Form SD ZEBRA TECHNOLOGIES CORP

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

Zebra Technologies Corporation

(Exact name of the registrant as specified in its charter)

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:

Introduction

Effective for the year ending December 31, 2021, Zebra Technologies Corporation (“Zebra”) must disclose whether any conflict minerals necessary to the functionality or production of a product manufactured by Zebra (or contracted by Zebra to be manufactured) originated in the Democratic Republic of the Congo (“DRC”) or a country adjoining the DRC [Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia, together the “Covered Countries”], or whether the conflict minerals are from recycled or scrap sources. The disclosure requirement arose from Congress’s determination that trade in conflict minerals in a DRC country is financing conflict in those areas, contributing to a humanitarian crisis.

The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the DRC or Covered Countries (“Conflict Minerals”).

Section 1 – Conflict Minerals Disclosures

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (‘Rule 13p-1”), Zebra Technologies Corporation (“Zebra”) has filed this Specialized Disclosure Form (“Form SD”) and the associated Exhibit 1.01 Conflict Minerals Report for the reporting period January 1, 2021, to December 31, 2021 and is publicly available on Zebra’s website under “Company Information”/“Compliance”/“Products and Materials Compliance” found on Zebra’s website at https://www.zebra.com/us/en/about-zebra/company-information/compliance/products-and-materials-compliance.html.

After conducting a reasonable country of origin inquiry and our supply chain due diligence inquiry, Zebra has been unable to determine that certain of its conflict minerals did not originate in the Covered Countries or come from recycled or scrap sources, or that such conflict minerals did not directly or indirectly finance or benefit armed groups in the Covered Countries.

Item 1.02 – Exhibits

The Zebra Technologies Corporation Conflict Minerals Report is attached to this report as Exhibit 1.01.

Section 2 – Exhibits

Item 2.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report of Zebra Technologies Corporation for the period January 1, 2021, to December 31, 2021, as required by Items 1.01 and 1.02 of this Form SD.

* * * * *

2

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 undersigned hereunto duly authorized.

3

EXHIBIT INDEX

4

Exhibit 1.01

CONFLICT MINERALS REPORT OF

ZEBRA TECHNOLOGIES CORPORATION

FOR THE REPORTING PERIOD FROM

JANUARY 1 TO DECEMBER 31, 2021

I.    Introduction

In accordance in all material respects with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”), Zebra undertook efforts to determine whether the necessary Conflict Minerals in our products were or were not “DRC conflict free.” This is the Conflict Minerals Report of Zebra Technologies Corporation (“Zebra,” the “Company,” “our” or “we”) for calendar year 2021 (excepting Conflict Minerals¹ that, prior to January 31, 2021, were located outside of the supply chain) in accordance in all material respects with Rule 13p-1 (the “Report”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Specialized Disclosure Form (“Form SD”) and the reader is referred to those sources, as well as, to Release No. 34-67716 (August 22, 2012) of the Act (the “Adopting Release”) for such definitions.

The statements below are based on the due diligence activities performed to date and in good faith by Zebra and are based on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters in responding to information requests, incomplete information from industry or other third-party sources, and continuing guidance regarding the SEC final rules.

II.     Zebra’s Manufacturing and Outsourcing Description

Zebra is a global leader providing Enterprise Asset Intelligence (“EAI”) solutions in the Automatic Identification and Data Capture (“AIDC”) industry. The AIDC market consists of mobile computing, data capture, radio frequency identification devices (“RFID”), barcode printing, and other workflow automation products and services. The Company’s solutions are proven to help our customers and end-users digitize and automate their workflows to achieve their critical business objectives, including improved productivity and operational efficiency, optimized regulatory compliance, and better customer experiences.

We design, manufacture, and sell a broad range of AIDC products, including: mobile computers, barcode scanners and imagers, RFID readers, specialty printers for barcode labeling and personal identification, real-time location systems (“RTLS”), related accessories and supplies, such as labels and other consumables, and related software applications. We also provide a full range of services, including maintenance, technical support, repair, managed and professional services, as well as cloud-based software subscriptions and robotics automation solutions. End-users of our products, solutions and services include those in the retail and e-commerce, manufacturing, transportation and logistics, healthcare, public sector, and other industries.

1

Final assembly of our hardware products is performed by third parties, including electronics manufacturing services companies (“EMSs”) and joint design manufacturers (“JDMs”). Our products are currently produced in facilities primarily located in the Asia-Pacific region, including China, Taiwan, Vietnam, and Malaysia, as well as Mexico and Brazil. The EMSs and JDMs produce our products to our design specifications. We maintain control over portions of the supply chain, including supplier selection and price negotiations for key components. The manufacturers generally purchase all the components and subassemblies used in the production of our products. Our products are shipped to regional distribution centers, operated by third party logistics providers or the Company. A portion of products are reconfigured at the distribution centers through firmware downloads, packaging, and customer specific customization before they are shipped to customers. In addition, certain products are manufactured in accordance with procurement regulations and various international trade agreements and remain eligible for sale to the U.S. government.

Production facilities for our supplies products are located in the U.S. and Western Europe. We also supplement our in-house supplies production capabilities with third-party manufacturers, principally located in Asia-Pacific.

III. Zebra’s Product Description

Acquisitions

Antuit: On October 7, 2021, the Company acquired Antuit Holdings Pte. Ltd. (“Antuit”). Antuit is a provider of demand-sensing and pricing optimization software solutions for retail and consumer products companies. Through this acquisition, the Company expands its portfolio of software solution offerings to customers in these industries by combining Antuit’s platform with its existing software solutions and EVM products.

Fetch: On August 9, 2021, the Company acquired Fetch Robotics, Inc. (“Fetch”). Fetch is a provider of autonomous mobile robot solutions for customers who operate in the manufacturing, distribution, and fulfillment industries, enabling customers to optimize workflows through robotic automation. Through this acquisition, the Company intends to expand its automation solution offerings within these industries.

Adaptive Vision: On May 17, 2021, the Company acquired Adaptive Vision Sp. z o.o. (“Adaptive Vision”). Adaptive Vision is a provider of graphical machine vision software with applications in the manufacturing industry, as well as a provider of libraries and other offerings for machine vision developers.

Reflexis: On September 1, 2020, the Company acquired Reflexis Systems, Inc. (“Reflexis”). Reflexis is a provider of task and workforce management, execution, and communication software solutions for customers in the retail, food service, hospitality, and banking industries. Through this acquisition, the Company intends to enhance its solution offerings to customers in those industries by combining Reflexis’ platform with its existing software solutions and EVM products.

Cortexica: On November 5, 2019, the Company acquired Cortexica Vision Systems Limited (“Cortexica”). Cortexica is a provider of computer vision-based artificial intelligence solutions primarily serving the retail industry.

2

Profitect: On May 31, 2019, the Company acquired Profitect, Inc. (“Profitect”). Profitect is a provider of prescriptive analytics software primarily serving the retail industry. Through this acquisition, the Company enhanced its existing software solutions within the retail industry by combining Profitect’s platform with its existing software solutions and EVM products.

Temptime: On February 21, 2019, the Company acquired Temptime Corporation (“Temptime”). Temptime is a developer and manufacturer of temperature-monitoring labels and devices. Through this acquisition, the Company expanded its product offerings within the healthcare industry, with possible future applications in other industries involving temperature-sensitive products.

Xplore: On August 14, 2018, the Company acquired all outstanding equity interests of Xplore Technologies Corporation (“Xplore”). The Xplore business designs, integrates, markets and sells rugged tablets that are primarily used by industrial, government, and field service organizations. The acquisition of Xplore is intended to expand the Company’s portfolio of mobile computing devices to serve a wider range of customers.

Enterprise Business: In October of 2014, Zebra acquired the Enterprise business (“Enterprise”) from Motorola Solutions, Inc. (“MSI”), excluding its iDEN, or Integrated Digital Enhanced Network Business. The Enterprise products include rugged and enterprise-grade mobile computers, barcode scanners and RFID readers, WLAN solutions, and accessories, software and services that are associated with these products.

Operations

Our operations consist of two reportable segments that provide complementary offerings to our customers: Asset Intelligence & Tracking (“AIT”), which includes barcode and card printing, supplies, services, and location solutions; and Enterprise Visibility & Mobility (“EVM”), which includes mobile computing, data capture, RFID, fixed industrial scanning and machine vision, services and workflow optimization solutions.

Asset Intelligence & Tracking

Barcode and Card Printing: We design, manufacture, and sell printers, which produce high-quality labels, wristbands, tickets, receipts, and plastic cards on demand. Our customers use our printers in a wide range of applications, including routing and tracking, patient safety, transaction processing, personal identification, and product authentication. These applications require high levels of data accuracy, speed, and reliability. They also include specialty printing for receipts and tickets for improved customer service and productivity gains.

Our printers use thermal printing technology, which creates images by heating certain pixels of an electrical printhead to selectively image a ribbon or heat-sensitive substrate. Our printers integrate company-designed mechanisms, electrical systems, and firmware that supports serial, parallel, Ethernet, USB, Bluetooth, or 802.11 wireless communications with appropriate security protocols. Enclosures of metal or high-impact plastic help ensure durability of our printers.

We also provide dye-sublimination thermal card printers that produce high quality images and are used for secure, reliable personal identification (e.g. state identification cards, drivers’ licenses, and healthcare identification cards), access control (e.g. employee or student building access), and financial transactions (e.g. credit, debit and ATM cards). Additionally, we provide RFID printers that encode data into passive RFID transponders embedded in a label or card. We offer a wide range of accessories and options for our printers, including vehicle mounts and battery chargers.

3

Supplies: We produce and sell stock and customized thermal labels, receipts, ribbons, plastic cards, and RFID tags suitable for use with our printers, as well as wristbands for use in laser printers. We support our printing products, resellers, and end-users with an extensive line of superior quality, high-performance supplies optimized to a particular end-user’s needs, such as chemical or abrasion resistance, extreme temperature environments, exceptional image quality, or long life. We promote the use of supplies with our printing equipment. Our supplies business also includes temperature-monitoring labels primarily used in vaccine distribution, which incorporate chemical indicators designed to change color upon exceeding predefined time and/or temperature thresholds.

Services: We provide a full range of maintenance, technical support, and repair services. We also provide managed and professional services, including those which help customers manage their devices and related software applications.

Location Solutions: The Company offers a range of RTLS and services that generate precise, on-demand information about the physical location and status of high-valued assets, equipment, and people. These solutions incorporate active and passive RFID technologies, beacons, and other tracking technologies to enable users to locate, track, manage, and optimize the utilization of enterprise assets and personnel. We provide substantially all elements of the location solution, including tags, sensors, exciters, middleware software, and application software.

Enterprise Visibility & Mobility

Mobile Computing: We design, manufacture, and sell rugged and enterprise-grade mobile computing products and accessories in a variety of specialized form factors and designs to meet a wide array of enterprise applications. Purpose-built devices ensure reliable operations for targeted use cases, surviving years of rough handling and harsh environments. Industrial applications include inventory management in warehouses and distribution centers; field mobility applications include field service, post and parcel, and direct store delivery; and retail and customer facing applications include e-commerce, omnichannel, mobile point of sale, inventory look-up, staff collaboration, and analytics. Our mobile computing products primarily incorporate the Android^™ operating system and support local-area and wide-area voice and data communications. Our products are also offered with software tools and services that enable secure data transmission while also supporting application development, device configuration, and field support to facilitate seamless, rapid deployment and maximum customer return on investment. Our products often incorporate barcode scanning, global position system and RFID features, and other sensory capabilities.

Data Capture, RFID, Fixed Industrial Scanning, and Machine Vision: We design, manufacture, and sell barcode scanners, RFID readers, industrial machine vision cameras, and fixed industrial scanners. Our portfolio of scanners includes laser scanning and imager products in a variety of form factors, including fixed, handheld, and embedded original equipment manufacturer (“OEM”) modules. Our scanners incorporate a range of technologies including area imagers, linear imagers, and lasers, as well as read linear and two-dimensional barcodes. They are used in a broad range of applications, ranging from supermarket checkouts to industrial warehouse optimization to patient management in hospitals. The design of these products reflects the diverse needs of these markets, with different ergonomics, multiple communication protocols, and varying levels of ruggedness. Our RFID products include fixed readers, RFID enabled mobile computers, and RFID sleds that utilize passive ultra-high frequency to provide high-speed, non-line of sight data capture from hundreds or thousands of RFID tags in near real-time. Using the Electronic Product Code (“EPC”) standard, end-users across multiple industries use our RFID technology to track high-value assets, monitor shipments, and drive increased retail sales through improved inventory accuracy. We also offer mobile computers that support high frequency near-field communications and low frequency radio technologies. In 2021, we introduced fixed industrial scanning and machine vision solutions. Our fixed industrial scanning products automatically track and trace items that move from production through distribution. Our industrial machine vision cameras extend scanning capabilities to help provide quality inspection on product lines. We also provide related software and accessories for these products.

4

Services: We provide a full range of maintenance, technical support, and repair services. We also provide managed and professional services that, among other things, help customers design, test, and deploy our solutions as well as manage their mobility devices, software applications and workflows. Our offerings include cloud-based subscriptions with multiple service levels, which are typically contracted through multi-year service agreements.

Workflow optimization solutions: We provide a portfolio of solutions that help our customers improve the agility and productivity of key operational workflows by analyzing and acting on data in real time. Our primary focus is on frontline workers in Zebra’s core customer segments, including retail, transportation and logistics, warehouse and distribution, and healthcare. Our workflow optimization solutions include:

IV. Zebra’s Due Diligence Process

Zebra’s Conflict Minerals Report relates to the diligence process undertaken for Zebra products that were manufactured, or contracted to be manufactured on behalf of Zebra, during calendar 2021. Zebra’s process to exercise due diligence and to determine country of origin was based on the following approach:

Zebra supports an industry initiative which audits the due diligence activities of the smelters and refiners: that industry initiative is the Responsible Minerals Initiative (the “RMI”), which was formerly known as the Conflict-Free Sourcing Initiative (“CFSI”), organized and operating under the auspices of the Responsible Business Alliance (“RBA”) [formerly known as Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”)].

5

The RMI provides companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas. The RMI designed and manages the Responsible Minerals Assurance Process (“RMAP”), formerly the Conflict-Free Smelter Program (“CFSP”), to identify the smelters that process 3TG and to independently audit those smelters to certify those whose operations are conformant with the RMI RMAP audit protocol. The data on which we relied for certain statements in our Conflict Minerals Report was obtained through our membership in RMI using the Reasonable Country of Origin Inquiry report for members—Zebra’s RMI member code for 2021 reporting is ZKXB.

The Zebra collection and diligence process utilized the RMI Conflict Minerals Reporting Template (“CMRT”), which is the standardized reporting tool that facilitates the collection and transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. Throughout the data collection process for the 2021 reporting year, Zebra continued to utilize the latest version of the CMRT during our due diligence process, CMRT v6.10, which published in April of 2021.

The following steps were taken as part of our overall risk assessment process:

We conducted our data collection by approaching suppliers directly to request completion of the currently available CMRT and asked them to submit the data to us by the 2021 year-end. In total, Zebra collected and reviewed 3TG information for 224 unique suppliers representing 99.2% of our total spend during 2021 [six (6) suppliers failed to respond to Zebra’s direct request]. We have reviewed CMRT declarations for completeness and consistency and used the RMI smelter/refinery database tool (RBA SOR Master formerly known as CM Master), updated monthly, for smelter validation. Additionally, we used an independent research of public domain information to determine non-certified smelters’ potential risk.

6

Based on the information received from our suppliers through Zebra’s diligence process, some information provided by our suppliers was unverifiable or incomplete and as such, we are unable to verify with certainty the source and chain of custody of all 3TGs used in our products. Please see the facilities listed in Table 1 to this Report for the list of facilities that have been reported as the source of 3TGs used in the manufacturing of Zebra products during the 2021 reporting year.

We have consolidated the results of Zebra’s due diligence on the 3TG used in Zebra’s in-scope products, and said results are summarized in the below table:

V.     Conflict Minerals Report

After conducting a reasonable country of origin inquiry and our supply chain due diligence assessment, Zebra has been unable to determine whether sourcing of 3TG metals used in its products directly or indirectly contributed to armed conflicts in the Covered Countries. Accordingly, this Conflict Minerals Report has been filed with the SEC and is publicly available on Zebra’s website under “AboutZebra”/“Compliance”/“ConflictMineralsDisclosureReport” found on Zebra’s website at https://www.zebra.com/us/en/about-zebra/company-information/compliance/products-and-materials-compliance.html.

As a result of Zebra’s diligence efforts, we have concluded that as of December 31, 2021, our products are not considered to be “DRC conflict free” (as defined). Zebra is making this determination because we have concluded in good faith that during 2021, we do not have sufficient information from suppliers or other sources to conclude at this time whether the necessary conflict minerals for in-scope products are in fact DRC conflict free.

7

VI.    Steps to Improve Due Diligence

Zebra expects that the amount of information globally on the traceability and sourcing of Conflict Minerals will continue to increase and this will enable Zebra to continue to make informed decisions regarding its supply chain. Zebra will continue to evaluate its diligence process and work to improve the diligence conducted to help reduce the risk that our necessary Conflict Minerals do not directly or indirectly benefit armed groups in the DRC and Covered Countries.

Zebra’s diligence of its suppliers remains ongoing, and we continue to work to collect accurate and complete responses from our suppliers through the continued use of tools like the Conflict Minerals Reporting Template. Zebra will also review and test its supplier responses against the information collected via independent conflict free smelter validation programs such as the Responsible Minerals Initiative.

Finally, Zebra will continue to monitor changes in circumstances that may impact our determination under the Act.

VII.    Independent Private Sector Audit

As Zebra has not described any of its products as “DRC conflict free” in this Report, and pursuant to the Act, an audit is not required for calendar year 2021.

8

Table 1

SMELTERS CURRENTLY CERTIFIED AS CONFORMANT BY RMI OR EQUIVALENT ORGANIZATION (LBMA, RJC)

This list contains certified conformant smelters reported by Zebra suppliers using 2021 RMI Conflict Minerals Reporting Templates v6.10.

9

10

11

12

13

14

15

16

17

SMELTERS NOT CURRENTLY CERTIFED CONFORMANT

This list contains smelters that are not certified conformant, reported by Zebra suppliers using 2021 RMI Conflict Minerals Reporting Templates v6.10.

18

19

20