LPL LG Display Co Ltd

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

LG Display Co., Ltd.

(Exact name of registrant as specified in its charter)

Jungseob Oh

LG Display Co., Ltd. Investor Relations Team

+82-2-3777-1010

(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

A company is required to file Form SD pursuant to Rule 13p-1 promulgated under the Exchange Act if it manufactures, or contracts to manufacture, products for which certain specified minerals are necessary to the functionality or production of the products. These minerals consist of columbite-tantalite (also referred to as “coltan”), cassiterite and wolframite (and their derivatives tantalum, tin, and tung­sten), and gold and are referred to as “conflict minerals” (also referred to herein as “3TG minerals”) regardless of the geographic origin of the minerals and whether or not they fund armed conflict.

LG Display Co., Ltd. (together with its consolidated subsidiaries, also referred to herein as “we” or “our”) manufactures display panelsfor which we have determined that 3TG minerals are necessary to the functionality or production of those products. Accordingly, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) with respect to 3TG minerals contained in those products manufactured in 2023. We believe our RCOI was reasonably designed to determine whether any 3TG minerals contained in our products originated in the Democratic Republic of the Congo or an adjoining country (together, the “Covered Countries”), or are from recycled or scrap sources.

We have prepared a Conflict Minerals Report, which is attached as an exhibit hereto and also publicly available on our website at www.lgdisplay.com.

Item 1.02: Exhibit

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

SECTION 2 – RESOURCE EXTRACTION ISSUER DISCLOSURE

Item 2.01: Resource Extraction Issuer Disclosure and Report

Not applicable.

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.

EXHIBIT INDEX

CONFLICT MINERALS REPORT OF LG DISPLAY CO., LTD.
FOR THE YEAR ENDED DECEMBER 31, 2023
 

This is the Conflict Minerals Report of LG Display Co., Ltd. for the year ended December 31, 2023 (this “Report”). In this Report, the terms “we,” “us” and “our” refer to LG Display Co., Ltd. and its consolidated subsidiaries. Capitalized terms in this Report that have not been expressly defined herein have the meanings assigned to them in Rule 13p-1 (“Rule 13p-1”) under the Exchange Act of 1934, as amended (the “Exchange Act”), and Form SD.

A company is required to file Form SD with the U.S. Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 if it manufactures, or contracts to manufacture, products for which certain specified minerals are necessary to the functionality or production of the products. These minerals consist of columbite-tantalite (also referred to as “coltan”), cassiterite and wolframite (and their derivatives tantalum, tin, and tung­sten), and gold and are referred to as “conflict minerals” (also referred to as “3TG minerals” in this Report) regardless of the geographic origin of the minerals and whether or not they fund armed conflict.

This Report is also publicly available on our website at: https://www.lgdisplay.com/eng/esg/social/scm/conflict-minerals

This document includes forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995, including (but not limited to) statements about expected future supplier diligence and engagement efforts, development of our systems supporting those efforts and participation in industry supply chain efforts. Many of the forward-looking statements contained in this document may be identified by the use of words such as “believe,” “expect,” “anticipate,” “should,” “planned,” “estimate” and “potential,” among others. These forward-looking statements are based on our expectations and beliefs concerning future events and involve risks and uncertainties that may cause actual results to differ materially from current expectations. These risks and uncertainties are difficult to predict accurately and may be beyond our control, and may include (but are not limited to) the following: regulatory changes and judicial developments relating to conflict minerals disclosure; changes in or developments related to our products or our supply chain; industry developments relating to supply chain diligence, disclosure and other practices; and cost considerations. Other risks and uncertainties relevant to our forward-looking statements are discussed in greater detail in our reports filed with the SEC. Forward-looking statements in this document speak only as of the date made, and we disclaim any obligation to update or revise these statements as a result of new developments or otherwise.
 

Company and Product Overview

We are a leading innovator of organic light-emitting diode (“OLED”) technology, thin-film transistor liquid crystal display (“TFT-LCD”) technology and other display panel technologies. We manufacture and sell display panels in a broad range of sizes and specifications primarily to end-brand customers who incorporate our display panels as component parts in the manufacture and assembly of IT products (comprising notebook

computers, desktop monitors and tablet computers), televisions and various other application products, including mobile devices, entertainment systems, automotive displays, portable navigation devices and medical diagnostic equipment. 3TG minerals are commonly used in electronic products in general, and we have determined that they are necessary to the functionality of our display panels and light panels, which consist of thousands of component parts and raw materials, including circuit components such as chips, wires and electrodes that are coated using 3TG minerals, and transparent electrodes for which 3TG minerals are a key material.

For additional information about our business in general, please refer to our most recent annual report on Form 20-F for the year ended 2023 filed with the SEC on April 29, 2024.

Conflict Minerals Policy

As a responsible corporate citizen, we believe in ethical sourcing and have formulated and announced a conflict minerals policy (our “Policy”), which is to eliminate from our products the use of 3TG minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together, the “Covered Countries”). Our current Policy is publicly available on our website at https://www.lgdisplay.com/eng/esg/social/scm/conflict-minerals and serves as a common reference point for all our suppliers and us internally.

Results of Reasonable Country of Origin Inquiry

As required under Rule 13p-1, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) with respect to 3TG minerals contained in our products manufactured in 2023. We believe our RCOI was reasonably designed to determine whether any 3TG minerals contained in our products originated in the Covered Countries or were from recycled or scrap sources.

Based on our RCOI, and as described further below, although we did not find any indication that the 3TG minerals necessary to the functionality of our productsoriginated from a Covered Country, we concluded that we had insufficient information to determine that there was no reason to believe that the 3TG minerals necessary to the functionality of our products may have originated from a Covered Country or were not from recycled or scrap sources.

Source and Chain of Custody Due Diligence

Given the results of our RCOI, we engaged in additional due diligence on the source and chain of custody of the 3TG minerals necessary to the functionality of our products. As further described below, our due diligence conformed in all material respects to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements (“OECD Guidance”) for downstream companies.

As an integral part of our source and chain of custody due diligence, we have conducted supply chain surveys by requesting that our suppliers of component parts and raw materials used

in our products (the “Covered Suppliers”) fill out the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”), which is an initiative founded by members of the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative and was formerly named the Conflict-Free Sourcing Initiative.
Responsible Minerals Assurance Process (“RMAP”), which was formerly called the Conflict-Free Smelter Program, of the RMI uses an independent third-party audit to identify smelters and refiners that have systems in place to assure sourcing of only minerals not benefitting armed groups in the Covered Countries. Further, we have requested certifications from each Covered Supplier regarding the truthfulness of its CMRT responses.

Company Management System

Our senior management established a 3TG minerals task force consisting of managerial level employees from our Purchasing Planning Team, Legal Department and Investor Relations Team along with outside consultants (the “Task Force”) to take the lead in formulating our Policy, implementing our Policy with our suppliers and us internally and conducting due diligence on our supply chain based on the OECD Guidance. The Task Force assigned roles and responsibilities to relevant internal teams and departments to implement our Policy and established a process for monitoring 3TG minerals in our supply chain.

Further to our efforts to more accurately identify the use of 3TG minerals in our supply chain, we implemented a conflict minerals management system (our “System”) for the overall management and coordination of our processes related to 3TG minerals, including verification of supplier data, immediate risk assessments and analyses of 3TG minerals usage statistics. The implementation of our System has enabled us to categorize and monitor our 3TG minerals usage
by buyer and model, on a real-time basis, and to track 3TG minerals throughout our supply chain.

In 2014, the continuing roles and responsibilities of the Task Force were transferred to the Purchasing Group. Within the Purchasing Group, the Purchasing Planning Team sets overall strategy and response processes, and the frontline purchasing teams obtain and verify data from our suppliers. Our chief production officer and the head of the Purchasing Group review monthly status reports and remain highly involved in the management of our System, as does our chief executive officer who is briefed with status updates periodically.

In 2013 and 2014, we engaged with senior management and working level personnel of our direct Covered Suppliers as well as second- and third-tier suppliers to raise awareness of regulations applicable to the sourcing of 3TG minerals and to educate them on our Policy, as well as to share policy guidelines and updates on conflict minerals management in an effort to facilitate compliance on their part. Since 2015, we have conducted additional supplier education outreach to suppliers for whom we deemed such additional outreach was necessary.

The implementation of our System and our supplier education efforts have also contributed to the reliability and accuracy of the information we are able to garner from and about our supply chain. In 2023, as a result of verification efforts by us and our suppliers, including direct communications with listed entities and requests for product-by-product level CMRT responses from our suppliers, we were able to identify 220 smelters and refiners that we believed were operational and still in our supply chain as of December 31, 2023.

We have continued in our efforts to identify and monitor smelters and refiners and encourage them to receive verification as independently audited under the RMAP of the RMI. We have also established an action plan to address unaudited smelters and refiners; to improve the integrity and accuracy of the information in our 3TG minerals database; and to hedge our exposure to operational risks associated with 3TG minerals.

In furtherance of our Policy, we require all of our suppliers to agree to terms that reflect our Policy. In the case of Covered Suppliers who responded that they do not use 3TG minerals or that they source from smelters or refiners that have been verified as conformant with the RMAP’s assessment protocols (“RMAP-conformant”), we require that they covenant not to use 3TG minerals that directly or indirectly finance or benefit armed groups in the Covered Countries. We have also developed a supplier code of conduct and we encourage our suppliers to formulate their own 3TG policies and identify all smelters and refiners that supply 3TG minerals in their supply chains. To encourage compliance with our Policy, we have also made the reporting center, including the cyber reporting center, of our Administrative Office of Ethics available to our employees, suppliers and other stakeholders to report any alleged violations of our Policy on a confidential basis. In addition, with a view to efficiently and practically address applicable regulations, we continue to attend governmental and non-governmental forums and conferences, and actively participate in a consultation committee with our affiliates, LG Electronics, LG Chem and LG Innotek. Moreover, as members of the Responsible Business Alliance and RMI, we actively participate in joint international efforts to improve the social, environmental and ethical conditions of global minerals supply chains.

Supply Chain Risk Identification and Assessment

In their CMRT responses, our Covered Suppliers identified smelters and refiners that they listed as sources for the 3TG minerals contained in the component parts and raw materials they supply. We further checked whether any of these smelters or refiners were located in or near Covered Countries or areas suspected of transporting or sourcing 3TG minerals from Covered Countries. We utilized our System to perform immediate risk assessments on our Covered Suppliers’ 3TG mineral information and informed our Covered Suppliers of applicable risks. We continue to monitor the risk hedging activities of our Covered Suppliers.

Based on their CMRT responses, we assessed the risk associated with the Covered Suppliers, smelters and refiners and categorized each Covered Supplier into one of the following three categories:

Response Strategy to Identified Risk

To address the identified risks, we established a risk hedging plan with respect to suppliers in the High Risk category. Pursuant to the risk hedging plan, we instructed suppliers within the High Risk category to adhere to the following alternatives:

We have historically selected suppliers which were in the High Risk category for additional due diligence. The selection criteria for these suppliers also included whether the supplier had a 3TG minerals policy of its own, the importance of the supplier to our production process (in terms of proportion of purchases), the extent to which the supplier sourced 3TG minerals from smelters and refiners that were not independently audited under the RMAP, the geographic location of the supplier and the geographic location of the smelters and refiners identified by the supplier. We have conducted on-site due diligence of these selected suppliers and examined their 3TG minerals management levels by reviewing the CMRT responses, 3TG minerals policies and internal processes of their up-stream suppliers. We have engaged in additional training and education with these selected suppliers on applicable regulations and how to improve their 3TG minerals management and we have assessed their improvements and grievances.

Third-party Independent Audit of Supply Chain

As a downstream company, there are many steps in the supply chain separating us from the mines, smelters and refiners that source the 3TG minerals contained in our products. With respect to smelters and refiners known to be in our supply chain, we make reference to independent third-party audits used by the RMAP to identify smelters and refiners that have systems in place to assure sourcing of only minerals not benefitting armed groups in the Covered Countries. Wehave not obtained an independent third-party audit of our own supply chain.

We will continue to support private and public efforts to encourage sourcing of 3TG minerals not benefitting armed groups in the Covered Countries.

Results of Source and Chain of Custody Due Diligence

We obtained CMRT responses from 100% of our Covered Suppliers, excluding suppliers no longer in our supply chain, as of December 31, 2023. We assessed the conformity and

reliability of these CMRT responses, conducted risk analyses and compliance improvement activities, and provided regular progress updates to our chief executive officer and other relevant members of management. In addition, we implemented strict limitations on authorizing transactions with new suppliers where risks materialized. We believe that these efforts have driven the following results.

Based on the CMRT responses provided by our Covered Suppliers and our further due diligence to confirm the usage of 3TG minerals within our supply chain, we identified a total of 220 entities as smelters or refiners from which 3TG minerals were sourced. All of the 220 smelters and refiners we identified in 2023 were independently audited under the RMAP and designated as “conformant,” and there were no smelters or refiners that were (x) progressing towards completion of an independent audit under the RMAP and designated as “active” or (y) not independently audited under the RMAP (“non-participating”).

As a result of our source and chain of custody due diligence for the year ended December 31, 2023, we were able to confirm that 100% of the tantalum, tin, tungsten and gold smelters known to be in our supply chain as of December 31, 2023 were RMAP-conformant. We therefore found no reasonable basis for concluding that our sourcing of 3TG minerals necessary to the functionality of our products directly or indirectly financed or benefitted armed groups in the Covered Countries.

The following table sets forth the number of smelters and refiners in our supply chain by RMAP status and type of mineral.

Based on the information provided by our suppliers and our own due diligence efforts with known smelters and refiners through December 31, 2023, we believe that the facilities that may have been used to process the 3TG minerals in our products include the smelters and refiners listed in Annex I below.

Future Measures

We will continue to seek to source all 3TG minerals in our supply chain from smelters and refiners that are RMAP-conformant or that have otherwise been verified under an independent third-party audit as sourcing only minerals not benefitting armed groups in the
Covered Countries, and we intend to do so through the following measures:

Conformant Smelters and Refiners