Form SD RTI Surgical Holdings,

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM SD

Specialized Disclosure Report

RTI SURGICAL HOLDINGS, INC.

(Exact name of Registrant as specified on its charter)

Ryan M. Bartolucci

Chief Accounting Officer

(877) 343-6832

(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

This Form SD of RTI Surgical Holdings, Inc. (the “Company”) has been prepared and filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2018 to December 31, 2018.

A copy of the Company’s Conflict Minerals Report is attached as Exhibit 1.01 to this Form SD, and is publicly available at www.rtix.com/en_us/investors/.

Section 2 – Exhibits

Item 2.01: Exhibits

Exhibit 1.01 — Conflict Minerals Report for the reporting period from January 1 to December 31, 2018.

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.

EXHIBIT INDEX

RTI Surgical Holdings, Inc.

Form SD

Exhibit 1.01

RTI Surgical Holdings, Inc.

Conflict Minerals Report

For The Reporting Period from January 1, 2018 to December 31, 2018

This Conflict Minerals Report (this “Report”) of RTI Surgical Holdings, Inc. (the “Company,” “we,” “us,” or “our”) has been prepared for the reporting period from January 1, 2018 to December 31, 2018 pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended. The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants who manufacture or contract to manufacture products containing “Conflict Minerals” (as defined in the next sentence) which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite (“coltan”), gold, wolframite, and the derivatives tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule 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.

Pursuant to the Rule, we were required to conduct due diligence for 2018 on the Conflict Minerals’ source and chain of custody and submit this Report to the SEC that includes a description of those due diligence measures. Those measures are discussed below.

Company Overview

This Report has been prepared by management of the Company. We are a global surgical implant company that designs, develops, manufactures and distributes biologic, metal and synthetic implants. Our implants are used in orthopedic, spine, sports medicine, general surgery, trauma and other surgical procedures to repair and promote the natural healing of human bone and other human tissues and improve surgical outcomes. We manufacture metal and synthetic implants and process donated human musculoskeletal and other tissue and bovine and porcine animal tissue in producing allograft and xenograft implants using our proprietary BIOCLEANSE^®, TUTOPLAST^® and CANCELLE^® SP sterilization processes.

While our allograft and xenograft implants do not contain Conflict Minerals, we manufacture metal and synthetic implants that may contain Conflict Minerals. We do not source the necessary Conflict Minerals in the in-scope products that we manufacture directly from mines, smelters or refiners and believe that we are in most cases many levels removed from these market participants. As a result, we have limited influence over the mines, smelters, refiners and many of the other suppliers in our supply chain. Furthermore, for these reasons, and because our supply chain is large and constantly evolving, we have difficulty in obtaining information on the source of each of the Conflict Minerals in the in-scope products that we manufacture. However, through the efforts described in this Conflict Minerals Report, we attempt to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is discussed in the section below, and to encourage conflict free sourcing in our supply chain.

We strive to conduct our activities in a manner that reflects our mission and Code of Conduct, which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing for materials for our products. As part of our commitment we have adopted a Supply Chain Policy (“Policy”) relating to conflict minerals which is posted on our website at www.rtix.com/en_us/about/corporate-social-responsibility. Our Policy provides that we support the goals and

objectives of the Dodd-Frank Act and that we expect our suppliers to support our efforts to comply with the Dodd-Frank Act and to proactively identify and make every effort to eliminate the use of any Conflict Minerals in our supply chain. In addition, we expect our suppliers to conduct business operations in an ethical manner and comply with all applicable laws related to environmental responsibility, workplace health and safety, and human resources.

Due Diligence Process

The Company’s due diligence program and related efforts on the chain of custody of the Conflict Minerals in its products has been designed in consideration of the framework in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition (the “OECD Guidance”). It is important to note that the OECD Guidance was written for both upstream and downstream companies in the supply chain. As the Company is close to the end-user of its products and is therefore a downstream company in the supply chain, our due diligence measures were tailored accordingly, which includes the five-step framework for risk-based due diligence in the mineral supply chain.

We intend to continue to improve our due diligence measures, which we believe will further mitigate the risk that our necessary Conflict Minerals do not benefit armed groups. The steps we intend to take in the 2019 compliance period include:

Determination

A total of 56 suppliers were identified as in-scope and contacted as part of the RCOI process. The response rate among these suppliers was 98%. Through the smelter/refiner identification and validation process, the Company identified 52 smelters/refiners with an indication of Covered Country sourcing, see table below. Due to our downstream position in our supply chain, we rely on our suppliers for accurate smelter and refiner information.

For the 52 smelters/refiners listed in the above table, the Company found each to be a Certified Smelter with Conflict-Free Certifications.