UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
HEWLETT PACKARD ENTERPRISE COMPANY
(Exact name of the registrant as specified in its
charter)
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DELAWARE
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001-37483
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47-3298624
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(State or other jurisdiction of
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(Commission File Number)
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(IRS Employer Identification No.)
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incorporation or organization)
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1701 EAST MOSSY OAKS ROAD, SPRING, TX
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77389 |
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(Address of principal executive offices)
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(Zip Code)
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Rishi Varma
Senior
Vice President, General Counsel and Corporate
Secretary
678-259-9860
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(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, 2022.
☐
Rule 13p-1 under the Securities Exchange Act (17 CFR
240.13p-1) for the fiscal year ended ______.
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and
Report
HPE Company Overview
We are a global technology leader focused on developing intelligent
solutions that allow customers to capture, analyze and act upon
data seamlessly from edge to cloud. We enable customers to
accelerate business outcomes by driving new business models,
creating new customer and employee experiences, and increasing
operational efficiency today and into the future. Our customers
range from small- and medium-sized businesses to large global
enterprises and governmental entities. Our legacy dates back to a
partnership founded in 1939 by William R. Hewlett and David
Packard. We strive every day to uphold and enhance that legacy
through our dedication to providing innovative technological
solutions to our customers.
Unless otherwise specified or unless the context otherwise
requires, we use the terms “Hewlett Packard Enterprise”, “HPE”,
“the Company”, “we”, “us”, and “our” to refer to Hewlett Packard
Enterprise 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. References to our websites
and information available through these websites are not
incorporated by reference into this Conflict Minerals Disclosure
and Report.
Our Responsible Minerals Program
HPE is committed to the responsible sourcing of minerals used in
its products and expects its suppliers to conduct their worldwide
operations in a socially and environmentally responsible and
sustainable manner, pursuant to HPE’s Supply Chain Social and
Environmental Responsibility Policy1
and HPE’s General Specification for the
Environment.2
Both policies contain a section on the responsible sourcing of
minerals.
We firmly believe that all people are entitled to basic freedoms
and standards of treatment, and we embed respect for
internationally recognized human rights within our Responsible
Minerals Program. We commit to align our approach with the United
Nations Guiding Principles on Business and Human Rights, as
described in HPE’s Global Human Rights Policy.3
Likewise, we expect our suppliers to uphold and respect human
rights, guided by best practice set out in these
standards.
As outlined in HPE’s Supply Chain Responsibility: Our Approach
guide,4
HPE takes a systematic approach to sensing, understanding, and
addressing risk. We re-examine and refine our program each year in
light of our experience and emerging best practices.
HPE has been recognized as an industry leader for the company’s
efforts to advance the use of responsibly sourced minerals. In
recognition of HPE’s focus on combatting modern slavery in our
supply chains and operations, which includes responsible sourcing
of minerals, the Thomson Reuters Foundation awarded HPE the Stop
Slavery Award twice in five years, in 2016 and 2021. In 2022, the
Ethisphere Institute named HPE as one of the “World’s Most Ethical
Companies” for the fifth year in a row, for “exemplifying and
advancing corporate citizenship, transparency and the standards of
integrity.” HPE also earned the highest ranking of KnowTheChain’s
2022 Benchmark for information communications and technology
(“ICT”) companies, and the highest ranking among the world’s
largest ICT companies in the 2022 Corporate Human Rights
Benchmark.
1
HPE’s Supply Chain Social and Environmental Responsibility Policy
is available at
https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04797673.
2
HPE’s General Specification for the Environment is available at
https://www.hpe.com/h20195/v2/Getdocument.aspx?docname=c04862211&ENW.
3
HPE’s Global Human Rights Policy is available at
https://h20195.www2.hpe.com/V2/getpdf.aspx/A00001847ENW.pdf.
4
HPE’s Supply Chain Responsibility – Our approach is available at
https://www.hpe.com/us/en/collaterals/collateral.a00001852enw.HPE-supply-chain-responsibility-E2-80-93-Our-approach-solution-guide.html?rpv=cpf&parentPage=/us/en/about/human-progress/supply-chain-responsibility.
Our goal is to improve the transparency of mineral sourcing within
our supply chain, while striving to ensure that the tin, tantalum,
tungsten, and gold (collectively, “3TG”) used in our products have
not benefited
armed groups
in the Democratic Republic of the Congo (“DRC”) and the DRC
adjoining countries
(collectively, the “Covered Countries”). Ultimately, we aim to
improve conditions in and around mining communities in the Covered
Countries and other Conflict-Affected and High-Risk Areas
identified by the presence of armed conflict, widespread violence,
or other human rights abuses. Because we believe it is important to
avoid the economic and humanitarian impacts associated with an
embargo of a particular region, we continually review and seek to
responsibly source – and do not prohibit our suppliers from
sourcing – from the Covered Countries and other Conflict-Affected
and High-Risk Areas.
Conflict Minerals Disclosure
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) to
determine whether any
conflict minerals
in our 2022 products originated in the Covered Countries or
were
conflict minerals from recycled or scrap sources.
To make this determination, downstream companies like HPE must
obtain and review sourcing information on the entities reported to
provide conflict minerals contained in or necessary to the
functionality or production (collectively, “necessary conflict
minerals”) of our products in the form of 3TG. We asked our direct
suppliers to provide us with relevant information and to report to
us the entities that were providing necessary conflict minerals to
them or their suppliers. HPE’s supplier social and environmental
responsibility requirements, which include responsible minerals due
diligence and reporting obligations, are incorporated into
contracts with direct suppliers. HPE engages in ongoing supplier
outreach, education, and communications, addressing in particular
the substance of our responsible minerals policies, and our
expectations and objectives with respect to responsible
sourcing.
Our 2022 RCOI included:
•reaching
out
to
101 of
our
direct
suppliers
to
inquire
whether
they
are
direct
suppliers
of
materials,
parts, components, or products containing necessary conflict
minerals (“3TG Direct
Suppliers”);
•confirming
that 87 of the direct suppliers are 3TG Direct
Suppliers;
•requiring
that 3TG Direct Suppliers use the Responsible Minerals Initiative
(“RMI”) Conflict Minerals Reporting Template (the “CMRT”) to
collect and provide information from their supply chains to
identify the entities recognized by RMI to be smelters, refiners,
recyclers, or scrap processors of 3TG (“3TG
facilities”);
and,
in
relation
to
smelters
and
refiners
(“SORs”),
asking
our
direct
suppliers
to
collect and provide available information on the origin of
necessary conflict
minerals;
•engaging
in
regular
communication
–
through
email
and
over
the
phone
–
with
3TG
Direct
Suppliers regarding their CMRTs and addressing questions as
necessary;
•analyzing
3TG
Direct
Suppliers’
submissions
for
completeness
and
consistency,
including
sub-tier
supplier response rate and adoption of a conflict or responsible
sourcing of minerals
policy;
•specifying
any deficiencies or feedback for our 3TG Direct Suppliers to
address in their
submissions;
•providing
further
training, resources,
and
education,
as
necessary,
to
support
3TG
Direct
Suppliers
in
improving
the quality and completeness of their
CMRT;
•obtaining
acceptable
responses
from
3TG
Direct
Suppliers
estimated
to
represent
more
than
98%
of
our 2022 spend with such
suppliers;
•based
on the information provided by our 3TG Direct Suppliers,
identifying
330 operational
3TG
facilities
that
may
process
the
necessary
conflict
minerals
contained
in
the products provided to
us;
•encouraging
3TG facilities to participate in RMI’s Responsible Minerals
Assurance Processes audit program or a similar OECD-aligned,
independent assessment program such as the Responsible Jewellery
Council’s
Chain-of-Custody
and
Code
of
Practices
Program,
or
the
London
Bullion
Market
Association’s Responsible Gold Programme when our 3TG Direct
Suppliers report any not-yet-participating SORs in their
CMRTs;
•reviewing
any
information
available
through
our
membership
in
RMI
on
countries
of origin or recycled and scrap sourcing for the 3TG
facilities;
and
•engaging
an external expert to directly engage with 3TG facilities and
review other publicly available information
to
further
assist
us
in
evaluating
whether
or
not
certain
3TG
facilities
may
have
sourced
from the Covered Countries or may source only conflict minerals
from recycled or scrap
sources.
For 2022, 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 from 3TG
facilities originated or may have originated in the Covered
Countries and 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 from these 3TG facilities
and have prepared the Conflict Minerals Report attached hereto as
Exhibit 1.01.
A copy of the Conflict Minerals Report filed for the calendar year
ended December 31, 2022 will be publicly available electronically
for a period of one year at
www.hpe.com/info/conflictminerals.
Item 1.02 Exhibit
The Conflict Minerals Report for the calendar year ended
December 31, 2022 is filed as Exhibit 1.01
hereto.
Section 3 — Exhibits
Item 3.01 Exhibits
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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HEWLETT PACKARD ENTERPRISE COMPANY
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Dated: May 30, 2023
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By:
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/s/ John Schultz
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Name:
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John Schultz
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Title:
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Executive Vice President,
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Chief Operating and Legal Officer
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Grafico Azioni Hewlett Packard Enterprise (NYSE:HPE)
Storico
Da Set 2023 a Ott 2023
Grafico Azioni Hewlett Packard Enterprise (NYSE:HPE)
Storico
Da Ott 2022 a Ott 2023
