID
Gold	Abington Reldan Metals, LLC	UNITED STATES OF	CID002708
		AMERICA
Gold	Agosi AG	GERMANY	CID000035
Gold	Aida Chemical Industries Co., Ltd.	JAPAN	CID000019
Gold	Almalyk Mining and Metallurgical Complex (AMMC)	UZBEKISTAN	CID000041
Gold	AngloGold Ashanti Corrego do Sitio Mineracao	BRAZIL	CID000058
Gold	Asahi Pretec Corp.	JAPAN	CID000082
Gold	Asahi Refining Canada Ltd.	CANADA	CID000924
Gold	Asaka Riken Co., Ltd.	JAPAN	CID000090
Gold	Aurubis AG	GERMANY	CID000113
Gold	Bangko Sentral ng Pilipinas (Central Bank of the Philippines)	PHILIPPINES	CID000128
Gold	Boliden AB	SWEDEN	CID000157
Gold	C. Hafner GmbH + Co. KG	GERMANY	CID000176
Gold	CCR Refinery - Glencore Canada Corporation	CANADA	CID000185
Gold	Chimet S.p.A.	ITALY	CID000233
Gold	Chugai Mining	JAPAN	CID000264
Gold	Coimpa Industrial LTDA	BRAZIL	CID004010
Gold	Dowa	JAPAN	CID000401
Gold	DSC (Do Sung Corporation)	KOREA, REPUBLIC OF	CID000359
Gold	Eco-System Recycling Co., Ltd. East Plant	JAPAN	CID000425
Gold	Eco-System Recycling Co., Ltd. North Plant	JAPAN	CID003424
Gold	Eco-System Recycling Co., Ltd. West Plant	JAPAN	CID003425

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Metal	Smelter or Refiner Name	Country	Smelter ID
Gold	Gold by Gold Colombia	COLOMBIA	CID003641
Gold	Gold Refinery of Zijin Mining Group Co., Ltd.	CHINA	CID002243
Gold	Heimerle + Meule GmbH	GERMANY	CID000694
Gold	Heraeus Germany GmbH Co. KG	GERMANY	CID000711
Gold	Heraeus Metals Hong Kong Ltd.	CHINA	CID000707
Gold	Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.	CHINA	CID000801
Gold	Ishifuku Metal Industry Co., Ltd.	JAPAN	CID000807
Gold	Istanbul Gold Refinery	TURKEY	CID000814
Gold	Italpreziosi	ITALY	CID002765
Gold	Japan Mint	JAPAN	CID000823
Gold	Jiangxi Copper Co., Ltd.	CHINA	CID000855
Gold	JX Nippon Mining & Metals Co., Ltd.	JAPAN	CID000937
Gold	Kazzinc	KAZAKHSTAN	CID000957
Gold	Kennecott Utah Copper LLC	UNITED STATES OF	CID000969
		AMERICA
Gold	KGHM Polska Miedz Spolka Akcyjna	POLAND	CID002511
Gold	Kojima Chemicals Co., Ltd.	JAPAN	CID000981
Gold	Korea Zinc Co., Ltd.	KOREA, REPUBLIC OF	CID002605
Gold	L'Orfebre S.A.	ANDORRA	CID002762
Gold	LS-NIKKO Copper Inc.	KOREA, REPUBLIC OF	CID001078
Gold	LT Metal Ltd.	KOREA, REPUBLIC OF	CID000689
Gold	Materion	UNITED STATES OF	CID001113
		AMERICA
Gold	Matsuda Sangyo Co., Ltd.	JAPAN	CID001119
Gold	Metal Concentrators SA (Pty) Ltd.	SOUTH AFRICA	CID003575
Gold	Metalor Technologies (Hong Kong) Ltd.	CHINA	CID001149
Gold	Metalor Technologies (Singapore) Pte., Ltd.	SINGAPORE	CID001152
Gold	Metalor Technologies (Suzhou) Ltd.	CHINA	CID001147
Gold	Metalor USA Refining Corporation	UNITED STATES OF	CID001157
		AMERICA
Gold	Metalurgica Met-Mex Penoles S.A. De C.V.	MEXICO	CID001161
Gold	Mitsubishi Materials Corporation	JAPAN	CID001188
Gold	Mitsui Mining and Smelting Co., Ltd.	JAPAN	CID001193
Gold	MKS PAMP SA	SWITZERLAND	CID001352
Gold	Nadir Metal Rafineri San. Ve Tic. A.S.	TURKEY	CID001220
Gold	Navoi Mining and Metallurgical Combinat	UZBEKISTAN	CID001236
Gold	NH Recytech Company	KOREA, REPUBLIC OF	CID003189
Gold	Nihon Material Co., Ltd.	JAPAN	CID001259
Gold	Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH	AUSTRIA	CID002779
Gold	Ohura Precious Metal Industry Co., Ltd.	JAPAN	CID001325
Gold	Planta Recuperadora de Metales SpA	CHILE	CID002919
Gold	PT Aneka Tambang (Persero) Tbk	INDONESIA	CID001397
Gold	Rand Refinery (Pty) Ltd.	SOUTH AFRICA	CID001512
Gold	REMONDIS PMR B.V.	NETHERLANDS	CID002582
Gold	Royal Canadian Mint	CANADA	CID001534
Gold	SAFINA A.S.	CZECHIA	CID002290
Gold	SEMPSA Joyeria Plateria S.A.	SPAIN	CID001585
Gold	Shandong Gold Smelting Co., Ltd.	CHINA	CID001916
Gold	Shandong Zhaojin Gold & Silver Refinery Co., Ltd.	CHINA	CID001622
Gold	Sichuan Tianze Precious Metals Co., Ltd.	CHINA	CID001736

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