UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

 

SPECIALIZED DISCLOSURE REPORT

 

Alibaba Group Holding Limited

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

 

 

 

Timothy A. Steinert, Esq.

General Counsel and Secretary

Telephone: +852-2215-5100

(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:

 

x  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2018 to December 31, 2018

 

 

 

Section 1 Conflict Minerals Disclosure

 

Item 1.01 Conflict Minerals Disclosure and Report

 

Conflict Minerals Disclosure

 

This Form SD disclosure of Alibaba Group Holding Limited (the “Company”) is for the period from January 1, 2018 to December 31, 2018. Unless the context indicates otherwise, “the Company,” “we,” and “our” refer to Alibaba Group Holding Limited and its consolidated subsidiaries and its affiliated consolidated entities, including our variable interest entities and their subsidiaries.

 

This disclosure is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). Pursuant to Rule 13p-1, the Company undertook to determine whether the products it manufactured or contracted to manufacture during the year ended December 31, 2018 contained conflict minerals necessary to the functionality or production of such products. “Conflict minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum and tungsten (“3TG”).

 

The Company evaluated its products to determine which of its products may contain 3TG. Based on this review, the Company determined that 3TG are necessary to the functionality or production of certain components in its products as follows:

 

(i)                         Certain of our Tmall Genie smart speakers and certain of our Tmall set-top boxes, remote controls and routers contain gold and tin;

 

(ii)                      DingTalk’s communications centers and mobile routers contain gold, tin, tantalum and tungsten;

 

(iii)                   DingTalk’s smart attendance machines contain gold and tin;

 

(iv)                  DAMO Academy’s smart speech recognition devices contains tin;

 

(v)                     Alibaba Cloud’s network access gateways as well as digital price tags contain gold, tin, tantalum and tungsten;

 

(vi)                  Koubei’s point of sale, or POS, systems contain gold, tin and tantalum;

 

(vii)               Amap’s navigation systems for vehicles contain gold, tin, tantalum and tungsten;

 

(viii)            Pingtouge Semiconductor Co. Ltd.’s chip wafers contain tantalum and tungsten; and

 

(ix)                  certain of Taobao Select’s private label home and personal electronics and appliances, taken as a whole, contain tin, gold, tantalum and tungsten.

 

We refer to the foregoing products as the “Covered Products.” The Covered Products account for an insignificant percentage of our revenue.

 

The Company conducted a reasonable country of origin inquiry to determine whether any of the 3TG contained in the Covered Products originated in the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (together, the “Covered Countries”) or from recycled or scrap sources. The Company’s primary means of determining the country of origin of the 3TG contained in the Covered Products was conducting (i) an internal supply-chain inquiry to identify products containing 3TG, and (ii) inquiring of the Company’s suppliers eliciting, as applicable, information regarding (a) the country of origin of the 3TG contained in the Covered Products, (b) whether the 3TG came from scrap or recycled sources, and (c) other relevant information regarding the suppliers’ (or its suppliers’) practices concerning 3TG.

 

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Based on the reasonable country of origin inquiry described above, the Company is unable to determine with the greatest possible specificity the country of origin of the 3TG in the Covered Products.

 

In accordance with the requirements under Rule 13p-1, the above disclosure is also available on the Company’s website at http://www.alibabagroup.com/en/ir/secfilings.

 

Item 1.02 Exhibits

 

None.

 

Section 2 Exhibits

 

Item 2.01 Exhibits

 

None.

 

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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.

 

	ALIBABA GROUP HOLDING LIMITED
Date: May 31, 2019	By:	/s/ Timothy A. Steinert
		Timothy A. Steinert
		General Counsel and Secretary

 

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