UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

Applied Materials, Inc.

(Exact name of registrant as specified in its charter)

Christina Y. Lai Esq.

Applied Materials, Inc.

(408) 727-5555

(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

Applied Materials, Inc. has filed a Conflict Minerals Report as an exhibit to this report on Form SD and has also posted the report on its publicly available Company website at http://www.appliedmaterials.com/company/corporate-responsibility/sustainability.

A Conflict Minerals Report is attached as Exhibit 1.01 to this report.

SECTION 2 – EXHIBITS

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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.

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EXHIBIT INDEX

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EXHIBIT 1.01

APPLIED MATERIALS, INC.

CONFLICT MINERALS REPORT

FOR YEAR ENDED DECEMBER 31, 2018

This is the Conflict Minerals Report of Applied Materials, Inc., including its subsidiaries (collectively, “Applied” or the “Company”), prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934. Terms used in this report have the meaning specified in Rule 13p-l and/or Form SD issued by the Securities and Exchange Commission, except as otherwise expressly defined herein. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite (coltan) and wolframite (and their derivatives, tin, tantalum and tungsten, respectively), and gold, regardless of the geographic origin of the minerals and whether or not they fund armed conflict. This report pertains to products manufactured from January 1 through December 31, 2018 for which any conflict minerals are necessary to the functionality or production of the product, as described further below.

Company Overview

A global company with a broad set of capabilities in materials engineering, Applied provides manufacturing equipment, services (including spare parts) and software to the global semiconductor, display, solar photovoltaic (PV) and related industries, and reports these products under three segments: Semiconductor Systems, Applied Global Services and Display & Adjacent Markets.    

Applied does not directly purchase raw ore or unrefined conflict minerals, nor does it have a direct relationship with any mines of origin or with any smelters or refiners (collectively, “smelters”) that process these minerals. Rather, Applied is a downstream company with an extensive and complex supply chain from which it purchases parts, components and assemblies (collectively, “Parts”). The Company’s manufacturing activities consist primarily of the assembly, testing and integration of various proprietary and commercial Parts that are used to manufacture systems. Applied has a distributed manufacturing model under which manufacturing and supply chain activities are conducted at its facilities, or those of contract manufacturers, located in various countries. Applied’s equipment products, due to their size and complexity, generally consist of thousands of Parts sourced from a multitude of suppliers. Applied relies on its direct suppliers to provide information on the origin of any conflict minerals contained in Parts they sell to the Company, including the source of conflict minerals they obtain from lower tier suppliers and smelters.

Products Covered by this Report

Tantalum, tin, tungsten and gold are metals commonly used in the electronics and related industries due to physical properties that make them well-suited for a variety of applications, such as in cables, printed circuit boards, power supplies, capacitors, solder alloys and certain plastics. As a result, all or substantially all of Applied’s equipment products, and many of its spare parts products, manufactured in 2018 include components for which one or more conflict minerals are necessary to the functionality or production of the product and are therefore considered “Covered Products” for purposes of this report. The following is a general description of Covered Products by reporting segment.

Semiconductor Systems. Applied’s Semiconductor Systems segment develops, manufactures and sells a wide range of manufacturing equipment used to fabricate semiconductor chips, also referred to as integrated circuits (ICs). The Semiconductor Systems segment includes semiconductor capital equipment for epitaxy, deposition, etch, ion implantation, rapid thermal processing, chemical mechanical planarization, metrology, inspection, review and wafer packaging. Most of these are single-wafer systems

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with multiple process chambers attached to one of nine basic platforms: the Endura^®, Centris^®, Centura^®, Olympia^TM, Producer^®, Reflexion^®, Raider^®, VIISta^® and Vantage^® platforms. Applied’s metrology and inspection tools, which include the PROVision™, UVision^®, SEMVision^™, VeritySEM^® and Aera4^™ Mask Inspection systems, are used to locate, measure and analyze critical defects and features on the wafer during various stages of the fabrication processes. The majority of Applied’s new equipment sales are to leading integrated device manufacturers and foundries worldwide.

Display and Adjacent Markets. This segment is comprised of products for manufacturing liquid crystal displays (LCDs), organic light-emitting diodes (OLEDs), and other display technologies for TVs, monitors, laptops, personal computers (PCs), electronic tablets, smart phones and other consumer-oriented devices as well as equipment for processing flexible substrates. While similarities exist between the technologies utilized in semiconductor and display fabrication, the most significant differences are in the size and composition of the substrate. Substrates used to manufacture display panels and other devices are typically glass, although newer flexible materials are entering the market. The Display and Adjacent Markets segment offers a variety of products and technologies, including: the AKT^® Electron Beam Array Test system for array test, AKT^® PECVD systems for CVD, AKT^® Aristo^™ and PiVot^™ systems for PVD, and AKT^® TFE systems for thin-film encapsulation. It also includes flexible coating systems that utilize physical vapor deposition, thermal evaporation, chemical vapor deposition and e-beam technology to deposit thin layers of metal onto flexible substrates for packaging, flexible electronics and security industries. These systems include TopBeam^™, TopMet^™ and SmartWeb^®.

Applied Global Services. This segment provides integrated solutions to optimize equipment and fab performance and productivity, including spares, upgrades, services, remanufactured earlier generation equipment and factory automation software for semiconductor, display and other products.

Other Products. Applied’s Baccini^® systems are used for fabricating crystalline-silicon (c-Si) solar PV cells.

Applied’s Conflict Mineral’s Compliance Program and Findings

Applied conducted in good faith a reasonable country of origin inquiry (“RCOI”) that it believes was reasonably designed to determine whether any of the necessary conflict minerals in its Covered Products manufactured in 2018 originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “DRC”) or were from recycled or scrap sources. Based on its RCOI, Applied determined it had insufficient information to conclude either (i) that all of its necessary conflict minerals originated outside the DRC or from CFSI “Compliant” sources within the DRC, or (ii) that all of its necessary conflict minerals came from recycled or scrap sources.

Applied therefore undertook further due diligence on the source and chain of custody of necessary conflict minerals contained in its Covered Products. Its due diligence approach was designed to conform in all material respects with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition and the related Supplements (“OECD Guidance”).

For calendar year 2018, Applied identified the top direct (or first-tier) suppliers in terms of total spend, suppliers who during the past four years were part of the top direct suppliers by spend, as well as suppliers considered reasonably likely to provide Parts containing conflict minerals based upon the commodity (e.g., suppliers of sputtering targets and suppliers of gold plating) to arrive at a target list of suppliers to be contacted (the “Surveyed Suppliers”). These Surveyed Suppliers represent approximately

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eighty percent of the Company’s actual total expenditures to all direct suppliers for fiscal year 2018.¹ One hundred percent (100%) of the Surveyed Suppliers responded, and 42% reported they did not provide Parts containing conflict minerals. Of the Surveyed Suppliers who reported they provided one or more Parts containing conflict minerals, 96% provided smelter names, or in some cases further information such as country location of the smelters. Approximately 8% of Surveyed Suppliers who reported Parts containing conflicts minerals declared that at least some minerals originated from recycled or scrap sources, although, with few exceptions, none were traced to a particular Part.

The table below summarizes certain information pertaining to smelters identified by Surveyed Suppliers. The Responsible Materials Initiative (“RMI”), formerly the Conflict-Free Sourcing Initiative, of which Applied is a member, was founded by the Responsible Business Alliance (“RBA”), formerly the Electronics Industry Citizenship Coalition (“EICC”), and the Global eSustainability Initiative. Under the RMI, “Conformant” smelters are those smelters that are conformant with the Responsible Minerals Assurance Process (“RMAP”) assessment protocols. “Active” smelters and refiners are participants in the RMAP who have agreed in writing to undergo a third party audit or are participating in one of the cross-recognized certification programs, signed an “Agreement for the Exchange of Confidential Information” and submitted a due diligence checklist. The classification of smelters considered Conformant or Active is current as of May 8, 2019.

As a result of its due diligence, Applied found evidence of potential sourcing from three gold smelters in the DRC (CID002854 - Universal Precious Metals Refining Zambia, CID003185 - African Gold Refinery, and CID002567 - Sudan Gold Refinery). These three smelters have not been assessed by the RMI. Information about these smelters was provided to Applied by Surveyed Suppliers as “company-level” rather than “product-level” responses or was insufficient to tie gold from one or more of these smelters to products supplied to Applied, and therefore, it is uncertain whether these smelters are part of Applied’s supply chain. Applied found no evidence that minerals from these three smelters were incorporated into its Covered Products.

Attached as Appendix A is a list of the smelters or refiners identified by the Surveyed Suppliers as the facilities that process conflict minerals necessary to their products and that are either (a) RMI Conformant or (b) RMI Active. Since the majority of the Surveyed Suppliers reported smelter information at the company level and not at the product level, and they did not identify the specific smelter that processed conflict minerals contained in a particular Part, we do not know with certainty that each smelter or refiner listed in Appendix A processed minerals that were used in the Parts we purchased. However, as an improvement over prior years, a growing number of Surveyed Suppliers submitted product specific Conflict Minerals Reporting Templates (“Templates”) (representing approximately 17% of Applied’s Surveyed Suppliers).

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For the significant majority of smelters reported by the Surveyed Suppliers, there is inadequate information available to assess the source of the conflict minerals they process. Therefore, for Covered Products manufactured in 2018, Applied concluded in good faith that it lacks sufficient information to trace the chain of custody of any conflict minerals contained in its Covered Products up through the supply chain to a specific smelter or, in turn, to a country or mine of origin.

Applied’s Due Diligence Process

Applied’s due diligence approach on the source and chain of custody of its necessary conflict minerals was designed to conform in all material respects with the OECD Guidance. The OECD Guidance is an internationally-recognized due diligence framework consisting of a multi-step, risk-based process, certain aspects of which differ depending in part on the position of a company in the supply chain. Applied is a “downstream” company, which refers to supply chain participants from the smelter to the retailer, in contrast to those “upstream,” that is, from the mine to the smelter.

As a downstream provider of finished products, Applied does not have direct relationships with smelters and does not perform or specify audits of such entities upstream in its supply chain. Through its membership and participation in the RBA, RMI and related working groups, Applied believes that seeking reliable information about smelters in its supply chain from its direct suppliers represents a reasonable and cost-effective approach to determine the mines or other locations of origin of conflict minerals in its products.    

Risk Identification and Assessment

In light of the complexity of its supply chain, Applied used a risk-based approach in designing the scope of its RCOI and due diligence process. As previously noted, the Company identified its top direct suppliers in terms of total spend, suppliers who previously were among the top direct suppliers in terms of total spend, as well as other suppliers considered reasonably likely to provide Parts containing conflict minerals, to arrive at the target list of Surveyed Suppliers. Applied also relied on information obtained through multi-industry-wide smelter certification resources, such as RMAP.

To collect information on the conflict minerals that may be in Covered Products manufactured in 2018, Applied used the Conflict Minerals Reporting Template (the “Template”) developed by the RMI. Applied contacted the Surveyed Suppliers and requested them to complete and return the Template with respect to Parts they supplied to the Company. The Template was designed to facilitate a supplier’s disclosure of information regarding conflict minerals contained in the supplier’s products, including the country of origin and the name and location of the smelters that process the conflict minerals.

Applied received wholly or partially completed Templates from 100% of its Surveyed Suppliers. The majority of the responding Surveyed Suppliers provided data at a company or “user defined” level, rather than at a Part number level, a permitted option under the Template. Those suppliers who reported at a user defined level reported data at the business division level. As noted above, approximately 17% of the Surveyed Suppliers submitted data at a Part number level. Applied reviewed responses against its criteria to determine which required further engagement, such as those with incomplete, untimely or inconsistent information, and made further inquiries of those suppliers. In addition, Applied checked the smelters identified by the Surveyed Suppliers against the lists published by RMI of Conformant and Active smelters.

Applied was not required to, and it did not, obtain an independent private sector audit of its due diligence approach.

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Risk Mitigation Strategy and Future Due Diligence

As part of its risk management strategy, Applied targeted suppliers who failed to respond adequately to the Company’s request for information.    Our sustained supplier outreach efforts enabled us to achieve a 100% response rate from the Surveyed Suppliers, consistent with our results for our Conflict Minerals Reports covering products manufactured in 2017, 2016 and 2015; compared to 99% in 2014 and 83% in 2013.

Our due diligence efforts grew during calendar year 2018: we increased the number of Surveyed Suppliers by approximately 13% in comparison to the prior year (we went from targeting 120 suppliers for our calendar year 2016 report to targeting 162 suppliers for our calendar year 2017 report and to targeting 183 suppliers for this report).

Applied intends to improve its ability to identify suppliers reasonably likely to provide Parts containing conflict minerals. In addition, the Company intends to continue to enhance its process to identify suppliers who fail to provide a completed Template or do not provide complete and accurate smelter information and to improve the quality of the data they provide. In addition, Applied intends to improve its ability to link the smelter information its suppliers report to specific products they supply to Applied by requiring suppliers to provide product level Templates for tantalum target, gold plating and special process parts. In support of this effort, Applied intends to continue its conflict minerals training initiatives for suppliers. Applied further has undertaken to report relevant smelter information it obtains to RMI, and to encourage its suppliers to reach out (or to encourage their own suppliers to reach out) to upstream smelters that provide them with conflict minerals and require that such smelters obtain a “conflict-free” designation from an industry program such as the RMAP.

Forward-Looking Statement Disclaimer

This report includes forward-looking statements, including but not limited those regarding Applied’s expected future supplier diligence and engagement efforts and development of related processes. These statements and their underlying assumptions are subject to known and unknown risks and uncertainties that could cause actual results to differ materially from current expectations, including but not limited to: regulatory changes and judicial developments relating to conflict minerals disclosure; changes in our supply chain, components and parts, or products; industry developments relating to supply chain diligence, disclosure and other practices; and other risks described in our most recent Form 10-Q and other SEC filings. Forward-looking statements are based on estimates, projections and assumptions as of May 28, 2019, and Applied undertakes no obligation to update any such statements.

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Appendix A

Section 1: Smelters/refiners that are RMI Conformant

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Section 2: Smelters/refiners that are RMI Active

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