Form SD SCHLUMBERGER LIMITED/NV

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

SCHLUMBERGER N.V.

(SCHLUMBERGER LIMITED)

(Exact name of registrant as specified in its charter)

Dianne B. Ralston

Chief Legal Officer and Secretary

(713) 513-2000

(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

Conflict Minerals Disclosure

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, Schlumberger Limited (the “Company”) has filed this Specialized Disclosure Report and the Conflict Minerals Report attached hereto as Exhibit 1.01 for the year ended December 31, 2021. Both of these documents are publicly available on the Company’s website at: https://www.slb.com/who-we-are/guiding-principles/corporate-accountability/conflict-minerals.*

Section 2 – Exhibits

Item 2.01 Exhibits

Exhibit 1.01 – 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.

SCHLUMBERGER LIMITED

Date: May 31, 2022

Exhibit 1.01

SCHLUMBERGER LIMITED

CONFLICT MINERALS REPORT

FOR THE YEAR ENDED DECEMBER 31, 2021

This Conflict Minerals Report (the “Report”) of Schlumberger Limited 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, 2021 to December 31, 2021.

All references in this Report to “Schlumberger,” “Company,” “we,” “us” or “our” are to Schlumberger Limited (Schlumberger N.V., incorporated in Curaçao) and its consolidated subsidiaries as of December 31, 2021.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which specified minerals are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“conflict minerals”).

Description of Products Covered by this Report

This Report relates to Schlumberger products: (a) that contain conflict minerals necessary to their functionality or production (“necessary conflict minerals”); (b) that we had reason to believe may have originated in the Democratic Republic of the Congo or an adjoining country (the “covered countries”) and may not have come from recycled or scrap sources; and (c) that we manufactured, or contracted to be manufactured, in 2021 (the “covered products”).

The covered products are as follows: permanent multiphase meters; subsea safety valves; oil, gas and core analysis laboratory equipment; perforating hardware and accessories; downhole drilling tools; solids and pressure control equipment for drilling fluids systems; data acquisition equipment for drilling operations; surface and downhole completions tools; artificial lift pumps; stimulation pumping and cementing equipment; groundwater monitoring products; drilling equipment packages; blowout preventers; drilling risers, top drives; draw works; complete wellhead and Christmas tree systems for onshore and offshore applications; subsea production systems and manifolds and aftermarket parts; valves; actuators; chokes and aftermarket parts; heaters; dehydration and desalting units; gas conditioning units; membrane separation systems; water processing systems; and electronic controls.

Due Diligence Design and Process

Our due diligence efforts were designed to conform in all material respects to the framework in the Organisation for Economic Co-operation and Development’s “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” and related Supplements on Gold and on Tin, Tantalum and Tungsten (collectively, the “OECD Guidance”).

The following is a description of the measures that we took to exercise due diligence on the source and chain of custody of necessary conflict minerals contained in our covered products.

Step 1: Company Management Systems

Conflict Minerals Policy

We have adopted a policy relating to conflict minerals in our products (the “Conflict Minerals Policy”), incorporating relevant standards contained in the OECD Guidance, which is available at https://www.slb.com/who-we-are/guiding-principles/corporate-accountability/conflict-minerals. The Conflict Minerals Policy iterates our commitment to responsibly source materials from suppliers that share our values. It reflects our expectation that our immediate (“Tier 1”) suppliers will perform due diligence similar to ours on the sources of conflict minerals in their supply chains, and our expectation that they will require their own suppliers to do the same. It further provides generally that when a robust and validated conflict-free supply chain is established or a robust mineral tracing program is developed, we will expect our direct suppliers to procure only minerals using that validated supply chain, so as to avoid the use of minerals that have financed conflict in the covered countries.

Internal Management Teams

Members of our business, planning and supply chain, legal, compliance, sustainability, human rights, and information technology functions comprised a core team that was involved in various phases of our compliance with the Rule. Members of this core team have put in place processes and controls reasonably designed to increase transparency in our conflict minerals supply chain. Members of the core team annually present to their respective Division Presidents or, in certain cases, Basin Presidents, a final, formal review of: (a) their findings as to the source and status of the necessary conflict minerals contained in the covered products for sale by their Division or Basin, as applicable; and (b) their Division or Basin due diligence efforts.

1

Control Systems

We have (a) adopted various processes related to our conflict minerals compliance efforts and determinations; (b) adopted standardized data templates for all Divisions to promote consistency across various information technology systems; (c) adopted a procedure in our engineering design and manufacturing systems that requires the recording of necessary conflict mineral contents of newly-developed parts included in our products; (d) adopted an electronic repository to retain relevant documentation concerning our conflict minerals compliance efforts and determinations; and (e) adopted written summaries, reviewed by the President of each relevant Division, summarizing how each such Division complied with the Rule and which of its products were subject to the Rule. In addition, certain employees from our planning and supply chain, legal, engineering, manufacturing, sustaining, sales, finance, and compliance functions are targeted for annual training.

As a downstream company, we are several tiers removed from conflict mineral smelters and refiners (“SORs”). We therefore must rely on information from industry sources to compare and assess due diligence responses, identify SORs in our supply chains and improve our ongoing due diligence efforts. We implemented a supply chain transparency system through the use of due diligence tools developed by the Responsible Minerals Initiative (“RMI”), including the RMI Conflict Minerals Reporting Template (the “Template”), which is designed to identify the SORs that process the conflict minerals in a company’s supply chain. We also support our suppliers’ use of validation, certification and audit programs on SORs upstream in our supply chain, such as:

We maintain a company-level grievance mechanism, as described in our Code of Conduct, that enables employees and others to anonymously report concerns, including any concerns regarding our conflict minerals supply chain. We communicate this mechanism to our employees at various times.

Step 2: Identification and Assessment of Supply Chain Risks

In order to identify and assess the risks in our supply chain, we first identified products for sale that we manufactured or contracted to manufacture in 2021 that contained, or that may have contained, necessary conflict minerals. As stated above, we have adopted a procedure in our engineering design and manufacturing system that is reasonably designed to identify each necessary conflict mineral included in our products. In cases where we determined that a necessary conflict mineral was contained in one of our parts, we identified that specific mineral and flagged both the part and finished product containing that part in our system. If, after our initial research, we were unable to determine whether a necessary conflict mineral was included in a part, we considered that part to be in scope of the Rule, and such part was internally flagged for additional research. For each new part developed or manufactured in 2021, the engineers and métiers in charge of providing materials for such part were required to indicate any necessary conflict minerals included in the part. Where we determined that a newly-developed part contained a necessary conflict mineral and that the finished product was in scope of the Rule, we included that part in our further information gathering efforts. We then identified our Tier 1 suppliers that supplied us with the parts and products considered to be within the scope of the Rule.

Because we are several tiers removed from mining operations and SORs, we must rely on our suppliers to provide information regarding the source and presence of necessary conflict minerals in our covered products. To that end, we engaged a third-party data collection and aggregation provider to assist us in conducting due diligence on our supply chain. Information was collected using the Template, which requested our Tier 1 suppliers to identify the SORs and countries of origin of the necessary conflict minerals they supplied to us and contained in our covered products and to determine whether any such necessary conflict minerals came from recycled or scrap sources. These requests were sent in multiple languages for the 2021 reporting year, in order to facilitate improved supplier response rates. In conducting due diligence, we prioritized obtaining responses from our critical suppliers, as determined based on their strategic and commercial importance to us and as discussed under “Supplier Categories” in “Step 5: Report on Supply Chain Due Diligence” below. We communicated this priority to our third-party data collection and aggregation provider in an effort to increase the response rate of these critical suppliers.

Our supplier engagement began with introductory emails to relevant Tier 1 suppliers, notifying them that we would be conducting appropriate due diligence regarding the presence, source, and chain of custody for any necessary conflict minerals that may be contained in parts or products that we purchased from them. The emails also described our conflict minerals compliance program and the Rule. In an effort to increase awareness of our conflict minerals program, we provided suppliers with background materials describing the conflict minerals rule, including frequently asked questions regarding, among other things, conflict minerals tracing. We requested product-level information from our Tier 1 suppliers on the parts and products we purchased from them. Suppliers were allowed to submit multiple responses as necessary to address all such parts and products.

2

We pursued subsequent engagement with non-responsive suppliers, including sending multiple email reminders requesting survey completion. Suppliers who remained non-responsive after these email reminders were contacted by phone and offered assistance, including further information about the Rule, our conflict minerals program, and clarification regarding how they could provide the required information. If, following the above efforts, a supplier still did not provide the information requested, we further escalated the matter internally on a supplier-risk-priority basis and followed up directly with certain of these suppliers.

We reviewed and evaluated all supplier responses for consistency and completeness, both in terms of which products were said to contain or not contain necessary conflict minerals, as well as the origin of those materials. When necessary, we followed up with suppliers on responses to their reporting templates to seek clarifying or corrective information. Specifically, if a supplier indicated that a product sold to Schlumberger did not contain conflict minerals, but we believed otherwise based on our own analysis, we requested (a) evidence that the product does not contain conflict minerals or (b) an updated Template response indicating the results of such supplier’s due diligence on the source of any conflict minerals contained in such product.

In instances where a supplier identified a SOR and the source of its conflict minerals, we sought to verify this information with third-party databases, Internet searches and reviews of government databases and industry and trade organization lists, including the list of known conflict minerals processing facilities worldwide published by the U.S. Department of Commerce. We also compared the SORs identified by suppliers in their responses to us against the list of compliant SORs published in the RMAP, the LBMA and the RJC. In some cases, a supplier identified a SOR and stated that its conflict minerals were not sourced from any of the covered countries. However, we were sometimes able to confirm, based on available information concerning the SOR identified, that the SOR was reported to source conflict minerals from one or more of the covered countries. In such cases, we communicated our findings to the supplier for further investigation. As a general matter, we requested that suppliers update their responses to us as more information became available to them.

Based on our review, we flagged certain responses when:

We followed up on all flagged responses to clarify and address inconsistencies, incompleteness, invalid responses, uncertainties, and responses indicating that relevant conflict minerals were or may have been sourced from one or more of the covered countries.

In addition, in 2021, we conducted a series of online trainings for our Tier 1 suppliers in multiple time zones, in order to train our suppliers on completing their Template responses and to facilitate improved supplier response rates.

Step 3: Strategy to Respond to Identified Risks

For any SORs that were known to source necessary conflict minerals from any of the covered countries, we confirmed that such SORs were listed in the various lists of compliant SORs described above. For any SORs known to source conflict minerals from covered countries, as well as SORs located in any covered country with unknown sources of conflict minerals, we will send, in 2022, a communication to our Tier 1 suppliers who sourced from such SORs, recommending that they request that such SORs become certified as compliant, pursue an alternative source of conflict minerals, and participate in the RMI to support industry efforts to achieve supply chain transparency.

As described in our Conflict Minerals Policy, in the event that we have reason to believe a supplier is supplying us with conflict minerals from sources that may support conflict in any of the covered countries, we will encourage that supplier to establish an alternative source of conflict minerals that does not support such conflict, or we may consider reevaluating the supplier relationship. If a Tier 1 supplier (i) has been unresponsive or otherwise uncooperative in our due diligence efforts or (ii) is not compliant with our Conflict Minerals Policy and is unwilling to expect its own suppliers to use conflict-free sources, then we may likewise reassess the supplier relationship. As described above, we support the use of validation, certification, and audit programs for SORs in our supply chain.

3

Our supplier engagement efforts described above in “Step 2: Identification and Assessment of Supply Chain Risks” also support our risk mitigation efforts.

Step 4: Independent Third-Party Audit of SORs’ Due Diligence Practices

As stated above, we are several tiers removed from mining operations and SORs. Furthermore, we do not have direct relationships with SORs, and while we conduct routine audits of our critical suppliers in accordance with internal requirements, we do not perform direct audits of all the upstream entities within our supply chain. Accordingly, we rely on our suppliers to provide the information necessary to assess compliance with our conflict minerals program and support the development and implementation of independent third-party audits of SORs’ sourcing, such as the RMAP.

We use a third party to aid in verifying the information supplied by our suppliers with respect to the SORs that they source from, and to review and confirm the validity of the RMAP, RJC, and LBMA certifications of those SORs. In some cases, our third party reaches out directly to SORs as necessary to confirm the information either publicly available or made available in reporting template responses that may be contradictory or incomplete.

Step 5: Report on Supply Chain Due Diligence

As indicated in the Specialized Disclosure Report on Form SD, this Report and our Conflicts Minerals Policy are publicly available on our website at https://www.slb.com/who-we-are/guiding-principles/corporate-accountability/conflict-minerals.

Supplier Categories

We categorize our suppliers by commercial importance:

We further classify certain SM Level 1 and SM Level 2 suppliers as “critical” if they provide materials, components, or services that may significantly influence one or more aspects of Schlumberger products and service performance. This includes elements such as safety, technology, and competitiveness, as well as compliance with operations integrity, health, safety and environmental standards, and ethics standards.

For 2021, we sent the Template to 3,224 suppliers and received completed responses from approximately 59% of these suppliers. As part of our risk identification and mitigation efforts, we focused on obtaining responses from our priority suppliers, including SM Level 1 suppliers, SM Level 2 suppliers, and critical suppliers within those two categories.

Results of Supply Chain Due Diligence

The following table lists the response rate and certain other information for our suppliers who received the Template in 2021.

Many of the respondents indicated that they had not finished the due diligence on their supply chains and were still completing the Template. As indicated above, we requested information from our suppliers at the product level; 63% of the completed Templates provided information at the product level for 2021, as compared to 67% for 2020.

For the responses we received at the company level, rather than product level, we do not know whether the SORs listed actually supplied conflict minerals that we used in our covered products. Therefore, such SORs are not included in the tables below of the SORs that we know to have processed the necessary conflict minerals contained in our covered products.

4

For responses we received at the product level, 333 SORs, organized by type of metal, are listed in the tables below. Based on our due diligence, we identified 52 verified SORs that smelt or source conflict minerals from one or more of the covered countries, of which 46 are certified by a recognized certification body. Three additional SORs are not currently certified by a recognized certification body, but are in the process of becoming certified by RMAP. Of the three remaining SORs that are not currently certified by a recognized certification body, one is located in a covered country with an unknown gold source, one is known to source tin from a covered country, and one is known to source gold from a covered country. As stated above, for each of these SORs not currently certified by a recognized certification body, we will send, in 2022, a communication to our Tier 1 suppliers who sourced from such SORs, recommending that they request that such SORs become certified as compliant, pursue an alternative source of conflict minerals, and participate in the RMI to support industry efforts to achieve supply chain transparency.

Future Process Improvements

Supplier engagement — As stated above, we received responses from 59% of our Tier 1 suppliers for 2021. An additional 1% of our Tier 1 suppliers provided some information in response to our reasonable country of origin inquiry, but did not complete their responses. We will continue to engage with our Tier 1 suppliers to attempt to increase supply chain transparency, including by following up with unresponsive suppliers and by sending the communications described in “Step 3: Strategy to Respond to Identified Risks” above.

In addition, we will work with our Tier 1 suppliers to obtain even more product-level responses. As stated above, 63% of our supplier responses for 2021 were at the product level, as compared to 67% for 2020.

Employee training — Approximately 96% of our employees targeted for training on the Rule completed their annual training in 2021. These employees are members of the planning and supply chain, legal, engineering, manufacturing, sustaining, sales and marketing, finance and compliance functions. We will also develop additional training materials to enhance understanding of various procedures for targeted employees who are integral to our reporting requirements under the Rule.

Automation of additional business lines — As described above, we have adopted standardized data templates for all Divisions to ensure consistency across various information technology systems and adopted a procedure in our engineering design and manufacturing systems that requires the recording of necessary conflict mineral contents of newly-developed parts included in our products. These templates and systems continue to be refined and automated in our current business lines and implemented in any new business lines which are the result of acquisition throughout the calendar year. We expect to continue to improve our automatization of these processes and the number of business lines which they cover.

5

SORs and Countries of Origin

The table below, which is as of April 22, 2022, lists the SORs known to us to have supplied necessary conflict minerals contained in our covered products and that sourced conflict minerals from one or more of the covered countries:

6

7

8

9

10

11

12

13

The table below, which is as of April 22, 2022, lists the SORs known to us to have supplied necessary conflict minerals contained in our covered products but did not source conflict minerals from any of the covered countries:

14

15

16

17

18

19

20

21

22

23

24

25

26

The table below, which is as of April 22, 2022, lists the SORs known to us to have supplied necessary conflict minerals contained in our covered products and that were either certified as compliant by one or more independent third-party audit certification programs or that used only recycled or scrap minerals, but as to which we were unable to determine the countries of origin from which they sourced such conflict minerals:

27

The table below, which is as of April 22, 2022, lists the SORs known to us to have supplied necessary conflict minerals contained in our covered products and that were not certified as compliant by one or more independent third-party audit certification programs. In addition, despite our diligence efforts we were unable to determine the countries from which these SORs sourced necessary conflict minerals:

28

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