HPQ HP Inc

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

HEWLETT-PACKARD COMPANY

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

Rishi Varma
Senior Vice President, Deputy General Counsel and Assistant Secretary
(650) 857-1501

(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:

x                                  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.

Section 1 — Conflict Minerals Disclosure

Item 1.01                                           Conflict Minerals Disclosure and Report

Hewlett-Packard Company (“HP”) is a leading global provider of products, technologies, software, solutions and services to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health and education sectors. We have a long-standing commitment to global citizenship. As part of our commitment, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HP’s Supply Chain Social and Environmental Responsibility Policy, which is available on our website at http://www8.hp.com/us/en/hp-information/global-citizenship/society/supplier-ser-requirements.html. In 2011, we added to this policy a section on conflict minerals (as defined in Item 1.01 of Form SD) and communicated our expectations with respect to these conflict minerals to our supply chain.

Conflict Minerals Disclosure

A copy of the Conflict Minerals Report filed for the calendar year ended December 31, 2014 is publicly available electronically at http://www.hp.com/hpinfo/globalcitizenship/environment/pdf/conflictminerals.pdf.

Item 1.02                                           Exhibit

The Conflict Minerals Report for the calendar year ended December 31, 2014 is filed as Exhibit 1.01 hereto.

Section 2 — Exhibits

Item 2.01                                           Exhibits

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

1

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.

2

EXHIBIT 1.01

CONFLICT MINERALS REPORT OF HEWLETT-PACKARD COMPANY

PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934

Hewlett-Packard Company (“HP”) presents this Conflict Minerals Report for the reporting period of January 1, 2014 to December 31, 2014 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission. Unless otherwise specified or unless the context otherwise requires, references to “HP,” “we,” “us” or “our” refer to Hewlett-Packard Company and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD.

Overview of our Conflict Minerals Program

HP is a leading global provider of products, technologies, software, solutions and services to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health and education sectors. As part of our long-standing commitment to global citizenship, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HP’s Supply Chain Social and Environmental Responsibility Policy, which is available on our website at http://www8.hp.com/us/en/hp-information/global-citizenship/society/supplier-ser-requirements.html. In 2011, we added to this policy a section on conflict minerals. We engage in ongoing supplier outreach and communications regarding the substance of our conflict minerals policy, our expectations of suppliers with respect to conflict minerals, and our objective of responsible mineral sourcing.

HP collaboratively works with other businesses, nongovernmental organizations, government agencies, and our extensive network of direct suppliers to advance the use of responsibly sourced minerals, including from the Democratic Republic of the Congo (“DRC”) and adjoining countries (collectively, the “Covered Countries”). Our work began in 2008 when we helped establish the working group that was the precursor to the Conflict Free Sourcing Initiative (“CFSI”) and in 2010 we began investigating the uses of tantalum in our products. This year we are able to announce that all of the tantalum smelters reported to be in the supply chain for our products are compliant with the Conflict Free Smelter Program. Other examples of our engagement and contributions to industry and multi-stakeholder groups, as well as in-region sourcing projects, include the Kemet Partnership for Social and Economic Sustainability, the former Conflict Free Tin Initiative, the International Tin Research Institute’s Tin Supply Chain Initiative, the Public-Private Alliance for Responsible Mineral Trade, Responsible Sourcing Network’s Multi-Stakeholder Group, and the Solutions for Hope Project.

HP Products

Conflict minerals in the form of gold and the derivatives tin, tantalum, and tungsten (collectively, “3TG”) were necessary to the functionality or production (“necessary conflict minerals”) of the following categories of products that we manufactured or contracted to manufacture during 2014.

·                  Enterprise Products. Server, storage and networking products, and certain accessories.

·                  Personal Systems Products. Consumer and commercial personal computers, workstations, calculators, tablets, and certain accessories.

·                  Printing Products. Consumer and commercial printer hardware, scanning devices, certain associated supplies, and certain accessories.

Reasonable Country of Origin Inquiry

We conducted a reasonable country of origin inquiry (“RCOI”) to determine whether any of the necessary conflict minerals in our 2014 products originated in the Covered Countries, or were conflict minerals from recycled or scrap sources. To make this determination, we focused on engaging our suppliers to identify the smelters and refiners (“facilities”) of necessary conflict minerals that may have been contained in our products and that are recognized by CFSI to be processors of conflict minerals (“Potential 3TG Facilities”), and reviewing available information on the sourcing of conflict minerals by Potential 3TG Facilities.

Our RCOI included:

·                  a survey of 950 of our direct suppliers using the CFSI Conflict Minerals Reporting Template (the “Template”), from which we identified the 418 direct suppliers of materials, parts, components or products containing necessary conflict minerals (“3TG Direct Suppliers”);

·                  requiring, as part of the survey and our accompanying communications, that suppliers use the Template to obtain and provide to HP information from their supply chains regarding Potential 3TG Facilities and the origin of necessary conflict minerals processed at these facilities;

·                  conducting follow-up with 3TG Direct Suppliers to clarify, update or complete information reported to us through the survey;

·                  obtaining responses from 3TG Direct Suppliers estimated to represent more than 95% of our 2014 spend with such suppliers;

·                  reviewing any information on countries of origin available through our membership in CFSI (member ID HPQQ) for Potential 3TG Facilities; and

·                  engaging an external expert consultant to review other publicly available information to assist us in determining whether or not Potential 3TG Facilities may have sourced from the Covered Countries.

For reporting year 2014, we have determined with respect to our products containing necessary conflict minerals that we know or have reason to believe that some of the necessary conflict minerals originated or may have originated in the Covered Countries. Further, we know or have reason to believe that these necessary conflict minerals may not be conflict minerals from recycled or scrap sources.

Accordingly, we conducted due diligence on the source and chain of custody of necessary conflict minerals processed by Potential 3TG Facilities and have prepared this Conflict Minerals Report.

Design of Our Due Diligence Measures

We designed our due diligence measures to conform with applicable portions of 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 (Second Edition, OECD 2013)

2

and the related Supplements (collectively, the “OECD Guidance”), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures took into account our individual facts and circumstances, particularly our downstream position in the minerals supply chain, the OECD recommendations for downstream actors that have no direct relationships to smelters or refiners(1), and the use of independent facility assessment programs to provide information about smelters or refiners.

Consistent with the OECD Guidance, the design of our due diligence has the following features:

(1) Establishment of strong internal company management systems, including a Conflict Minerals Policy; a Conflict Minerals Program team with senior management support; a Supply Chain Transparency System; engagement with suppliers to communicate and reinforce HP expectations; and a company level grievance mechanism that is available internally and externally to report concerns, including those related to conflict minerals.

(2) Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Conflict Minerals Program team in systematically surveying, collecting, and analyzing information relating to the use of necessary conflict minerals in the supply chain for our products.

(3) Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on the due diligence practices of Potential 3TG Facilities, formulation of a risk management plan, and reporting to senior management.

(4) Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices, including through our membership in CFSI, the industry initiative that conducts audits of facilities’ due diligence activities, and assisting CFSI by making facility visits to recruit facilities to participate in the Conflict Free Smelter Program.

(5) Annual reporting through this Conflict Minerals Report, supplemented with additional information about our Conflict Minerals Program in our annual Living Progress Report.

Description of Due Diligence Measures Performed

We undertook due diligence on the source and chain of custody of necessary conflict minerals processed by Potential 3TG Facilities and reviewed our results with senior supply chain management.

Due diligence measures:

·                  compared the Potential 3TG Facilities to the facilities that are listed by CFSI as either compliant or in process(2) with the Conflict Free Smelter Program;

(1)  The OECD Guidance distinguishes between “upstream” and “downstream” actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HP; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.

(2)  Throughout this Conflict Minerals report, “in process” refers to facilities that are listed by CFSI as (a) currently in the process of becoming Conflict Free Smelter Program compliant or (b) Tungsten Industry-Conflict Minerals Council (TI-CMC) Category A members.

3

·                  directly engaged Potential 3TG Facilities through 11 facility visits and 61 email communications to provide conflict minerals education, collect information on necessary conflict minerals related to the supply chain for our products, or further encourage participation in the Conflict Free Smelter Program;

·                  implemented a risk management plan including engagement with the relevant 3TG Direct Supplier when a conflict minerals risk was identified with that supplier;

·                  supported the Conflict Free Smelter Program through leadership participation in sub-committees and on the CFSI Steering Committee; and

·                  asked 3TG Direct Suppliers to encourage the Potential 3TG Facilities in their supply chain to join the Conflict Free Smelter Program.

Results

We made strong progress toward our objective of responsible minerals sourcing. Of the 257 total Potential 3TG Facilities identified, we believe 22 may source necessary conflict minerals from the Covered Countries. As of April 20, 2015, all 22 of these facilities were listed by CFSI as compliant with the Conflict Free Smelter Program. Globally, 76% of the Potential 3TG Facilities are now Conflict Free Smelter Program compliant or in process to become compliant. All of the tantalum smelters reported to be in our supply chain, whether or not they are sourcing from the Covered Countries, are also compliant with the Conflict Free Smelter program.

Table 1 provides a breakdown of our progress with Potential 3TG Facilities. We more than doubled the number of Potential 3TG Facilities that are compliant as well as the number of Potential 3TG Facilities that are in process to become compliant.

Table 1: Progress in Facility Status

4

Table 2 further illustrates our results by providing, for each metal, the number and percentage of Potential 3TG Facilities that were either Conflict Free Smelter Program compliant or in process to become compliant as of April 20, 2015.

Table 2: 2014 Compliant or in process facilities, by metal

Attachment A to this Conflict Minerals Report sets forth the name and status of the 257 Potential 3TG Facilities we identified, and is reasonably believed by us to include the facilities that processed necessary conflict minerals contained in our products.

Attachment B to this Conflict Minerals Report sets forth the countries reasonably believed by us to include the countries of origin of the necessary conflict minerals contained in our products.

Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity

As a downstream actor we rely upon independent facility assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for a downstream actor like HP, our efforts to facilitate upstream mine or location of origin determinations were focused on support of independent facility assessment programs such as the Conflict Free Smelter Program.

To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by independent facility assessment programs, we:

·                  surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the Template (which included questions about the mine or location of origin) and required those suppliers to make similar efforts to survey their supply chains using the Template;

·                  reviewed information obtained through those surveys on the 3TG facilities reported by our suppliers, i.e., our Potential 3TG Facilities, and any mine or location of origin information if it was provided;

·                  assessed any information on countries of origin available through our membership in CFSI for Potential 3TG Facilities (as part of the Conflict Free Smelter Program audit protocol, the independent auditor makes an examination of the countries of origin as well as the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to CFSI members);

·                  engaged an external expert consultant to review publicly available information that was self-declared by the facility, or found in publicly available media or reports, for further analysis of Potential 3TG Facilities; and

5

·                  took into account other information on the mine or location of origin of minerals as available, for example, as part of our direct outreach to facilities.

Steps to Further Mitigate Risk and Improve Due Diligence in 2015

We have identified the following steps that are intended to improve the quality of information we receive from 3TG Direct Suppliers in 2015 and to further mitigate any risk that necessary conflict minerals in our products finance or benefit an armed group:

·                  engage with 3TG Direct Suppliers to improve the completeness and accuracy of information provided to us;

·                  repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the Conflict Free Smelter Program; and

·                  support the development of the CFSI’s Conflict Free Smelter Program, including outreach efforts to encourage participation in the program.

6

Attachment A

Facility List

This Facility List is the result of our review of data from several sources, including information reported to us by our 3TG Direct Suppliers, obtained through supplemental engagement with facilities, and from CFSI. In many cases facility information was provided to us for the entire supply chain of our 3TG Direct Suppliers, and did not identify those facilities believed to contribute necessary conflict minerals to an HP product.

(3)  Entities that have been reported to us by 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by CFSI as a smelter, refiner, recycler or scrap processor (as of April 20, 2015). The facility names are listed as they appear on the CFSI Smelter or Refiner Information Exchange. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler or scrap processor) that is processing different types of minerals or metals.

(4)  Mine or location of origin likely outside of Covered Countries refers to tin processing facilities located in Indonesia that, after reasonable due diligence, we believe are not sourcing cassiterite from the Covered Countries.

(5)  CFSP Compliant refers to facilities that are listed by CFSI (as of April 20, 2015) as (a) compliant with Conflict Free Smelter Program protocols or (b) certified or accredited by a similar independent facility assessment program such as the Responsible Jewellery Council’s (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Association’s (LBMA) Responsible Gold Programme. In Process refers to facilities that are listed by CFSI (as of April 20, 2015) as (a) currently in the process of becoming Conflict Free Smelter Program compliant (“In Process”) or (b) Tungsten Industry-Conflict Minerals Council (TI-CMC) Category A members (“In Process (TI-CMC Category A)”). Not yet participating refers to facilities with sourcing practices that could not yet be determined.

A-1

A-2

A-3

A-4

A-5

A-6

A-7

A-8

A-9

A-10

Attachment B

Countries of Origin

Based on information available from CSFI as of April 20, 2015 and additional research by our external expert consultant, we believe that the countries of origin of the necessary conflict minerals contained in our products include the following countries.

B-1

B-2