Form SD ERICSSON LM TELEPHONE

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form SD

SPECIALIZED DISCLOSURE REPORT

TELEFONAKTIEBOLAGET LM ERICSSON

(Exact Name of Registrant as Specified in Its Charter)

LM ERICSSON TELEPHONE COMPANY

(Translation of Registrant’s Name Into English)

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 and 1.02 - Conflict Minerals Disclosure and Report, Exhibit

A copy of Telefonaktiebolaget LM Ericsson’s Conflict Minerals Report for the reporting period January 1, 2021 to December 31, 2021 is provided as Exhibit 1.01 hereto and is publicly available at http://www.ericsson.com/thecompany/investors/financial-reports.

Section 2 - Exhibits

Item 2.01 - Exhibits

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

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.

EXHIBIT INDEX

Exhibit 1.01

Conflict Minerals Report

Telefonaktiebolaget LM Ericsson

Conflict Minerals Report for the year ended December 31, 2021

This Conflict Minerals Report of Telefonaktiebolaget LM Ericsson for the year ended December 31, 2021 is provided pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the U.S. Securities and Exchange Commission (the “SEC”) to implement disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. As permitted by the Rule and the SEC, this report has not been subject to an independent private sector audit.

Ericsson is a global provider of hardware, software, and services – especially in networks, digital services, managed services and new businesses – to the telecom industry and other sectors to enable the full value of connectivity. This report has been prepared by the management of Telefonaktiebolaget LM Ericsson (herein referred to as “Ericsson”, the “Company”, “we”, “us”, or “our”). This report does not include the activities of entities that are not required to be consolidated in our financial statements. In accordance with the Rule, this report is available on our website: http://www.ericsson.com/thecompany/investors/financial-reports.

Ericsson’s hardware largely consists of electronics. For manufacturing, the Company purchases customized and standardized components and services from both global, regional, and local suppliers. The production of electronic modules and sub-assemblies is mostly outsourced to manufacturing services companies. Ericsson is focusing internal manufacturing on new product introductions and new technologies.

There are often several tiers of suppliers between Ericsson and any smelters or refiners of minerals, even more when tracing a mineral all the way back to the mines. As a result, the Company does not normally have a direct purchasing relationship with mines, smelters, or refiners.

In 2020, Ericsson’s Conflict Mineral program was extended to also cover cobalt. Ericsson gathers materials information from our suppliers. Through this, we know that many of the components used in our products contain small amounts of tin, tungsten, tantalum, gold (3TG) and cobalt that are necessary to the functionality of those products.

As part of Ericsson’s commitment to responsible sourcing and human rights it is our goal that the 3TG and cobalt in our products should not, directly or indirectly, finance or benefit armed groups in the Democratic Republic of Congo (the “DRC”) or adjoining countries. At the same time, we aim to continue supporting responsible mineral sourcing in the region. Ericsson’s efforts with

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respect to 3TG and cobalt are aligned with the Responsible Minerals Initiative (RMI) and our aim is to improve traceability in our supply chain. Ericsson does not prohibit sourcing of materials from the DRC or adjoining countries or avoid using 3TG or cobalt since Ericsson believes that such a ban could result in negative consequences for responsible mining companies, their workers and the most vulnerable groups in a society. The Company has a Conflict Minerals Program to fulfill compliance with the Rule, including performing the Reasonable Country of Origin Inquiry and reporting on 3TG and cobalt, which in 2020 and 2021 also covered cobalt.

Ericsson relies on its first-tier suppliers to provide information on the origin of 3TG and cobalt contained in components and parts included in Ericsson’s products. This includes sources of 3TG and cobalt that are supplied to them from sub-suppliers. Ericsson’s first-tier suppliers are required to comply with the requirements in Ericsson’s Code of Conduct for Business Partners which requires due diligence to be exercised with respect to the sourcing and extraction of raw materials, including 3TG and cobalt.

Ericsson´s suppliers’ due diligence shall be consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”). Furthermore, suppliers are required to comply with the requirements of the Ericsson Lists of Banned and Restricted Substances and the Ericsson Code of Conduct for Business Partners which include an obligation to have appropriate due diligence processes in place to identify the source and chain of custody of 3TG. Our first-tier suppliers are similarly to Ericsson reliant upon information provided by their suppliers.

The identification of first-tier suppliers of Ericsson that are in scope under the Rule involves different parts of Ericsson’s global organization. The sourcing organization has the important role of leading and coordinating the work. Suppliers identified to be in scope are first-tier suppliers of Ericsson supplying (i) products containing 3TG or cobalt that Ericsson contracts to manufacture, (ii) materials, parts, components and other products, containing 3TG or cobalt, that are incorporated into or included in a product manufactured by Ericsson, or (iii) materials used in the production of Ericsson’s products where 3TG or cobalt becomes part of the final product. Suppliers of products that Ericsson does not contract to manufacture (i.e. products purchased “off-the shelf”) and not included in or incorporated into an Ericsson product have been considered out of scope for purposes of the Rule. In our annual inquiry we survey first-tier suppliers identified to be in scope and analyze and follow up on the responses as we deem appropriate.

Ericsson believes that industry cooperation is one of the best ways to address issues related to 3TG and cobalt in an efficient and transparent way. We typically do not have a direct relationship with 3TG and cobalt smelters and refiners, and we do not perform direct audits of these entities within our supply chain. In accordance with the OECD Guidance, we support the RMI’s audit of smelters’ and refiners’ due diligence activities mainly via the Responsible Minerals Assurance Process (RMAP).

Ericsson has a process in place for the purpose of exercising due diligence in the supply chain. The design of the due diligence processes conforms to the

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OECD Guidance as it relates to “downstream” purchasers of products and components. The due diligence processes have been described below under sub-headings corresponding to the five-step framework of the OECD Guidance. Ericsson’s Conflict Minerals Program focuses on identifying the origin of 3TG and cobalt; however, Ericsson acknowledges that other human rights and environmental risks, such as forced labor and child labor, health and safety, land-related rights and community rights are also salient relating to sourcing of 3TG and cobalt. Ericsson is currently engaged in industry dialogues relating to these issues.

The first step of the OECD Guidance relates to strong management systems. As mentioned above, Ericsson has established a Conflict Minerals Program for reporting on 3TG and cobalt and compliance with the Rule. Controls include, but are not limited to, our Code of Business Ethics and Code of Conduct for Business Partners, which outline required behaviors for all Ericsson’s employees and suppliers (https://www.ericsson.com/en/about
-us/sustainability-and-corporate-responsibility/responsible-business/responsible-sourcing/supplier-requirements-related-to-responsible-sourcing ), and the Ericsson Lists of Banned and Restricted Substances, which include supplier requirements to have diligence processes in place to identify the source and chain of custody of 3TG and are integrated in our template supplier agreements.

With respect to 2021, identification of smelters and refiners in our supply chain was made via the use of due diligence tools created by the RMI, including the Conflict Minerals Reporting Template 6.1 and the Cobalt Reporting Template (the “Templates”). The Templates are standardized supply chain surveys designed to gather information regarding the smelters and refiners that process 3TG and cobalt used in our supply chain. The information from our suppliers, in combination with information from the RMI, helps Ericsson to obtain information on the origin of minerals processed. Data obtained was reviewed, analyzed and retained by Ericsson.

In Ericsson’s Code of Conduct for Business Partners, the topic of responsible sourcing of raw materials is included with clear requirements of suppliers to exercise due diligence in accordance with the OECD Guidance.

Employees are encouraged to report conduct that could violate law, the Code of Business Ethics or the Code of Conduct for Business Partners to their manager, and if due to circumstances, this is not an option, there are other channels that an employee may use, including reporting to the superior of a manager or to Group Functions People or Legal Affairs and Compliance. Such conduct may relate to corruption, fraud, auditing, questionable accounting, deficiencies in the internal controls, personal health and safety, environmental issues, human right matters, workplace respect and fairness or other matters that could constitute a breach of law, or that could harm the sustainability, or the reputation of Ericsson, its employees and shareholders. In addition, Ericsson has a whistle-blower tool, Ericsson Compliance Line, operated by a third party, for the reporting of alleged violations of laws, the Code of Business Ethics or the Code of Conduct for Business Partners. Ericsson Compliance Line is available 24/7, 365 days per year for both Ericsson employees, suppliers and other external parties. Ericsson recognizes that Ericsson Compliance Line might not be the most effective way of capturing issues related to sourcing of 3TG or cobalt and intends to further explore

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other mechanisms that may be more effective, like the Minerals Grievance Platform managed by RMI. Ericsson has published a “Statement on sourcing of minerals from Conflict-Affected and High-Risk Areas” on its website (https://www.ericsson.com/49dadc/assets/local/about-ericsson/sustainability
-and-corporate-responsibility/documents/2020/statement-on-sourcing-of-minerals-from-cahra.pdf) that indicates Ericsson’s position and expected supplier activities in this area.

In the second step of the OECD Guidance, risks are identified and assessed. For downstream companies such as Ericsson, the focus should be on the smelters and refiners. Downstream companies should, with help from their first-tier suppliers, identify smelters and refiners in the supply chain.

In Ericsson’s 2021 Conflict Minerals’ survey, first-tier suppliers identified to be in scope were requested by Ericsson to provide information on 3TG and cobalt in their supply chain through completing and submitting the Conflict Minerals Reporting Template and the Cobalt Reporting Template. Suppliers were provided with the Templates, support material, including the available instructions and training illustrating the use of the tool that is available on RMI’s website. To ensure quality, a high response rate and to minimize risks, the responses were analyzed and followed up as deemed appropriate. Data obtained was saved, reviewed and analyzed by Ericsson. Supplier responses were reviewed against criteria developed to determine which responses required further engagement with our suppliers. In certain circumstances, suppliers were contacted via e-mail or telephone to improve the quality of responses (obtaining missing information, updating templates’ format to the required version) and increase the response rate (reminding supplier to provide information in the templates with extended deadlines).

Under the third step of the OECD Guidance, companies are encouraged to design and implement a strategy to respond to identified risks. Due diligence within Ericsson is an ongoing process. Ericsson publishes additional information about its commitment to responsible sourcing and engagement with its suppliers in the Sustainability and Corporate Responsibility Report, published together with the Annual Report.

We continuously work to improve our due diligence with respect to 3TG and cobalt, mainly focusing on the quality of data from suppliers surveyed. This includes communication and collaboration with suppliers for purposes of improving the response rate of surveyed suppliers and improving the reliability and quality of the information provided. As described above, we have a risk-based approach when reviewing and following up supplier responses and generally prioritize to follow up suppliers that are awarded large parts of our business. For example, if a supplier reports non-conformant smelters or refiners, the relevant sourcing responsible manager is notified for purposes of initiating a discussion with the supplier.

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The fourth step of the OECD Guidance focuses on audits of smelters’/refiners’ due diligence practices. Through our Responsible Business Alliance (RBA) membership we are also members of the RMI, supporting the responsible minerals assurance process (“RMAP”) as well as the development and implementation of due diligence practices and tools such as the Templates. Due to the structure of our supply chain, there are generally many tiers of suppliers between Ericsson and the smelters and refiners in the supply chain. Therefore, we have, as mentioned in section 2.2, not performed our own audits of smelters or refiners.

The fifth step of the OECD Guidance encourages reporting on supply chain due diligence. We have a public statement on sourcing of minerals from Conflict Affected and High Risk Areas including 3TG and cobalt; which is available on our website: https://www.ericsson.com/49dadc/assets
/local/about-ericsson/sustainability-and-corporate-responsibility/documents/2020/statement-on-sourcing-of-minerals-from-cahra.pdf

In accordance with the Rule, we make our Conflict Minerals Report available on our website:

http://www.ericsson.com/thecompany/investors/financial-reports.

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4. 2021 due diligence result

For the calendar year 2021, our inquiries were made on supplier level and most supplier responses received also provided data at a company or divisional level, with only a few exceptions providing product-level information. Our inquiries include responses where we believe that the names of smelters or refiners may have been misidentified as smelters and refiners or smelters or refiners that we believe are not operational. Such names have not been listed among identified smelters and refiners.

The response rate among suppliers surveyed in 2021 was 49,8 % which is significantly lower as compared to prior years.¹ We believe that this response rate is due, in part, to a number of new suppliers brought on board as a result of recent acquisitions completed by Ericsson. Several such new suppliers had not previously responded to questions on Conflict Minerals. Ericsson plans to continue to engage with new suppliers that did not respond with such information to increase response rates. Among the supplier responses, we identified 393 smelters as potential sources of 3TG and cobalt that were reported to be in the supply chain during the 2021 calendar year. The following table presents, by mineral, the number of identified smelters or refiners verified as conflict-free by the RMAP or mutually recognized audit systems. In case a supplier has identified non-conformant smelters in their supply chain Ericsson engages with such suppliers for them to phase-out non-conformant smelters and refiners or to encourage smelters to participate in RMAP.

Table 1. RMAP eligible smelters and refiners identified by Ericsson via inquiries to our suppliers in 2021

Note: The RMAP audit status of smelters and refiners are subject to change and the above represents information available from RMI on May 16th, 2022.

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We are unable to validate that any of the identified smelters or refiners are actually in our supply chain. However, based on the information provided by Ericsson’s suppliers during the 2021 calendar year, Ericsson believes that the facilities that may have been used to process 3TG or cobalt in Ericsson’s products include the smelters and refiners listed in Annex 1 below. Ericsson does not have enough information to determine with specificity all countries of origin of 3TG or cobalt in our products or whether they are from recycled and scrap sources. Nevertheless, based on data from RMI and RMAP, Ericsson generated a list of Reasonable Country of Origin (RCOI) for 3TG and cobalt based on smelters and refiners identified as shown in Annex 2.

We support the refinement and expansion of the list of participating smelters and have determined that seeking information about 3TG and cobalt smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of 3TG and cobalt in our supply chain.

During 2022, we anticipate continuing to review and evolve our Conflict Minerals due diligence processes with respect to 3TG and cobalt. As part of these efforts, we expect to continue to collaborate with suppliers to maintain a high supplier response rate and improve the reliability and quality of information provided. Our engagement in the RMI program is anticipated to continue.

Certain of the matters discussed in this report, including our due diligence processes with respect to 3TG and cobalt, include forward-looking statements. Readers of this document are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We expressly disclaim a duty to provide updates to these forward-looking statements after the date of this filing to reflect events or changes in circumstances or changes in expectations or the occurrence of anticipated events.

The information included on any websites that appear in this report and other materials referenced to is not incorporated by reference in this report.

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Annex 1

Smelters and refiners identified by Ericsson via inquiries to our suppliers during 2021², note that this list include smelters and refiners not eligible for RMAP.

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25

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Annex 2

Reasonable Country of Origin for 3TG based on the identified smelters and suppliers.³

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