RYLPF Royal Phillips NV (PK)

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

KONINKLIJKE PHILIPS N.V.

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

ROYAL PHILIPS

(Translation of Registrant’s name into English)

Willem Appelo, Chief Operations Officer

+31 20 59 77111, wim.appelo@philips.com, Breitner Center

Amstelplein 2, 1096 BC Amsterdam, The Netherlands

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

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:

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Koninklijke Philips N.V. evaluated its current product lines and determined that certain products we manufacture or contract to manufacture contain tin, tungsten, tantalum and/or gold (3TG).

Conflict Minerals Disclosure

Koninklijke Philips N.V. has, in good faith, conducted a reasonable country of origin inquiry (“RCOI”) to determine whether its products contain conflict minerals originated in the Democratic Republic of the Congo or an adjoining country as described in the Company’s Conflict Minerals Report provided as Exhibit 1.01 hereto.

We have not been able to confirm the identification of and conflict-free status under the Responsible Minerals Assurance Process (RMAP) standards for all smelters used in our supply chain. None of the smelters identified in our supply chain are known to us as sourcing 3TG that directly or indirectly finances or benefits armed groups in the covered countries. As a result we file a Conflict Minerals Report as an Exhibit to this filing.

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at: https://www.philips.com/a-w/about/environmental-social-governance/environmental/supplier-sustainability/responsible-sourcing-of-minerals.html.

Item 1.02 Exhibit

The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 – Exhibits

Item 2.01 Exhibits

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

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SIGNATURES

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.

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Exhibit 1.01

Philips Conflict Minerals Report

This Conflict Minerals Report for Koninklijke Philips N.V. (hereafter ‘’Royal Philips’’, “Philips”, or “our”) covers the reporting period from January 1, 2023 to December 31, 2023, and has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934.

This Conflict Minerals Report is filed as Exhibit 1.01 to Philips’ Specialized Disclosure Report on Form SD and is also posted on the Philips conflict minerals website^{1 2}.

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Contents

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Rule 13p-1 under the Securities Exchange Act of 1934, as amended, requires a company to make disclosures, for each calendar year, if conflict minerals are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin, and tungsten (henceforth referred to as “3TG”).

Philips has concluded that for the period from January 1, 2023 to December 31, 2023:

Philips

Royal Philips (NYSE: PHG, AEX: PHIA) is a leading health technology company focused on improving people’s health and well-being through meaningful innovation. Philips’ patient- and people-centric innovation leverages advanced technology and deep clinical and consumer insights to deliver personal health solutions for consumers and professional health solutions for healthcare providers and their patients in the hospital and the home. Headquartered in the Netherlands, the company is a leader in diagnostic imaging, ultrasound, image-guided therapy, monitoring and enterprise informatics, as well as in personal health. Philips generated 2023 sales of EUR 18.2 billion and employs approximately 69,100 employees with sales and services in more than 100 countries. News about Philips can be found at www.philips.com/newscenter.

In 2023, Royal Philips was organized around the following reportable segments:

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Supply chain characteristics for 3TG

The supply chain for 3TGs consists of many tiers. Before reaching Philips’ direct suppliers, in general, 3TGs will go from mines to traders, exporters, smelters or refiners (collectively referred to in this report as smelters), alloy producers and component manufacturers, and sometimes intermediate suppliers. One or more of the 3TG metals are contained in the vast majority of Philips products, typically in small quantities. Philips sources products and components from approximately 4,900 first-tier suppliers globally. First-tier suppliers are those suppliers that Philips selected and with whom Philips has a direct business relationship. These first-tier suppliers may select their suppliers (second-tier suppliers), which in turn may have their own group of suppliers (third-tier), and so on. There may be seven or more tiers in the supply chain between a 3TG mine and Philips. Philips works with its first-tier suppliers to investigate the deeper levels of the supply chain, to determine the origin of 3TGs contained in Philips products.

Philips conflict minerals due diligence program

Due to Philips’ position in the supply chain and its limited insight in and leverage over the lower levels of the supply chain, Philips engages and actively cooperates with other industry members. As encouraged in the third edition of the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (including its supplements on 3TG, referred to in this report as “OECD Guidance”), the internationally recognized standard on which Philips’ system is based, Philips supports an industry initiative, the Responsible Minerals Initiative (RMI), that uses an independent third-party audit to identify smelters that have systems in place to assure sourcing of only conflict-free materials. The RMI, was founded by members of the Responsible Business Alliance (RBA), and the Global e-Sustainability Initiative (GeSI).

The data on which certain statements in this report are based were obtained through Philips’ membership in the RMI, using the RMI Reasonable Country of Origin Inquiry report³. In addition, Philips uses the tools and supports the initiatives developed by the RMI especially the Conflict Minerals Reporting Template (CMRT) and Responsible Minerals Assurance Process (RMAP).

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Philips designed its conflict minerals supply chain due diligence program with reference to the OECD Guidance and the five steps described in the supplements on 3TG.

OECD Step 1: Company Management system

Philips adopted a position paper on responsible sourcing in relation to conflict minerals. The position paper is posted on Philips’ website. In addition, Philips has communicated its position on conflict minerals to all priority suppliers (see below section “OECD Step 2” for the definition of priority suppliers). Philips has committed not to purchase raw materials, subassemblies, or supplies, which Philips knows contain conflict minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC), an adjoining country or any conflict-affected or high-risk areas (CAHRAs). Philips’ program goals, as described in the position paper, encourage the development of initiatives to:

Philips created and maintains an internal conflict minerals team to manage the implementation and progress of Philips’ due diligence efforts. The internal team consists of representatives from Procurement, Sustainability, Finance, Export Control, Legal and the General Business Principles (GBP) Program Office.

Philips established a system of control and transparency over its 3TG supply chains by creating a process to engage a group of first-tier priority suppliers and request them to submit information to Philips using the CMRT⁴. The information submitted by priority suppliers includes information gathered by those suppliers about the smelters identified in their own supply chains. The information has been used by Philips to assess the due diligence efforts implemented by priority suppliers, and to identify smelters in the supply chain.

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Philips made responsible sourcing of minerals a supplier contract requirement. The Philips Supplier Sustainability Declaration⁵ (SSD) includes a provision about Responsible Sourcing of Minerals. The SSD is part of the general conditions of purchase, and of the purchasing agreements signed with suppliers. It requires suppliers to have a policy in place to reasonably assure that their 3TG does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the DRC, an adjoining country, or CAHRAs, and to exercise due diligence on the source and chain of custody. This due diligence should be done in a way consistent with the Organisation for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework.

For first-tier suppliers, Philips has a supplier sustainability performance program⁶ in place in which, amongst others, the implementation of the SSD is assessed. Responsible Sourcing of Minerals is one of the topics reviewed in this program. In case non-conformances are identified during the assessment, suppliers are requested to make a corrective action plan and Philips monitors the implementation of this plan until the non-conformance is corrected.

Multiple communication channels exist to serve as grievance mechanisms for early-warning risk awareness. Philips has the Philips Speak Up policy and underlying Speak Up mechanism that enables its stakeholders (including employees, former employees and third parties) to inform Philips of any concerns they may have. Internally, its personnel can (anonymously) report possible violations of Philips General Business Principles (GBP)⁷ and other policies including those related to 3TG supply chains via the GBP Compliance Officer or Philips Speak Up using the hotline or a web intake form. Third parties can also use Philips Speak Up to file a complaint.⁸ In addition, stakeholders can use the email address conflict_free_minerals@Philips.com or existing industry grievance mechanisms like RMI to file complaints related to 3TG.

OECD Step 2: Risk identification and assessment

Given the substantial number and diversity of Philips’ suppliers, Philips focuses its efforts on a group of first-tier priority suppliers (referred to as “priority suppliers”) and collaborates with them to identify the smelters in their supply chain. Priority suppliers are selected based on two primary elements:

https://www.philips.com/c-dam/corporate/about-philips/company/suppliers/supplier-sustainability/policies/philips-supplier-sustainability-declaration.pdf

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The suppliers which provide a high quantity of 3TG materials are selected as priority suppliers. Even if these suppliers are not part of the top 80% relevant purchasing spend, Philips includes the suppliers as they are supplying a relatively high quantity of 3TG materials.

All identified priority suppliers receive a letter formally requesting them to:

A Philips conflict minerals team is available to increase awareness amongst priority suppliers and to help them meet Philips’ expectations/requirements. Different background and training materials are made available to suppliers.

Philips reviews each received supplier CMRT and assesses whether it meets Philips’ acceptance criteria regarding completeness, adoption of a conflict-free policy, data collection from next tier suppliers, and smelter identification and disclosure. Suppliers who provided a CMRT that did not meet the acceptance criteria, and suppliers who provided incomplete or potentially inaccurate information, were requested to take corrective actions, perform additional due diligence and update their CMRT accordingly.

Philips reviews the supplier CMRTs to determine if there are any findings that indicate a need to conduct further due diligence and gather more detailed information.

Philips evaluates the smelters identified in the supplier CMRTs based on various sources of available information. Philips mainly uses the Responsible Minerals Assurance Process (RMAP) conformant and active⁹ smelter list to evaluate the identified smelters. RMAP recognizes and includes smelters from other lists such as the London Bullion Metal Association (LBMA) and Responsible Jewelry Council (RJC). Philips may also use other sources of information to assess potential risk. In addition, Philips uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include geographic proximity to the DRC, Covered Countries, or an embargoed country/region; Known mineral source country of origin; RMAP audit status; Credible evidence of unethical or conflict sourcing; and Peer Assessments conducted by credible third-party sources, including international organizations.

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OECD Step 3: Strategy to respond to identified risks

Progress and findings of the supply chain risk assessment are regularly reported to senior management. The risk management plan adopted by Philips is in accordance with its policy to ultimately discontinue doing business with any supplier found to be purchasing 3TG material which directly or indirectly finances or benefits armed groups in the DRC, adjoining countries, or CAHRAs, after attempts at corrective actions are not successful.

To monitor and track performance of risk management efforts, Philips uses data reported by suppliers in the CMRTs and updates of the RMAP conformant smelter list. The status is discussed internally in monthly reviews with the conflict minerals team and reported to senior management.

Philips requests priority suppliers to update and resend their CMRT when additional information becomes available to such suppliers. When updates are received, the CMRT review step as described above is repeated to assess and mitigate risks.

OECD Step 4: Audits of smelter due diligence practices

The fourth step in the OECD guidance is to conduct independent third-party audits of supply chain due diligence at identified points in the supply chain. Philips is a member of RMI and uses information provided by the RMI for this step. Through its membership, Philips has access to the RMI RCOI report data which is used to identify the minerals country of origin and conflict-free status of smelters.

Philips contributes to the RMI as a member company and encourages smelters to participate in the RMAP through direct communication and smelter outreach communication.

OECD Step 5: Report annually on supply chain due diligence.

Since 2014, Philips reports annually on supply chain due diligence by filing a Form SD and Conflict Minerals Report with the SEC. Philips has been including certain disclosures about the use of conflict minerals since 2009, even before the SEC’s rules first became effective. A dedicated conflict minerals website with information for consumers, customers and suppliers is available. In 2012, Philips was the first company to publish its smelter list and continues to regularly update this list as more information becomes available.

3. Reasonable country of origin inquiry results

As described above, SEC rules provide that if, after conducting in good faith, a reasonable country of origin inquiry, an SEC registrant determines, or has reason to believe, that any of the 3TGs used in connection with the products for which it is responsible may have originated in the DRC or an adjoining country, or did not come from recycled or scrap sources, the registrant should conduct due diligence on the source and chain of custody of its conflict minerals, following a nationally or internationally recognized framework.

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Philips identified 186 priority suppliers and used the data provided by these suppliers in their CMRTs to identify the smelters in the Philips supply chain. These smelters may have been used to process 3TG metals contained in Philips’s products.

Philips achieved a 97% response rate in its supply chain investigation and 78% of the submitted CMRTs met or exceeded Philips’ minimum acceptance criteria. Since 2022, Philips intensified its due diligence by strengthening the acceptance criteria for CMRTs. This adjustment, while initially reducing the approval rate of submitted CMRTs to 65%, was a strategic step to enhance due diligence. By 2023, the implementation of these strengthened criteria and Philips’ continued collaboration with suppliers led to an increased approval rate of 78%. Philips remains focused on consistently engaging with suppliers to improve their practices, aiming to achieve an approval rate of 85%. The names of 342 different smelters were reported by priority suppliers in their CMRT smelter lists. However, some of the entities named by the priority suppliers may not be smelters. Philips used the “Smelter Look-up” in the CMRT version 6.31 and RMI smelter database information as a reference to compile the Philips Smelter List.

Based on the CMRT “Smelter Look-up”, Philips identified a total of 329 listed smelters in the supply chain out of the 342 names reported to Philips. According to the RMI smelter database information, among the 342 names of smelters reported to Philips, 13 have ceased or suspended operations, 10 have been confirmed to no longer be actively purchased from and 3 have confirmed not to be smelters.

As a result of focusing on improving the smelter data quality received from the priority suppliers, Philips was able to reduce the number of non-recognized smelters from 85 reported in 2015, to 9 reported in 2016, to 5 reported in 2017, to 3 reported in 2018, and finally to 0 since 2019.

The majority of the identified smelters are located in Asia, with 82 smelters in China, followed by Indonesia (32) and Japan (31).

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Results of the RCOI (Reasonable Country of Origin Inquiry)

For the 329 identified smelters, Philips used the RMI Reasonable Country of Origin Inquiry (RCOI) report. This country-of-origin data is available for smelters that successfully completed an RMAP audit and chose to disclose their sourcing countries to the RMI. The table above shows the results of the RCOI. The total number shown in the table is not equal to the total number of identified smelters, because a smelter may fall into more than one category (e.g., a smelter can source from both the DRC as well as from countries outside the DRC). As the RMI generally does not specify individual countries of origin of 3TGs processed by audited smelters and some of the smelters do not disclose origin information, we were not able to determine with certainty the specific countries of origin of 3TGs processed by the identified smelters.

In the CMRTs received, 51 suppliers indicated that their products contain 3TG metals that originated or potentially originated from the DRC, adjoining countries or CAHRAs. We then performed due diligence on the source and chain of custody of the conflict minerals in question.

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4. Conflict minerals due diligence framework & measures

Framework

The Philips conflict minerals due diligence framework for the reporting period of calendar year 2023 has been designed to conform in all material respects to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (2016), as applicable for downstream companies.

Measures

Below is a description of the measures Philips performed in due diligence on the source and chain of custody of the necessary conflict minerals contained in Philips’ products.

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5. Conflict minerals due diligence outcomes

To the best of Philips’ knowledge, none of the smelters identified in Philips’ supply chain are known to source 3TG that directly or indirectly benefit armed groups in the DRC. 235 (71%) of the 329 smelters identified by Philips participated in the RMAP or equivalent audit program. 226 (69%) of the identified smelters successfully passed the RMAP or equivalent audit, thereby confirming their conflict-free status under those standards. 9 (3%) of the identified smelters are in various stages of the audit (so-called “RMI active smelters”). The remaining 94 (29%) identified smelters have not started a valid independent third-party audit to confirm their conflict-free status. Accordingly, the conflict-free status of these 94 unaudited smelters as well as the 9 active smelters that are in various stages of the audit process is reported in this conflict minerals report as undeterminable.

Philips did not discontinue business with any direct suppliers in the reporting period because Philips did not identify any reason to believe that any of the suppliers were purchasing 3TG that directly or indirectly finances or benefits armed groups in the DRC or adjoining countries nor has any supplier refused to continue investigating and potentially eliminate a red flag smelter from the supply chain, if confirmed. Philips nevertheless continues to review and potentially remove smelters from its supply chain when Philips has concerns regarding their due diligence process and/or sourcing practices. This includes analysis of current events and related to applicable sanctions and embargoes. Given the fact that neither Philips nor its suppliers have a direct business relationship with the entities with respect to which Philips is further investigating concerns, the process takes time.

6. Determination

Philips has not been able to confirm the identification of a conflict-free status under the RMAP standards for all smelters used in its supply chain. However, none of the smelters identified in Philips’ supply chain is known to Philips as sourcing 3TG that directly or indirectly finances or benefits armed groups in the DRC or adjoining countries.

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As a result of the due diligence measures performed, Philips provides below the known smelter facilities that may have been used to process 3TG metals contained in Philips’s products, and their conflict-free status. The conflict-free status is based on information the RMI provides to its members. Philips includes the category “RMI Active” as it shows smelters that committed to or are currently in the process of undertaking an audit. The list of smelter facilities provided in Section 8 of this Conflict Minerals Report includes all 329 entities that were confirmed to be eligible smelters.

This Conflict Minerals Report is intended to cover Philips’ entire product portfolio that uses 3TG. Given Philips’ large product portfolio and extensive supplier base, Philips does not have component level information from all 4,900 first-tier suppliers. This means our list of processing smelters and refiners disclosed in Section 8 may contain more facilities than those that actually processed the conflict minerals contained in our products. As a result, the approach is to conduct supply chain due diligence and report at the company level for the entire product portfolio, rather than for specific Philips products. This enables Philips to focus its efforts on building, maintaining, and improving a robust due diligence program.

7. Steps to improve future Philips conflict minerals due diligence program

For reporting year 2024, Philips plans to:

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The table below represents a consolidated list of smelters (329 in total) identified by Philips’ priority suppliers. The results are based on:

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