DLB Dolby Laboratories Inc

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

DOLBY LABORATORIES, INC.

(Exact name of registrant as specified in its charter)

Andy Sherman, Executive Vice President, General Counsel and Corporate Secretary

(415) 558-0200

(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

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Dolby Laboratories, Inc. (the “Company”) has filed a Conflict Minerals Report which is attached as Exhibit 1.01 to this Form SD. A copy of this filing and the report are also available on the Company’s website at https://investor.dolby.com/financials/sec-filings/default.aspx .

Section 3 – Exhibits

Item 3.01 Exhibits

Exhibit 1.01 – 2023 Conflict Minerals Report

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.

Date: May 30, 2024

Exhibit 1.01

GLOSSARY OF TERMS

The following table summarizes certain terms and abbreviations that may be used within the text of this report:

Dolby Laboratories, Inc.

Conflict Minerals Report

For Calendar Year Ended December 31, 2023

Introduction

This Conflict Minerals Report (this “Report”) of Dolby Laboratories, Inc. (“Dolby” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2023, to December 31, 2023. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals referred to as “Conflict Minerals” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their metallic derivatives which include tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola.

Dolby has determined that certain Conflict Minerals are necessary to the functionality or production of products manufactured or contracted to be manufactured by us during calendar year 2023. These products are referred to in this Report as “Covered Products.” Dolby has conducted a RCOI reasonably designed to determine if Conflict Minerals originated in the Covered Countries. Based on our RCOI, Dolby believes that certain of the Conflict Minerals used in our products may have originated in the Covered Countries. Because of this finding, we performed additional due diligence on the source and chain of custody of these Conflict Minerals based on 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: Third Edition (“Framework”), to determine if the Conflict Minerals that may have originated in the Covered Countries benefited armed groups. As such, we believe our process was reasonably designed and performed in good faith. After performing the RCOI and additional due diligence in conformity with the Framework, we were unable to comprehensively determine the origin of all Conflict Minerals used in our products, the facilities used to process them, their country of origin, and their mine or location of origin. We note, however, that we did not learn of any facts that led us to conclude that any of our Covered Products include Conflict Minerals that originated in a Covered Country and financed or benefitted an armed group.

The Covered Products are hardware products, and a significant majority of Dolby’s revenues are associated with licensing and services as opposed to physical hardware products. As reported in Dolby’s Annual Report on Form 10-K for the fiscal year ended September 29, 2023, Dolby’s Products and Services revenue for the fiscal year period comprised approximately 8% of reported revenues of $1.3 billion. Most of Dolby’s hardware products are manufactured by contract manufacturers. These factors result in a relatively small supply base as indicated in the RCOI summary. Descriptions of our covered products are provided below.

Descriptions of Covered Products

RCOI

Our RCOI consisted of requesting a completed RMI CMRT from our contract manufacturers and suppliers of materials/products/components received by Dolby in 2023 for purchases made through Dolby’s purchase order system for use in applicable Dolby products. Responses were reviewed for completeness and consistency, and we routinely followed up with our suppliers for corrections and clarifications as needed. We submitted this questionnaire to 54 suppliers and manufacturers of components and products purchased directly by Dolby. As of May 16, 2024, we did not receive complete responses to the questionnaire from 8 of these suppliers (14.8%) despite repeated follow-up attempts with these nonresponsive suppliers. We were informed that many of Dolby’s suppliers have not received responses from all their upstream suppliers. Of the responses received, 24 suppliers indicated that they source Conflict Minerals from the Covered Countries while 2 others indicated they do not know whether they source Conflict Minerals from the Covered Countries. Based on these responses, we conducted additional due diligence on the smelters and refiners identified.

Due Diligence Framework

Dolby’s due diligence program was designed to conform in all material respects with the OECD Framework.

Due Diligence Measures Taken

The due diligence measures taken include, but are not limited to, those described as follows:

Dolby has assembled a conflict minerals project team comprised of representatives from engineering, legal, and procurement who meet periodically and provide oversight of our Conflict Minerals program. Dolby adopted a conflict minerals policy in 2013 and it was updated in 2018. The policy, which is available at

https://investor.dolby.com/governance/Governance-Overview/default.aspx#governance-documents , describes our commitment to avoiding the use of Conflict Minerals that finance or benefit armed groups. Our policy statement does not exclude the use of responsibly sourced materials from the Covered Countries. Dolby has communicated this policy to our suppliers. We encourage suppliers to seek conflict-free sources of Conflict Minerals that are validated as conflict-free by recognized responsible sourcing protocols such as RMAP and its cross-recognized programs (e.g., RJC and LBMA). If we become aware of a supplier who does not meet the expectations specified in our conflict minerals policy, including the provision of a CMRT, our director of procurement may seek alternative sources of supply for our products or components. In support of Dolby’s Conflict Minerals program, we participate in industry groups on the topic of Conflict Minerals and other responsible sourcing matters. Dolby is an active member of RMI, and we utilize data from RMI for smelter conformance status and reasonable country of origin information.

Findings and Conclusions

Through our RCOI, certain suppliers reported the use of smelters or refiners with an RMI audit status of “Non-Conformant” or “Communication Suspended - Not Interested”. We cannot be certain these smelters or refiners are present in our supply chain due to uncertainty in our supplier survey results. We have asked these suppliers to request that these smelters or refiners pursue conformance to a recognized responsible sourcing protocol or be removed from our supply chain. Where contact information was available, we have communicated this request directly to these smelters or refiners. Should these smelters or refiners decline to pursue conformance to a recognized responsible sourcing protocol and our supplier refuses to remove these smelters from our supply chain, we will evaluate our relationship with that supplier and explore alternatives.

Dolby did not receive responses from certain of our suppliers as noted above. We made repeated requests that these suppliers provide a CMRT. A list of these nonresponsive suppliers was provided to our director of procurement who is determining if Dolby will continue to purchase components from these non-responsive suppliers or if alternative suppliers can be identified and utilized in the future. We continue to include provisions in new supply agreements relating to the gathering of Conflict Minerals information, the provision of a CMRT, and the sourcing of Conflict Free materials to encourage greater cooperation by the companies in our supply chain.

As we have not received conclusive data from all our direct suppliers, we are unable to make a definitive determination about all sources of the tin, tungsten, tantalum or gold in our products and cannot determine whether our supply chain is “conflict-free”. However, we received no information from our direct suppliers who did provide a CMRT response to indicate that the tin, tantalum, tungsten or gold directly or indirectly financed or benefitted armed groups in the DRC or adjoining countries. The table in Annex 1 lists the names and countries of the smelters or refiners reported by our suppliers. Annex 2 lists the countries of origin identified as the sources of those smelters and refiners.

We believe that requesting our contract manufacturers and component/product/material suppliers to complete the RMI CMRT and encouraging these upstream suppliers to source materials from conflict-free sources such as those validated by the RMAP, communicating our conflicts minerals policy, reviewing the smelter or refiner information provided, and reviewing the country of origin of source materials of those smelters or refiners represents a reasonable effort to determine the mines or location of origin of the Conflict Minerals in our supply chain. Moving forward, the Company will continue to implement commercially reasonable procedures to prevent Conflict Minerals that finance or benefit armed groups from entering our supply chain.

Independent Private Sector Audit (IPSA)

Not required for reporting year 2023.

Risk Factors

The statements above are based on the RCOI process and due diligence performed in good faith by the Company. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect Dolby’s Conflict Minerals status. These factors include, but are not limited to, gaps in supplier data, gaps in smelter or refiner data, errors or omissions by suppliers, errors or omissions by smelters or refiners, the definition of a smelter or refiner not being finalized at the end of the reporting period, all instances of Conflict Minerals necessary to the functionality or manufacturing of Dolby’s products possibly not yet having been identified, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, errors in public data, inaccurate or incomplete information due to disruptions caused by military conflicts and natural disasters, language barriers and translation, supplier and smelter or refiner unfamiliarity with the protocol, oversights or errors in independent third party audits conducted by the RMAP, LBMA, or RJC, Covered Countries sourced materials being declared secondary materials, companies going out of business, auditing programs being not equally advanced for all industry segments and metals, and smuggling of Conflict Minerals from the Covered Countries to countries beyond the Covered Countries.

Forward-Looking Statements

Certain statements in this Report, including, but not limited to, statements relating to Dolby’s future supply management practices, policies and plans for procurement of materials, and efforts to improve supply chain transparency, are “forward-looking statements” that are subject to risks and uncertainties. In some cases, you can identify forward-looking statements because they contain words such as “believe,” “continue,” “could,” “expect,” “may,” “will,” “would,” “should,” “plan,” “anticipate,” or “intend” or the negative of these words or other similar terms or expressions. Such forward-looking statements are based on management’s reasonable and current assumptions and expectations, but such statements inherently involve substantial risks and uncertainties. Actual results may differ materially from those discussed in these forward-looking statements due to a number of factors. The following important factors, without limitation, could cause actual results to differ materially from those in the forward-looking statements: the ability of Dolby and its suppliers to obtain reliable information as to the source of purchased production materials; whether upstream suppliers responsibly source materials from conflict-free sources; political and regulatory developments; and other risks detailed under the section captioned “Risk Factors” in this Report. Dolby disclaims any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.

Annex 1

The table below shows the smelters and refiners reported by our contract manufacturers and component/product/materials suppliers in their CMRTs as of May 16, 2024, covering materials provided to Dolby during calendar year 2023:

Annex 2

The table below provides a list of countries identified as potential sources of minerals for the smelters or refiners described in Annex 1:

Gold

Tantalum

Tin

Tungsten