Form SD TERADATA CORP /DE/

Company Overview

Products Overview

Supply Chain Overview

Conflict Minerals Analysis

Teradata’s Due Diligence Framework

Establishment of Robust Company Ethics and Compliance Management Systems

Teradata has adopted and maintains a Conflict Minerals Policy (the “Policy”), which is publicly available on its website at www.teradata.com (the “website”). The Policy has been communicated to relevant personnel and is available to all Teradata employees via the website. Among other things, the Policy:

authorizes and assigns responsibilities for a Teradata Conflict Minerals Management Committee;

encourages respect and protection of human rights and the environment with its supply chain;

fosters supply chain integrity, ethics, compliance and accountability, including with respect to Conflict Minerals, Conflict Minerals legal duties and Conflict Minerals industry and framework initiatives;

prohibits knowing inclusion of DRC Region Conflict Minerals in its hardware products;

establishes an escalation and corrective actions process in the event of actual or suspected Conflict Minerals compliance risks, exceptions or violations;

establishes an expectation or requirement with its supply chain that the 3TG content in its hardware products must become conflict-free as and when required by law and SEC guidance;

adopted procedures and expectations that Teradata’s Conflict Minerals initiatives and status are reviewed with Teradata senior management and the Audit Committee of Teradata’s Board of Directors; and

adopted procedures and expectations that the Policy is reviewed and updated at least annually and on an intermediate as-required basis to assure that any new legal developments are accounted for on a timely basis.

Teradata has prepared this Report for 2021 and it will be posted on its website.

Teradata supports the principles of the Responsible Business Alliance (formerly the Electronic Industry Citizenship Coalition) (“RBA”) Code of Conduct. The RBA Code of Conduct includes provisions regarding responsible sourcing of minerals, including with respect to 3TG and DRC Region Conflict Minerals.

Teradata (i) has declared its support for and adopted the principles of the United Nations (“UN”) Global Compact, (ii) is a signatory to the UN Global Compact, (iii) is a financial supporter of the UN Global Compact, and (iv) submitted an UN Global Compact Communications on Progress.

Teradata has adopted a company Code of Conduct, which is publicly available on its website. The Code of Conduct includes provisions related to respecting and protecting human rights, including Teradata’s adoption of the principles of the UN Global Compact and compliance regarding, among other areas, Conflict Minerals. Teradata’s public website also declares support for the principles of the RBA.

Teradata has adopted a Teradata Supplier Code of Conduct and Teradata Business Partner Code of Conduct, both of which are publicly available on its website. Each of these includes Conflict Minerals compliance provisions and the principles of the RBA Code of Conduct and UN Global Compact.

Teradata maintains the Teradata Ethics Helpline (i.e., a whistleblower hotline) through which anyone may report Teradata-related actual or suspected violations of policies or laws or raise Teradata-related issues for review and guidance and may do so on an anonymous and confidential basis. Anyone may report and seek guidance regarding Teradata-related matters that pertain to Conflict Minerals through Teradata’s Ethics Helpline.

Teradata has maintained an Ethics and Compliance program and process for investigating, taking corrective actions and reporting matters related to ethics, compliance, actual or suspected violations of policies and actual or suspected violations of law, including matters involving policies or laws that pertain to Conflict Minerals. The linkage between the Conflict Minerals compliance processes and broader Ethics and Compliance processes is described in the Policy.

Teradata publishes an annual Environmental, Social and Governance (“ESG”) Report, which is publicly available on its website. The ESG Report includes reference to the Policy and program, supply chain integrity initiatives, and initiatives to support and help protect human rights.

Teradata has, by reference to/incorporation in various training materials (including as part of its annual Code of Conduct training), included Conflict Minerals, human rights, and third-party due-diligence awareness and compliance.

Teradata has included requirements that Flex and its suppliers comply with the Policy in certain relevant specifications and vendor regulatory compliance criteria for Teradata hardware products.

Teradata has included compliance with Conflict Minerals requirements provisions in certain relevant contracts with its Contract-Manufacturer and/or key suppliers.

Supply Chain Risk Identification and Assessment

Teradata has communicated with the Contract-Manufacturer regarding Conflict Minerals surveying, tracking, reporting, expectations and upstream key supplier communications with respect to direct suppliers of components for hardware that contain any 3TG.

Teradata has reviewed its Contract-Manufacturer’s Conflict Minerals Reports filed with the SEC.

Teradata has spot-checked relevant websites, statements, Conflict Minerals Policies and/or Conflict Minerals Reports of certain key suppliers regarding their stated Conflict Minerals initiatives, processes, reasonable country of origin inquiry processes and due diligence processes.

Teradata has received and reviewed a RMI Conflict Minerals Reporting Template form for 2021 completed by the Contract-Manufacturer with respect to Teradata hardware products.

Teradata designed its Conflict Minerals program and actions and determinations related to the Conflict Minerals program described in this Report to materially meet RCOI (defined below) requirements of the Rule and OECD Guidance.

Teradata has, through its participation in and support of the RMI, helped make Conflict Minerals training, guidance and resources available to its employees, suppliers and others.

Reasonable Country of Origin Inquiry (“RCOI”)

66 key suppliers of components for Teradata hardware products manufactured during 2021 were surveyed regarding Conflict Minerals using the RMI framework. Of the 66 key suppliers, it was determined that 20 solely provide components or materials that do not contain any 3TG or are outside the scope of the Rule, such as components or materials that are solely plastic, non-metallic fasteners, aluminum, packaging, test media, documentation, ink or a label.

As of April 12, 2022, 12 of the remaining 46 key suppliers surveyed provided responses for 2021 that were deemed complete, 27 were open (e.g., awaiting responses or supplemental responses), 5 were rejected or repeated (e.g., identity of smelter or refiner not provided or deemed to be invalid), and 2 had some other identified problem (e.g., response in a form other than through the CMRT).

each of the Conflict Minerals is contained in Teradata hardware products;

each of the Conflict Minerals is necessary to the production of Teradata hardware products;

the Conflict Minerals in Teradata hardware products do not originate exclusively from recycled or scrap sources;

Conflict Minerals data/information has not yet been received from 100% of suppliers of 3TG used in Teradata hardware products;

all smelters of the Conflict Minerals in Teradata hardware products have not yet been identified for all of the Conflict Minerals;

all applicable smelter information received by Teradata Contract-Manufacturer has been reported in its CMRT declaration that was provided to Teradata; and

the Contract-Manufacturer has a policy in place that addresses Conflict Minerals sourcing, which is publicly available at www.flex.com and states that Flex:

expects that its suppliers source from socially responsible suppliers;

expects that its suppliers have policies and procedures in place to ensure that products and parts supplied to Flex are DRC conflict-free;

expects that its suppliers provide all necessary due diligence information to confirm that all Conflict Minerals supplied to Flex are DRC conflict-free;

expects that its suppliers pass these requirements on to their supply chain; and

states that compliance with these requirements are taken into consideration when selecting and retaining suppliers.

Conformant: 237

Active: 18

In Communication: 12

Outreach Required: 45

Non Conformant/Not Applicable: 24

Communication Suspended-Not Interested: 6

RMI Due Diligence Reviews/Unable to Proceed: 4

Teradata’s Responses to Identified Risks

Continued Risk Mitigation

All smelters/refiners identified by the Contract-Manufacturer that reportedly source, or reportedly might source, directly or indirectly, 3TG from mines or sources in the Covered Countries were on the RMAP conformant list for 2021.

Although the total number of identified smelters/refiners/sources for the Conflict Minerals increased from 325 in 2020 to 346 in 2021, the number of key suppliers decreased from 84 in 2020 to 66 in 2021.

Teradata generally maintained the percentage of total key suppliers that have historically been surveyed:

2021: 56%

2020: 62%

2019: 70%

2018: 64%

2017: 63%

Teradata continued to include compliance with the Policy, the principles of the RBA Code of Conduct and the principles of the UN Global Compact in our Code of Conduct, Supplier Code of Conduct and Business Partner Code of Conduct during 2021 and included information about each of those items in the annual all-employee ethics and compliance training for 2021 and/or other all-employee training materials.

Teradata continued to report relevant information regarding Conflict Mineral requirements, compliance and status to its senior management and the Audit Committee of our Board of Directors.

Teradata continued to monitor legal developments and guidance related to Conflict Minerals compliance (including with respect to the Conflicts Minerals Rule and related SEC interpretive guidance) and considered and applied relevant developments to our Conflict Minerals program.

Teradata maintains and supplements information and materials on its internal employee online resource and collaboration site regarding Conflict Minerals.

Teradata maintains inquiries regarding Conflict Minerals as part of its compliance due diligence questionnaire template for merger-and-acquisition candidates.

Teradata continues to be a member of the RMI and financially supports the RMI through paying the RMI membership fees.

As an RMI member, Teradata has direct access to RMI participant data, enabling it to take measures to verify related data reported by the Contract Manufacturer and to review relevant data to identify red flags and other indicia of risks, rather than relying solely on the Contract-Manufacturer to identify and report such risks.