UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

VERIZON COMMUNICATIONS INC.

(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:

Section 1 – Conflict Minerals Disclosure

Item 1.01    Conflict Minerals Disclosure and Report

Verizon Communications Inc. has issued a Conflict Minerals Report for the period from January 1, 2019 to December 31, 2019. A copy of the Conflict Minerals Report is filed herewith as Exhibit 1.01 and is available at http://www.verizon.com/about/investors/financial-reporting.

Item 1.02    Exhibit

See Item 2.01

Section 2 – Exhibits

Item 2.01    Exhibits

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

SIGNATURE

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, thereunto duly authorized.

Exhibit 1.01

Verizon Communications Inc. Conflict Minerals Report for Calendar Year 2019

This is the Conflict Minerals Report (“CMR”) of Verizon Communications Inc. (“Verizon”, “Company” or “we”) for the reporting period covering January 1, 2019 through December 31, 2019 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”) and Form SD.

Introduction

The Conflict Minerals Rule requires issuers to annually file a Form SD with the United States Securities and Exchange Commission (“SEC”) to disclose information regarding the use and origin of “Conflict Minerals” necessary for the functionality or production of products manufactured or contracted to be manufactured by such issuer. Under the Conflict Minerals Rule, “Conflict Minerals” currently include columbite-tantalite (coltan), cassiterite, gold, wolframite, and also their derivatives tantalum, tin and tungsten. We refer to gold, tantalum, tin and tungsten collectively as “3TG”. The purpose of the Conflict Minerals Rule is to discover if covered issuers’ use of 3TG may have directly or indirectly financed or benefitted armed groups in the Democratic Republic of Congo and its adjoining countries (the “DRC Region”).

This CMR describes how Verizon’s Conflict Minerals compliance program is designed, as well as what steps have been taken to implement the compliance program, conduct in good faith an investigation as to the country of origin of the minerals used in the Verizon products that are within the scope of the Conflict Minerals Rule, and perform due diligence on the source and chain of custody of such minerals (see “Product Description and Determination”).

This CMR is based on information available at the time of filing. This CMR may contain forward-looking statements regarding steps to be taken in the future as we improve our measures with respect to 3TG, and those statements are subject to risks and uncertainties. References to any website in this Form SD or CMR do not incorporate information from that website within this filing.

Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source Conflict Minerals, (3) internal and external resource constraints, and (4) political and regulatory developments, whether in the DRC Region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this CMR. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this CMR or to reflect the occurrence of unanticipated events.

Reasonable Country of Origin Inquiry

In accordance with the Conflict Minerals Rule, Verizon’s compliance process includes a “reasonable country of origin inquiry” (“RCOI”) seeking the location of the smelter/refiner facilities used to refine or process the 3TG used in products that are within the scope of the Conflict Minerals Rule. With respect to the products described in the “Product Description and Determination” section of this CMR (the “Covered Product”), Verizon requested that its relevant suppliers complete a Conflict Minerals Reporting Template (the “CMRT”) to support the RCOI. The CMRT was developed by the Responsible Minerals Initiative (the “RMI,” see http://www.responsiblemineralsinitiative.org/) to assist companies in determining the smelter/refiner facilities contributing 3TG to their products. The CMRT requests information regarding the supplier’s own Conflict Minerals diligence policies, in addition to the identification of smelter/refiner facilities within the supply chain, and the country of origin of the 3TG used by such facilities. Verizon is a member of the RMI, and uses data available to RMI members to further assess the supplier’s CMRT response – see the section below titled “Identifying and Assessing Risks”.

Verizon’s Compliance Framework

In addition to Verizon’s compliance with the due diligence required by the Conflict Minerals Rule, Verizon has adopted a five-step framework recommended by the Organization for Economic Cooperation and Development in its Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying Supplements (the “OECD Guidance”) as applicable for “downstream companies” (as defined in the OECD Guidance), such as Verizon. The OECD Guidance includes the following steps that downstream companies should include in their Conflict Minerals compliance program:

ESTABLISHMENT OF STRONG COMPANY MANAGEMENT SYSTEMS

Verizon has taken the following steps to strengthen its company management systems with respect to Conflict Minerals matters:

• Instituted a Conflict Minerals Policy. Our Conflict Minerals policy communicates Verizon’s perspective regarding the use of Conflict Minerals, our support of certain cross-industry efforts to address them, and our intent to avoid sourcing 3TG that directly or indirectly benefit non-state armed groups. Our Supplier Code of Conduct incorporates the supplier-facing requirements of our Conflict Minerals policy, including the need for suppliers to assist us with any required RCOI investigations, and the requirement that suppliers of applicable products complete a CMRT to support our Conflict Minerals due diligence programs. Our Conflict Minerals policy can be found on the web at: https://www.verizon.com/about/our-company/company-policies/conflict-mineral.

• Created a Team of Appropriate Personnel to Support Conflict Minerals Due Diligence. We assembled an internal team to support our compliance plan. The team includes representatives from our Legal, Sustainability, Supply Chain, External Communications and Environmental-Social-Governance functions, as well as the appropriate Sourcing teams responsible for managing relevant supplier relationships. Team members periodically review the goals for our Conflict Minerals compliance program, with Legal, Sourcing and Supply Chain teams taking primary responsibility for supplier-facing diligence and compliance measures.

• Established a System of Controls and Transparency over the Mineral Supply Chain. Because Verizon does not typically contract to manufacture the products associated with our business, much of our visibility into the mineral supply chain must necessarily come via our suppliers. Verizon has inserted a detailed set of contractual provisions in its supply contracts for products within the scope of Verizon’s reporting obligations under the Conflict Minerals Rule. The provisions require the supplier to establish processes consistent with the Conflict Minerals Rule and the OECD Framework in order to determine the facilities from which the 3TG originates. The contract provisions also require the supplier’s periodic engagement with Verizon with respect to Conflict Minerals due diligence and the supplier’s completion of a CMRT for review by Verizon.

The contractual provisions described above are detailed and collaborative, requiring periodic meetings and resource dedication to assure that due diligence proceeds throughout each reporting period. The collaborative nature of the provisions is designed to strengthen engagement with our suppliers in accordance with the OECD Framework. The contractual provisions are separate and in addition to the Conflict Minerals-related obligations incorporated by reference within our Supplier Code of Conduct from our Conflict Minerals policy.

• Provided a Company-level Grievance Mechanism. In accordance with our public Supplier Code of Conduct, issues with respect to Conflict Minerals can be reported at any time to our Office of Ethics and Business Conduct through the VZ Compliance Guideline at 844-VZGUIDE (844.894.8433) (within the U.S.), (+)800.0.624.0007 (outside the U.S.), or online at www.verizonguideline.com.

IDENTIFYING AND ASSESSING RISKS

We use the CMRT for data collection in connection with our RCOI. The contractual provisions referred to above provide a schedule for the supplier’s delivery of the CMRT first in draft and then final form, allowing additional time to address any ‘red flags’ as required by the Conflict Minerals Rule. Typically, the CMRT reflects the list of smelter/refiner facilities known by the supplier, or reported to our direct supplier by its own sub-tier suppliers, that contribute 3TG contained in the product to which the CMRT relates.

To assist in determining whether due diligence is necessary, Verizon compares the list of smelter/refiner facilities disclosed by our suppliers with available information about the regions from which those facilities source 3TG. As a RMI member, Verizon has access to minerals sourcing information for smelter/refiner facilities known to the RMI’s assessment program, called the “Responsible Minerals Assurance Process.” Where some of the smelter/refiner facilities disclosed by our suppliers are indicated by the RMI’s country of origin data to source 3TG from the DRC Region, or Verizon otherwise has a reason to believe based on the RCOI that 3TG in our suppliers’ products may have come from the DRC Region, Verizon will exercise due diligence on the source and chain of custody of the 3TG within the affected Verizon products.

Due Diligence

Verizon designed its due diligence framework to conform, in all material respects, with the OECD Guidance as applicable for “downstream companies” (as defined in the OECD Framework), taking into account Verizon’s position in the 3TG supply chain and the fact that Verizon does not typically contract to manufacture the products associated with its business, and typically has limited engagement with suppliers beyond its direct suppliers.

Verizon’s due diligence framework and actions are described below in the sections titled “Responding to Identified Risks” and “Auditing Supply Chain Due Diligence.”

RESPONDING TO IDENTIFIED RISKS

In addition to instituting a Conflict Minerals Policy, we have implemented a risk management process to respond to identified risks, actively involving the applicable direct supplier where necessary to increase commercial leverage on upstream suppliers.

The risk management process largely relies on suppliers’ CMRT submissions. We compare CMRT responses to data provided by the RMI to determine whether the smelter/refiner facilities disclosed by our suppliers have engaged in the RMI’s Responsible Minerals Assurance Process. Where smelter/refiner facilities are not indicated to be “conformant” (indicating that the smelter/refiner conforms to the RMI’s Responsible Minerals Assurance Process assessment protocols) or “active” (indicating that those smelters/refiners that are currently enrolled in the RMI’s assessment program but have not undergone an on-site audit for the applicable compliance period, and while these smelters/refiners have sent in certain required information to show their full sourcing information, the information provided has not been validated by a third party auditor) within the RMI’s assessment program, we engage our suppliers for further information and to cooperate on measures to mitigate identified risks. This will typically involve written communication sent by our direct suppliers, or by Verizon, to selected upstream suppliers, asking them to consider redirecting their minerals sourcing toward smelter/refiner facilities that are either RMI-conformant, are “active” within the RMI program, or have indicated to be undertaking corrective action within the RMI program.

We consider whether additional risk mitigation steps are necessary, such as disengaging or suspending trade with our supplier. We did not view any suspension or disengagement necessary in 2019, largely due to the high level of cooperation from our suppliers.

We brief senior management on the results of our risk assessment and mitigation activities.

AUDITING SUPPLY CHAIN DUE DILIGENCE

Because we do not have a direct relationship with any smelter/refiner facilities for minerals contained in our products, we are unable to conduct audits of these entities. Instead, as recommended by the OECD Framework, we participate in industry initiatives for the development and implementation of a smelter/refiner audit program through our membership in the RMI, which administers the Responsible Minerals Assurance Process, which includes an audit.

PUBLICLY REPORTING ON SUPPLY CHAIN DUE DILIGENCE

Our Form SD and CMR for 2019 are publicly available on Verizon’s website at http://www.verizon.com/about/investors/financial-reporting.

Due Diligence Performed and Results

Verizon determined as a result of its RCOI conducted in 2019 that some of the included smelter/refiner facilities that were disclosed may have sourced 3TG from within the DRC Region. Verizon accessed data about those smelter/refiner facilities disclosed to us that have engaged with the RMI to undergo an independent audit of the measures those smelter/refiner facilities have in place to assure that they are sourcing only conflict-free 3TG. We further analyzed the CMRT responses from each of our suppliers to determine which of the smelter/refiner facilities disclosed by our suppliers were indicated to be “conformant” under the RMI’s assessment program. Where smelter/refiner facilities were not listed as conformant with the RMI’s assessment protocols or were not listed as “active” within the RMI’s assessment program, we engaged our suppliers for further information and a strategy to manage and mitigate identified risks. Each of our direct suppliers reviewed CMRT disclosures from second-tier suppliers to identify which second-tier suppliers were sourcing 3TG from smelter/refiner facilities that were not RMI-conformant smelter/refiner facilities, nor “active”.

Due to our downstream position in the supply chain, we believe that seeking information about 3TG smelter/refiner facilities in our supply chain and otherwise participating in the RMI’s assessment program as described represents a reasonable effort to determine the mines or locations of origin of 3TG in our supply chain. One of our suppliers indicated in its CMRT response that its smelter/refiner facility data reflected information about all Verizon products it supplied, not solely the Covered Product. We engaged in correspondence with that supplier to verify those non-conformant smelters that were present in the supply chain for our Covered Product.

As a result of the due diligence described above, we identified, based on data we received from our suppliers, 242 unique smelter/refiner facilities contributing 3TG contained in our Covered Product for 2019.

Based on data we received from our suppliers, we believe that the smelter/refiner facilities listed (with their geographic location) on Annex I may have contributed 3TG to our Covered Product.

Of the 242 smelter/refiner facilities identified, 235 were included on the RMI’s list of conformant smelters/refiners as of March 2019. Of the remaining 7 smelter/refiner facilities identified, none were on the list of smelter/refiner facilities that were “active” within the RMI’s audit program, but not yet confirmed as conformant. Based on data we have access to as members of the RMI regarding conformant smelter/refiner facilities, we believe that the 3TG used in our Covered Product from those smelter/refiner facilities may have come from the countries listed on Annex II or from recycled or scrap materials. Certain of the RMI-conformant smelter/refiner facilities have not disclosed their sourcing locations to the RMI, so additional countries may have contributed 3TG to those facilities.

Consistent with our Conflict Minerals Policy, which encourages the responsible sourcing of minerals from within the DRC Region, 12 conformant smelters/refiners disclosed to the RMI that they sourced from within the DRC Region and an additional 11 conformant smelters/refiners disclosed to the RMI that they sourced from the Democratic Republic of Congo itself. 17 conformant smelters/refiners that did not directly source from the Democratic Republic of Congo disclosed to the RMI that they indirectly sourced from other conformant smelters within the Democratic Republic of Congo.

Steps Taken Or To Be Taken In 2020 To Mitigate Risk And Improve Due Diligence:

Throughout 2020, Verizon and its suppliers will follow up on the communication steps described in “RESPONDING TO IDENTIFIED RISKS” and will assess alternative sources of 3TG where improvement is not shown.

In 2020, we will continue to do the following:

In addition, as smelter/refiner auditing regimes mature, we will refine and improve contractual provisions that direct suppliers to prefer sources from smelter/refiner facilities that are listed as certified by the RMI.

PRODUCT DESCRIPTION AND DETERMINATION

The due diligence measures set forth above were undertaken with respect to suppliers of the product that Verizon contracts to manufacture listed below. After taking those due diligence measures, we are not able to determine whether, for all of the 3TG smelter/refiner facilities used in our supply chain, those smelter/refiner facilities sourced 3TG from the DRC Region and, if so, whether that 3TG was sourced from recycled, scrap, or other conflict-free sources.

Annex I

Annex II