CNHI CNH Industrial NV

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form SD

Specialized Disclosure Report

CNH INDUSTRIAL N.V.

(Exact name of registrant as specified in charter)

Cranes Farm Road, Basildon, Essex, SS14 3AD, United Kingdom

(Address of principal executive offices)

Roberto Russo; Telephone: 44 2079 251964

(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 copy of CNH Industrial N.V.’s Conflict Minerals Report for the year ended December 31, 2023 is provided as Exhibit 1.01 hereto and is publicly available at https://www.cnh.com/en-US/Investor-Relations/financial_information/sec_filings

Item 1.02 Exhibit

CNH Industrial N.V. has filed, as Exhibit 1.01 to this Specialized Disclosure Report on Form SD, a Conflict Minerals Report.

Section 2 – Exhibits

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report for the year ended December 31, 2023 as required by Items 1.01 and 1.02 of this Form SD.

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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 duly authorized undersigned.

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Exhibit 1.01

CNH Industrial N.V.

Conflict Minerals Report

For The Year Ended December 31, 2023

This report has been prepared by CNH Industrial N.V. pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934 (the “Exchange Act”). References to internet websites herein are provided only as required by the Rule and information available through these websites is not incorporated by reference into this Form SD. Unless otherwise specified, the terms “we,” “us,” “our,” “CNHI,” and the “Company” refer to CNH Industrial N.V., a public limited liability company (naamloze vennootschap) organized under the laws of the Netherlands, together with its consolidated subsidiaries or any one or more of them, as the context may require.

With 2023 net sales of $24.7 billion, CNH Industrial is a leading equipment and services company engaged in the design, production, marketing, sale, and financing of agricultural and construction equipment. We have industrial and financial services companies located in 32 countries and a commercial presence in approximately 164 countries. CNH Industrial’s industrial operations include two segments. The Agriculture segment designs, manufactures and distributes a full line of farm machinery and implements, including two-wheel and four-wheel drive tractors, crawler tractors, combines, grape and sugar cane harvesters, hay and forage equipment, planting and seeding equipment, soil preparation and cultivation implements, and material handling equipment as well as technology dedicated to Precision Agriculture. The Construction segment designs, manufactures and distributes a full line of construction equipment including excavators, crawler dozers, graders, wheel loaders, backhoe loaders, skid steer loaders, and compact track loaders. CNH Industrial also provides financing and services through its Financial Services segment. Tin, tantalum, tungsten and gold (“3TG”) can be found in all of CNH Industrial’s products.

Our products are highly complex, typically containing thousands of parts from many direct suppliers. We have relationships with a vast network of suppliers throughout the world. Many of our suppliers are located outside the United States and include foreign entities that are not subject to the Rule. In addition, there are generally multiple tiers between the 3TG mines and our suppliers. Therefore, we must rely on our direct suppliers to work with their suppliers to provide us with accurate information on the origin of the 3TG contained in components and materials purchased by us.

We conducted an inquiry of our suppliers to determine the country of origin of the components provided to CNH Industrial. Our RCOI comprised identification of relevant suppliers and a survey of those suppliers.

Because of the scope and complexity of our supply chain, we developed a risk-based approach that focused on our major direct suppliers as well as direct suppliers that we believed were likely to provide us with components containing 3TG (collectively, the “Surveyed Suppliers”). Surveyed Suppliers represented approximately 86% of the purchases (by dollar value) that we made for goods from suppliers. For 2023, we received responses from more than 72% of our Surveyed Suppliers equaling 484 total responses.

We requested that all Surveyed Suppliers provide information to us regarding 3TG and smelters using the template developed by the Responsible Minerals Initiative (“RMI”), known as the Conflict Minerals Reporting Template (the “Template”). The Template is a free, standardized reporting template that facilitates disclosure and communication of information regarding smelters and refiners that provide 3TG to a manufacturer’s supply chain. It includes questions regarding a direct supplier’s conflict-free policy and its due diligence process, and requests information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TG used by such smelters and refiners. The information we receive is submitted into an electronic database to facilitate information analysis.

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Pursuant to the Rule, we undertook due diligence efforts on the source and country of origin of 3TG in our supply chain. The Rule requires that a registrant’s due diligence follow a nationally or internationally recognized due diligence framework. Presently, the only nationally or internationally recognized due diligence framework available is the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements for each of the conflict minerals (the “OECD Guidance”). The OECD Guidance is a framework for risk-based due diligence for responsible supply chains of conflict minerals from conflict-affected and high-risk areas that is described in the five-steps noted in Section V below.

CNH Industrial designed its due diligence measures to be in conformity, in all material respects, with the OECD Guidance.

This section IV describes measures performed by us to exercise due diligence on the source and chain of custody on the 3TG contained in our products.

OECD Step 1. Establish Strong Company Management Systems

Conflict Minerals Policy

CNHI Industrial has implemented a compliance program and a Conflict Minerals Policy intended to promote the responsible sourcing of 3TG from the Democratic Republic of the Congo and adjoining countries (the “Covered Countries”), where revenues from the extraction of these natural resources have historically funded armed conflict and human rights abuses. Our conflict minerals policy is publicly available on our website at https://www.cnh.com/-/media/CNHi/cnhicorporate/Governance/corporate_governance/sustainability_guidelines/CNH_Industrial_Conflict_Minerals_
Policy_2015.pdf?rev=-1

Internal Team

We have established a management system to support supply chain due diligence related to goods that may contain 3TG. Our management system includes a cross-functional executive steering committee sponsored by senior legal and compliance staff, and a team of subject matter experts from functions such as purchasing, sustainability and research and development. The next level of the management system is a team of subject matter experts (“CM Team”) from relevant functions within the Company, including procurement, quality, product safety, internal audit, and legal. The CM Team is responsible for implementing the Company’s due diligence procedures.

Control Systems

We do not have a direct relationship with 3TG smelters and refiners; therefore, we rely on suppliers to provide information on the origin of the 3TG contained in the components and materials supplied to us. We are a member of RMI (RMI Member Code: CNHI). RMI is an initiative developed to identify and disclose upstream actors in the supply chain, including 3TG smelters and refiners. RMI program initiatives include the Responsible Minerals Assurance Process (“RMAP”), which identifies smelters and refiners that source minerals in conformance with RMAP, and the Template. We use the Template in our RCOI and RMAP data and information in our identification and assessment of risks in the supply chain. The control systems that we have in place include, but are not limited to, a dedicated email address for conflict minerals information, supplier retention response through our third-party software tool and a smelter outreach program through RMI.

Supplier Engagement

We have provided the Surveyed Suppliers with instructions for responding to the Template and how to access our third-party software tool. Surveyed Suppliers also have access to a conflict minerals compliance e-mail address, monitored by a member of the Conflict Minerals working group, which Surveyed Suppliers could use to seek assistance in interpreting and completing the Template. Our standard purchase order terms and conditions and purchase agreements require our suppliers to provide us with supporting information and documentation evidencing due diligence of 3TG in their respective supply chains. We have adopted and made available to our suppliers a Supplier Code of Conduct that

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requires, among other things, all suppliers to exercise due diligence, in accordance with the OECD Guidance, on its entire supply chain with respect to the sourcing of all 3TG to determine whether those metals are from the Covered Countries and, if so, to determine whether those metals directly or indirectly financed or benefited armed groups that are perpetrators of serious human rights abuses in the Covered Countries.

Grievance Mechanism

We have processes to collect and act on concerns expressed by employees and others about possible improper or unethical business practices, violations of company policies (including our Code of Conduct, the Supplier Code of Conduct and Conflict Minerals Policy) or applicable laws. This grievance mechanism is described in our Conflict Minerals Policy.

OECD Step 2. Identify and Assess Risks in the Supply Chain

Our method for determining the country of origin of 3TG contained in our products was to conduct a supply-chain survey with Surveyed Suppliers using the Template. We have implemented a third-party software solution to collect and manage supplier CMRT data. We use this third-party solution to analyze the CMRT data provided by suppliers, aggregate the supplier CMRT data for our reporting, and follow up with any supplier whose CMRT data we identified to contain incomplete or potentially inaccurate data. We rely on our suppliers to provide information on the origin of 3TG contained in the components and materials supplied to us. These suppliers are similarly reliant upon information provided by their suppliers. Smelters and refiners identified by a supplier in response to our supply-chain survey are compared against the RMI list to identify and assist in assessing the risk that the 3TG used in our products may have originated in the Covered Countries.

OECD Step 3. Design and Implement a Strategy to Respond to Identified Risks

The Steering Committee is periodically briefed about our due diligence efforts. The executive officer signing this report is briefed on our conflicts minerals compliance program.

Suppliers are required to adhere to our Supplier Code of Conduct that requires, among other things, all suppliers to exercise due diligence, in accordance with the OECD Guidance, on its entire supply chain with respect to the sourcing of all 3TG to determine whether those metals are from the Covered Countries and, if so, to determine whether those metals directly or indirectly financed or benefited armed groups that are perpetrators of serious human rights abuses in the Covered Countries.

We have an internal escalation process for following up with unresponsive suppliers to increase the response rate, and we follow-up with the Surveyed Suppliers that provide incomplete or inconsistent responses. Finally, we follow up with Surveyed Suppliers who listed non-compliant smelters or refiners in their CMRT.

OECD Step 4. Carry Out Independent Third Party Audit of Supply Chain Due Diligence At Identified Points In The Supply Chain

We support audits of 3TG smelters and refiners conducted by third parties through our membership in RMI. RMI developed the RMAP, which uses an independent third-party audit to identify smelters and refiners that have management systems and sourcing practices in place to conform with RMAP protocols and global standards.

OECD Step 5. Report Annually on Supply Chain Due Diligence

This Conflict Minerals Report constitutes our annual report on our 3TG due diligence, is available on our website https://www.cnh.com/en-US/Investor-Relations/financial_information/sec_filings and is filed with the United States Securities and Exchange Commission.

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Survey Responses

We reviewed the Surveyed Supplier responses, including those not provided on the Template, to determine whether further engagement was necessary. When reviewing the Surveyed Supplier responses, we focused on incomplete responses as well as inconsistencies within the data reported by those suppliers. We worked directly with such suppliers in an effort to secure revised responses.

The Company relies on its suppliers to provide information on the origin of conflict minerals contained in the material supplied to the Company. In turn, those suppliers are reliant on the information supplied by their suppliers. The vast majority of the responses received provided data only with respect to the supplier’s overall 3TG sourcing, without specifying if the 3TG was used in the specific goods supplied to us. Consequently, we cannot be certain that the smelters or refiners identified by the vast majority of our Surveyed Suppliers supplied 3TG to us rather than to other customers of that Surveyed Supplier.

A minority of responses listed specific smelters or refiners. Such responses collectively identified 319 unique facilities as identified by the RMI, of which 228 were included on the RMAP Conformant Smelters and Refiners List. We also identified 1 smelter that may be sourcing from the Covered Countries and may not have been from recycled or scrap resources. This processing facility has been validated as compliant with RMAP protocols. Please see Attachment A for a list of smelters and refiners reported to us by the Surveyed Suppliers that listed specific smelters or refiners. The smelters or refiners listed in Attachment A may have processed the 3TG necessary for our products, but we do not have sufficient information to establish a direct link between our products and the smelters or refiners listed in Attachment A.

We requested our suppliers complete the Template, which includes questions regarding the locations of smelters and refiners or origin for the minerals. When a supplier cannot directly obtain information beyond smelter or refiner name, we consult the RMI to determine the country of origin and whether the smelter or refiner has been validated as RMAP conformant.

Going forward, we intend to build on our efforts and continue working with our suppliers to improve the quality of the information provided. To the extent that we are able to influence the sourcing decisions of our direct suppliers, we intend to encourage these suppliers to source Conflict Minerals from smelters and refiners that have been determined by RMI to conform to the RMAP or an equivalent third-party audit program. As we enter into new, long-term supply agreements with these direct suppliers, we will continue to incorporate terms that obligate our direct suppliers to provide information in sufficient detail to enable us to comply with our due diligence and disclosure requirements under the Rule. We will also provide our direct suppliers with additional instructions regarding our third-party software tool, and we will continue to work with our direct suppliers to educate them about the Rule and our Conflict Minerals Policy. We also intend to continue to participate in RMI meetings in order to gather best practices and collaborate with industry peers.

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Attachment A

The processing facilities listed in the table below represent the smelters and refiners provided by the Surveyed Suppliers that provided a list of smelters or refiners.* The smelters or refiners may have processed the 3TG necessary for our products, but we do not have sufficient information to determine with certainty that is the case. Additionally, we are unable to conclusively determine the country of origin information for our necessary 3TG, but based on the data gathered from RMI, we believe that the sources may include the countries listed following the table.

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Country of Origin for the Conflict Minerals processed by the facilities listed above may include:

Andorra, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Czechia, Estonia, France, Germany, Ghana, India, Indonesia, Italy, Japan, Kazakhstan, Korea (Republic Of), Lithuania, Malaysia, Mexico, Myanmar, Netherlands, New Zealand, Norway, Peru, Philippines, Poland, Portugal, Rwanda, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan (Province Of China), Thailand, Turkey, United Arab Emirates, United States Of America, Uzbekistan, Vietnam

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