Document


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
SPECTRUM BRANDS HOLDINGS, INC.
(Exact Name of Registrant as Specified in its Charter)
Delaware001-421974-1339132
(State or other jurisdiction of incorporation)(Commission File Number)(I.R.S. Employer Identification No.)
3001 Deming Way
Middleton, Wisconsin 53562
(Address of principal executive offices)

(608) 275-3340
(Registrant’s telephone number, including area code)

Ehsan Zargar
Executive Vice President
General Counsel and Corporate Secretary
(608) 275-4924
(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:
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2025.
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended September 30, 2024.



Section 1 - Conflict Minerals Disclosure
Item 1.01. Conflict Minerals Disclosure and Report
As contemplated by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report for the reporting period from January 1 to December 31, 2025 is provided as an Exhibit to this Form SD and is available on our website at https://spectrumbrands.com/about-us/our-company/global-sustainability-statement.html.
Our website is not incorporated by reference and should not be considered part of this Form SD or our Conflict Minerals Report.
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 – Resource Extraction Issuer Disclosure
Item 2.01. Resource Extraction Issuer Disclosure and Report.
Not applicable
Section 3 - Exhibits
Item 2.01. Exhibits
The following exhibit is filed as part of this report:
Exhibit No.Exhibit
1.01
2


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 undersigned hereunto duly authorized.
Date: May 29, 2026
SPECTRUM BRANDS HOLDINGS, INC.
By:/s/ Ehsan Zargar
Name: Ehsan Zargar
Title: Executive Vice President, General Counsel and Corporate Secretary
3
Document

EXHIBIT 1.01
Conflict Minerals Report
This is the Conflict Minerals Report of Spectrum Brands Holdings, Inc. and its consolidated subsidiaries, including SB/RH Holdings, LLC and its consolidated subsidiaries (the “Company,” “Spectrum Brands,” “we,” “us,” or “our”), for January 1, 2025 through December 31, 2025 (“Calendar Year 2025”) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). As used herein, “Conflict Minerals” or “3TG” is defined as, consistent with the Conflict Minerals Rule, cassiterite, columbite-tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten. Please refer to Rule 13p-1, Form SD and Exchange Act Release No. 34-67716 for definitions of the other terms used in this Report, unless otherwise defined herein.
Forward-Looking Statements
This Conflict Minerals Report contains “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. These statements relate to, among other things, our future plans, goals, and expectations regarding our due diligence efforts and transparency in our supply chain. Forward-looking statements can generally be identified by words such as “expects,” “anticipates,” “plans,” “projects,” “intends,” “believes,” and “will.” Such statements are based on current assumptions and expectations of future events and are not guarantees of future performance. They involve substantial known and unknown risks and uncertainties that could cause actual results to differ materially from those in the forward-looking statements. These risks include but are not limited to, incomplete or unavailable supplier, smelter or refiner data; errors, omissions, or fraud by suppliers, smelters or refiners; changing regulatory requirements or guidance and other issues. You should not place undue reliance on these statements, which speak only as of the date of this report. For more information on risks that may affect our business, please refer to the section titled “Risk Factors” in our most recent Annual Report on Form 10-K and our other filings with the Securities and Exchange Commission (“SEC”). Except as required by law, we undertake no obligation to update or revise any forward-looking statement to reflect new information or future events.
Applying the Dodd-Frank Act to Spectrum Brands Holdings, Inc.
The SEC’s conflict minerals rule requires a three-step compliance approach. The first step is determining applicability of the conflict minerals rule to us; the second step is a reasonable country of origin inquiry (“RCOI”) to determine whether we have reason to believe that conflict minerals from the Democratic Republic of the Congo (the “DRC”) or adjoining countries (collectively, the “Covered Countries”) that are necessary to the functionality or production of products manufactured by us, or contracted to be manufactured by us, are present in our products; and the third step (referred to as “due diligence” in the SEC rule) is to determine the source and origin of any such conflict minerals and the facilities in which they were processed.
As a downstream company, we are several tiers removed from mining operations and smelters or refiners (“SORs”) in dealing with its direct suppliers. Therefore, we must rely on our direct suppliers, who must in turn rely on their suppliers, to gather and report information about the source and chain of custody of Conflict Minerals, if any, in the products they supply to us. For Calendar Year 2025, we hired a third-party provider to assist us in performing the RCOI and Conflict Minerals supply chain due diligence (the “Provider”). Engaging the Provider combined with our supply chain due diligence processes and focusing on accountability within the supply chain by using the industry standard Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”) and reaching out to our suppliers, we seek to gain greater transparency in our supply chain. Certain of the activities described below were performed by the Provider on our behalf.
Products Potentially Subject to Due Diligence
As an initial matter, we considered whether Conflict Minerals were necessary for the production or functionality of our products. Our Steering Committee reviewed the products manufactured or contracted to be manufactured by us to determine which products might contain Conflict Minerals necessary to the products’



functionality or production. The Steering Committee conducted this review at a product level. The list of such products is contained in Attachment A to this Conflict Minerals Report.
Reasonable Country of Origin Inquiry
We then determined that 74 of our approximately 416 direct suppliers are “in-scope,” which means the suppliers we reasonably believed represented the highest risk of supplying us with products or components that do or may contain Conflict Minerals from the Covered Countries for Calendar Year 2025. That is where we directed our good-faith efforts to determine the country of origin of Conflict Minerals in our supply chain. The RCOI was then conducted as follows:
a. We sent initial inquiries to the in-scope suppliers and instructed them to complete the CMRT and return it to us.
b. The Provider engaged with our suppliers to collect information about the presence and sourcing of conflict minerals used in the products and components supplied to us in Calendar Year 2025. This adds more transparency to our supply chain, with the ultimate goal of identifying the related smelters or refiners and associated mine countries of origin.
c. We or the Provider sent follow-up inquiries to any initially unresponsive suppliers and conducted follow-up inquiries with responsive suppliers for further information if initial CMRT responses were incomplete or unclear; all identified issues were addressed.
d The Provider evaluated the completed CMRTs for plausibility, consistency and gaps. Additional supplier contacts were conducted to attempt to resolve “quality control” flags, such as where: (a) SORs were not provided for a used metal, (b) the supplier listed one or more SORs for an unused metal, (c) the supplier indicated that it had not identified all SORs for the in-scope products, (d) the supplier indicated it had not received conflict minerals data for each metal from all of its relevant suppliers, or (e) the supplier indicated that all of its conflict minerals were from recycled or scrap sources, but one or more of the SORs listed are not known to be exclusive recyclers.
e. At the conclusion of the RCOI process, we had a 90% CMRT response rate from our in-scope suppliers.
Due Diligence Framework
In conducting our due diligence, we implemented the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”), an internationally recognized due diligence framework, and related supplements for each of the Conflict Minerals. Accordingly, the steps taken by us in preparing this Conflict Minerals Report were in accordance with the OECD Framework. As such, we used the RMI’s CMRT versions 6.4 and 6.5, which includes standard supply chain survey and information tracking methods, as part of assessing our supply chain’s adherence to due diligence measures stated by the OECD Framework. These methods and actions include, but are not limited to:
Standard follow-up emails sent to all suppliers on a monthly basis over a three-month period;
Automatic enrollment of non-responsive suppliers in the Provider’s CMRT training webinar;
Two targeted follow-up emails to suppliers, supplemented by phone outreach;
Follow-up emails issued by the supplier’s Spectrum Brands contact, with our Director of Sourcing and the Environmental Sustainability & Product Regulatory Specialist copied; and
Two escalation emails sent three weeks apart, notifying suppliers that their CMRT submission is past due.
Due Diligence Steps Performed
1. Steps Taken to Establish Strong Company Management Systems
a. We educate our employees and disseminate Conflict Minerals information and updates internally through our Steering Committee, which implements and manages our Conflict Minerals compliance program. We also



disseminate Conflict Minerals information and updates externally through sourcing leads, supply chains, and sales forces. During Calendar Year 2025, we opted into the Smelters Outreach Initiative, which is coordinated by RMI to encourage and facilitate contact with SORs.
b. We are committed to sourcing components and materials from suppliers that share our values about human rights, ethics and environmental responsibility. Our employees are expected to comply with, and the Steering Committee is responsible for enforcing, our Policy Regarding Conflict Minerals (the “Conflict Minerals Policy”), which is available on our website at https://spectrumbrands.com/about-us/our-company/corporate-compliance/conflict-minerals.html. As required by our Conflict Minerals Policy, our suppliers are required to sign our Supplier Code of Conduct, which includes requirements relating to Conflict Minerals and responsible sourcing. A copy of our Supplier Code of Conduct can be found at https://www.spectrumbrands.com/about-us/suppliers/supplier-code-of-conduct.html.
c. We maintain a grievance mechanism, including, among other items, an anonymous, 24-hour helpline and reporting system (1-866-384-4277; https://secure.ethicspoint.com/domain/media/en/gui/7424/index.html, to enable any individual to report grievances related to Conflict Minerals and other supply chain matters.
d. We retain Conflict Minerals program documentation in accordance with our record retention policies.
2. Steps Taken to Identify Risks in the Supply Chain and Strategies to Respond to Identified Risks.
a. We identified the products we manufactured or contracted to manufacture in Calendar Year 2025.
b. We identified 74 in-scope suppliers from whom we purchase components used in the production of those products, and which could contain conflict minerals were necessary for the functionality or production of such products and solicited information from such suppliers as part of our RCOI. The Provider compared the list of the SORs collected to the Provider’s SOR database, which incorporates information from the lists publicly published by the RMI. Attached hereto as Attachment B is a list of SORs identified by our suppliers with valid smelter certification identification numbers.
c. We performed, and continue to perform, risk mitigation efforts to bring suppliers into conformity with our Conflict Minerals Policy and contractual requirements. These efforts included working with direct suppliers to consider alternative sources of components or supplying components which contain conflict minerals from sources listed as “conformant” or the equivalent by independent third-party audit programs as sponsored by the RMI, London Bullion Market Association (the “LBMA”) and Responsible Jewellery Council (the “RJC”).
3. Carry Out Independent Third-Party Audit of Smelter/Refiner Due Diligence Practices.
We use information publicly provided by the RMI, LBMA and RJC to confirm the existence and verify the OECD conformance status of SORs identified during due diligence. We are many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals, and we do not conduct any purchasing activities directly in the Covered Countries.
4. Mitigation Steps We Have Taken or Will Take Since the End of Calendar Year 2025.
We undertook the following steps since the end of Calendar Year 2025 to mitigate the risk that our products may contain Conflict Minerals that benefit armed groups within the Covered Countries, including steps to improve our due diligence:
a. Continued to enforce our Conflict Minerals Policy and disseminate the Supplier Code of Conduct to those suppliers who provide raw materials and components in our manufacturing operations and our contract manufacturers.
b. Continued to enforce the process within our manufacturing operations/procurement function to notify new vendors of our Supplier Code of Conduct.



c. Published a copy of our current Form SD and this Conflict Minerals Report on our website at https://spectrumbrands.com/about-us/our-company/global-sustainability-statement.html.
d. Continued our supply chain due diligence with the assistance of the Provider, on the source and chain of custody of raw materials and components purchased for our manufacturing operations. We plan to continue to enhance supplier communication on Conflict Minerals. We value our supplier relationships, but if any supplier is at risk to or does violate our Conflict Minerals Policy or Supplier Code of Conduct, we intend to require a corrective action plan from the supplier and move towards conflict-free sourcing. We do not intend to ban sourcing from the Covered Countries, but we seek to procure materials from responsible sources in the region to assist legitimate, conflict-free businesses there.
e. Due to our size, the complexity of our products, and the depth, breadth and constant evolution of our supply chain, it is difficult to identify sub-tier suppliers downstream from our direct suppliers. We do not purchase products directly from any suppliers, SORs or mines in the Covered Countries and have no direct contractual relationships with SORs, as previously noted. Instead, we rely on our direct suppliers to gather and provide specific information about the source of Conflict Minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers. Therefore, the Provider’s assistance with unresponsive first tier suppliers is used to add transparency to our supply chain. Our suppliers identified 103 SORs potentially in our supply chain that the Provider’s database indicated as having valid smelter certification identification numbers. Additional investigation was undertaken to determine the source of and chain of custody of the Conflict Minerals. The following internationally accepted audit standards were reviewed: the RMI Responsible Minerals Assurance Process (“RMAP”), the LBMA Responsible Gold Guidance and the RJC Chain-of-Custody Standard.
f. We identified 74 suppliers that may source from Covered Countries. 67 of those 74 suppliers provided CMRT responses, a response rate of 90%. Attached hereto as Attachment B is a list of the 103 SORs with valid smelter certification numbers identified by the 67 suppliers that provided product specific information, a list of the products covered by this Conflict Minerals Report and a list of the smelter location for the Conflict Minerals that are necessary to the production of our products. For the remainder of calendar year 2026, we plan to continue to emphasize to our suppliers the importance of sourcing responsibly and from conflict-free sources if the suppliers desire to retain our business.
g. Based on our due diligence efforts and information from the Provider, we have reason to believe that the Conflict Minerals necessary to the functionality or production of our products, where known, may originate from the countries listed in Attachment C hereto (country of origin).
Pursuant to SEC rules and guidance, this Conflict Minerals Report was not subjected to an independent private sector audit.



Attachment A

List of Products
The following products are more fully described in Spectrum Brands Holdings, Inc. Form 10-K, which may be found publicly on our website at: https://investor.spectrumbrands.com/sec-spectrum-brands-holdings-inc.
Electric shavers and accessories
Grooming products and hair care appliances
Small household appliances
Personal care products
Herbicides
Insecticides and repellants
Specialty pet supplies
Household cleaning products





Attachment B

List of Identified Smelters
MetalSmelter NameSmelter Facility LocationSmelter ID
GoldJiangxi Copper Co., Ltd.ChinaCID000855
GoldShandong Gold Smelting Co., Ltd.ChinaCID001916
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationChinaCID002224
GoldAsahi Pretec Corp.JapanCID000082
GoldDowaJapanCID000401
GoldHeraeus Metals Hong Kong Ltd.ChinaCID000707
GoldLS MnM Inc.Korea, Republic ofCID001078
GoldMatsuda Sangyo Co., Ltd.JapanCID001119
GoldMetalor Technologies (Suzhou) Ltd.ChinaCID001147
GoldMetalor Technologies (Hong Kong) Ltd.ChinaCID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SingaporeCID001152
GoldMetalor Technologies S.A.SwitzerlandCID001153
GoldMitsubishi Materials CorporationJapanCID001188
GoldMitsui Mining and Smelting Co., Ltd.JapanCID001193
GoldNihon Material Co., Ltd.JapanCID001259
GoldMKS PAMP SASwitzerlandCID001352
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.ChinaCID001622
GoldSolar Applied Materials Technology Corp.Taiwan, Province of ChinaCID001761
GoldSumitomo Metal Mining Co., Ltd.JapanCID001798
GoldTanaka Kikinzoku Kogyo K.K.JapanCID001875
GoldTokuriki Honten Co., Ltd.JapanCID001938
GoldUnited Precious Metal Refining, Inc.United States of AmericaCID001993
GoldAbington Reldan Metals, LLCUnited States of AmericaCID002708
GoldL'Orfebre S.A.AndorraCID002762
GoldWEEEREFININGFranceCID003615
GoldGold by Gold ColombiaColombiaCID003641
GoldCoimpa Industrial LTDABrazilCID004010
GoldGG Refinery Ltd.Tanzania, United Republic ofCID004506
GoldArgor-Heraeus S.A.SwitzerlandCID000077
GoldHangzhou Fuchunjiang Smelting Co., Ltd.ChinaCID000671



MetalSmelter NameSmelter Facility LocationSmelter ID
GoldAida Chemical Industries Co., Ltd.JapanCID000019
GoldIshifuku Metal Industry Co., Ltd.JapanCID000807
GoldJX Nippon Mining & Metals Co., Ltd.JapanCID000937
GoldSichuan Tianze Precious Metals Co., Ltd.ChinaCID001736
GoldWestern Australian Mint (T/a The Perth Mint)AustraliaCID002030
GoldYunnan Copper Industry Co., Ltd.ChinaCID000197
GoldTongling Nonferrous Metals Group Co., Ltd.ChinaCID001947
TantalumF&X Electro-Materials Ltd.ChinaCID000460
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDChinaCID000616
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.ChinaCID000914
TantalumJiujiang Tanbre Co., Ltd.ChinaCID000917
TantalumMitsui Mining and Smelting Co., Ltd.JapanCID001192
TantalumNPM Silmet ASEstoniaCID001200
TantalumNingxia Orient Tantalum Industry Co., Ltd.ChinaCID001277
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.ChinaCID001522
TantalumTaki Chemical Co., Ltd.JapanCID001869
TantalumUlba Metallurgical Plant JSCKazakhstanCID001969
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.ChinaCID002492
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.ChinaCID002506
TantalumTANIOBIS Co., Ltd.ThailandCID002544
TantalumTANIOBIS GmbHGermanyCID002545
TantalumMaterion Newton Inc.United States of AmericaCID002548
TantalumTANIOBIS Japan Co., Ltd.JapanCID002549
TantalumTANIOBIS Smelting GmbH & Co. KGGermanyCID002550
TantalumGlobal Advanced Metals BoyertownUnited States of AmericaCID002557
TantalumJiangxi Tuohong New Raw MaterialChinaCID002842
TantalumPowerX Ltd.Korea, Republic ofCID004054
TinGejiu Non-Ferrous Metal Processing Co., Ltd.ChinaCID000538
TinChina Tin Group Co., Ltd.ChinaCID001070
TinPT Timah Tbk KundurIndonesiaCID001477
TinPT Timah Tbk MentokIndonesiaCID001482
TinThaisarcoThailandCID001898
TinTin Smelting Branch of Yunnan Tin Co., Ltd.ChinaCID002180



MetalSmelter NameSmelter Facility LocationSmelter ID
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.ChinaCID000228
TinAlpha Assembly Solutions IncUnited States of AmericaCID000292
TinDowaJapanCID000402
TinFenix MetalsPolandCID000468
TinGejiu Zili Mining And Metallurgy Co., Ltd.ChinaCID000555
TinMineracao Taboca S.A.BrazilCID001173
TinMinsurPeruCID001182
TinMitsubishi Materials CorporationJapanCID001191
TinJiangxi New Nanshan Technology Ltd.ChinaCID001231
TinOperaciones Metalurgicas S.A.Bolivia (Plurinational State Of)CID001337
TinRui Da HungTaiwan, Province of ChinaCID001539
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.ChinaCID002158
TinO.M. Manufacturing Philippines, Inc.PhilippinesCID002517
TinAurubis BeerseBelgiumCID002773
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.ChinaCID003116
TinChifeng Dajingzi Tin Industry Co., Ltd.ChinaCID003190
TinGejiu City Fuxiang Industry and Trade Co., Ltd.ChinaCID003410
TinMalaysia Smelting Corporation Berhad (Port Klang)MalaysiaCID004434
TinMetallic Resources, Inc.United States of AmericaCID001142
TinPT Mitra Stania PrimaIndonesiaCID001453
TinEstanho de Rondonia S.A.BrazilCID000448
TinSuper LigasBrazilCID002756
TinLuna Smelter, Ltd.RwandaCID003387
TinPrecious Minerals and Smelting LimitedIndiaCID003409
TinWoodcross Smelting Company LimitedUgandaCID004724
TinEM VintoBolivia (Plurinational State Of)CID000438
TinDongguan CiEXPO Environmental Engineering Co., Ltd.ChinaCID003356
TungstenChongyi Zhangyuan Tungsten Co., Ltd.ChinaCID000258
TungstenJapan New Metals Co., Ltd.JapanCID000825
TungstenXiamen Tungsten (H.C.) Co., Ltd.ChinaCID002320
TungstenA.L.M.T. Corp.JapanCID000004
TungstenGlobal Tungsten & Powders LLCUnited States of AmericaCID000568



MetalSmelter NameSmelter Facility LocationSmelter ID
TungstenWolfram Bergbau und Hutten AGAustriaCID002044
TungstenXiamen Tungsten Co., Ltd.ChinaCID002082
TungstenGanzhou Seadragon W & Mo Co., Ltd.ChinaCID002494
TungstenMasan High-Tech MaterialsViet NamCID002543
TungstenNiagara Refining LLCUnited States of AmericaCID002589
TungstenCronimet Brasil LtdaBrazilCID003468
TungstenJiangxi Yaosheng Tungsten Co., Ltd.ChinaCID002316
TungstenH.C. Starck Tungsten GmbHGermanyCID002541




Attachment C

List of Countries of Origin
Albania
Andorra
Angola
Argentina
Armenia
Australia
Austria
Azerbaijan
Belarus
Belgium
Benin
Bolivia (Plurinational State of)
Brazil
Burkina Faso
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Congo
Democratic Republic of Congo
Djibouti
Dominica
Dominican Republic
Ecuador
Egypt
El Salvador
Eritrea
Estonia
Ethiopia
France
Germany
Ghana
Guatemala
Guinea
Guyana
Honduras
Hong Kong
Hungary
India
Indonesia
Ireland
Israel
Japan
Jersey
Kazakhstan
Korea
Kyrgyzstan
Liberia
Liechtenstein
Luxembourg
Madagascar
Malaysia
Mali
Mauritania
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
Nicaragua
Niger
Nigeria
Panama
Papua New Guinea
Peru
Philippines
Poland
Portugal
Russian Federation
Rwanda
Saudi Arabia
Sierra Leone
Singapore
Slovakia
South Africa
South Sudan
Spain
Sudan
Suriname
Sweden
Switzerland
Taiwan
Tanzania
Thailand
Uganda
United Kingdom
United States
Uzbekistan
Viet Nam
Zambia
Zimbabwe