UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

Form SD

Specialized Disclosure Report

Analog Devices, Inc.

(Exact name of registrant as specified in its charter)

(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

Conflict Minerals Disclosure

Analog Devices, Inc. has filed a Conflict Minerals Report (the Report) as Exhibit 1.01 hereto. The Report is publicly available at www.analog.com under the heading “Investor Relations.” The content of any website referred to in this Form SD and/or the Report is included for general information only and is not incorporated by reference in this Form SD and/or the Report.

The Conflict Minerals Report for the reporting period from January 1 to December 31, 2023 is filed as Exhibit 1.01 to this Form SD.

Section 2 – Resource Extraction Issuer Disclosure

Not applicable.

Section 3 – Exhibits

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

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.

Exhibit 1.01

CONFLICT MINERALS REPORT OF ANALOG DEVICES, INC. IN ACCORDANCE WITH RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934 (UNAUDITED)

Section 1: Introduction

This is the Conflict Minerals Report of Analog Devices, Inc. (Analog Devices, ADI, we, our) for calendar year 2023 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (Rule 13p-1). Numerous terms in this report are defined in Rule 13p-1 and Form SD and the reader is referred to those sources for such definitions and explanations thereof.

Products manufactured or contracted to be manufactured by Analog Devices may contain tantalum, tin, tungsten and/or gold (collectively, conflict minerals) that are necessary to the functionality or production of our products. Based on the reasonable country of origin inquiry (RCOI) described below, Analog Devices either knows that necessary conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (collectively, Covered Countries) and are not from recycled or scrap sources, or has reason to believe that necessary conflict minerals may have originated in the Covered Countries and has reason to believe that they may not be from recycled or scrap sources. Accordingly, we undertook due diligence on the source and chain of custody of the necessary conflict minerals in our products, as described below. Analog Devices is many steps removed from the mining of the conflict minerals; we do not purchase raw ore or unrefined conflict minerals, and we do no purchasing in the Covered Countries. We either purchase conflict minerals indirectly from a smelter or refiner (SOR) for use in our manufacturing processes or purchase components from suppliers that incorporate conflict minerals. The mine or other point of origin of conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined, and converted to ingots, bullion, or other conflict mineral-containing derivatives.

Analog Devices is a global semiconductor leader dedicated to solving our customers’ most complex engineering challenges. We deliver innovations that connect technology to human breakthroughs and play a critical role at the intersection of the physical and digital worlds by providing the building blocks to sense, measure, interpret, connect, and power. We design, manufacture, test, and market a broad portfolio of solutions, including integrated circuits (ICs), software and subsystems that leverage high-performance analog, mixed-signal and digital signal processing technologies. Our comprehensive product portfolio, deep domain expertise and advanced manufacturing capabilities extend across high-performance precision and high-speed mixed-signal, power management and processing technologies – including data converters, amplifiers, power management, radio frequency (RF) ICs, edge processors and other sensors.

Section 2: Product Scope

We design, manufacture, test, and market a broad portfolio of solutions, including ICs, software and subsystems that leverage high-performance analog, mixed-signal and digital signal processing technologies. Our comprehensive solution portfolio, deep domain expertise and advanced manufacturing capabilities extend across high-performance precision and high-speed mixed-signal, power management and processing technologies – including data converters, amplifiers, power management, RF ICs, edge processors and other sensors. The scope of this report applies to semiconductor ICs, monolithic and multi-chip ICs, multi-component ICs, system-in-package modules/hybrid ICs, and other modules and assembled products. Our ICs are designed to address a wide range of real-world signal processing applications. We sell our products to customers worldwide, many of whom use products spanning our core technologies in a wide range of applications. Our IC product portfolio includes both general-purpose products used by a broad range of customers and applications, as well as application-specific products designed for specific target markets. By using readily available, high-performance, general-purpose products in their systems, we help our customers to reduce complexity and accelerate their time to market. Given the high cost of developing more customized ICs, our standard products often provide a cost-effective solution for many low to medium volume applications. More specifically, our analog ICs monitor, condition, amplify or transform continuous analog signals associated with physical forces. By sensing and analyzing signals near their source, we enable processing, decision making and action at the Intelligent Edge, helping us better translate physical forces like temperature, light, and sound into actionable insights, and enabling the innovations that improve quality of life and solve the world’s most pressing challenges. Our analog ICs also provide voltage regulation and power control to electronic systems. We collaborate with customers to design application-specific solutions and help them to solve their toughest technology challenges. We begin with our existing core technologies, which leverage our analog and mixed signal, power management, RF and microwave, edge processors and other sensors, and devise solutions that more closely meet the needs of a specific customer or group of customers. In certain cases, because we have already developed the core technology platform for our general-purpose products, we can create trusted, application-specific solutions quickly and efficiently.

We produce and market a broad range of ICs and products and operate in one reportable segment based on the aggregation of our operating segments. The ICs sold by each of our operating segments are manufactured using similar semiconductor processes, package manufacturing processes and raw materials in either our own production facilities or by third-party wafer fabricators and package manufacturers.

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Section 3: Reasonable Country of Origin Inquiry

Analog Devices engaged with our relevant suppliers to identify SORs in our supply chain. We define relevant suppliers as those who supply materials to Analog Devices that are known to contain any or all of the conflict minerals, where such conflict minerals are necessary to the functionality and/or production of our products. We reach out to our relevant suppliers to request conflict minerals sourcing information using the Responsible Minerals Initiative (RMI)’s Conflict Minerals Reporting Template (RMI CMRT). Information provided by our relevant suppliers is reviewed for completeness and reasonableness, based on our knowledge of the supplier. Further supplier engagement, as necessary, is undertaken for any additional actions regarding their submission, including but not limited to follow-up and escalation on the identified SORs.

Section 4: Due Diligence Framework

Analog Devices’ due diligence measures are designed to conform, in all material respects, with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development (the OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (OECD 2016) (the OECD Framework), including related supplements for each of the conflict minerals. Below is a description of our due diligence measures pursuant to the OECD Framework:

Step 1. Establish strong company management systems

Step 2. Identify and assess risk in the supply chain

The OECD Framework for managing risk is largely directed towards the upstream portion of the supply chain (SORs and mines of origin). As a downstream company in the supply chain, ADI participates in the RMAP under the RMI to identify and review the due diligence process of SORs in our supply chain. The RMI assesses and audits whether SORs adhere to RMAP standards, which meet the requirements of the OECD Framework. Compliant SORs are then designated as Conformant and listed as such on the RMI website. We request suppliers provide information regarding SORs in our supply chain by using the RMI CMRT. We review supplier responses to identify areas for further follow-up and key risks in our supply chain.

Step 3. Design and implement a strategy to respond to identified risks

We encourage suppliers who are sourcing from non-Conformant SORs to move towards using Conformant SORs (as identified via the RMI and other industry-developed third-party audit mechanisms). We contact SORs directly to support participation in the RMI and respond to the RMI’s requests for information as they relate to SOR operational changes, audit requirements or SOR status. If a supplier fails to remedy the risks identified by review of SORs reported to ADI, and subsequent supplier or SOR engagement cannot yield resolution, the supplier status will be escalated for review by the Conflict Minerals Oversight Committee to take measures up to and including termination of our relationship with the supplier, if warranted.

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Step 4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain

We rely on industry efforts, including the RMI, to conduct third-party audits of eligible SORs against the RMAP standards, which meet the OECD Framework for due diligence practices. As a member of the RMI, we utilize information from these RMAP audits as well as other recognized industry audits of SORs to validate SOR conformance.

Step 5. Report on supply chain due diligence

This report and the associated Form SD have been filed with the U.S. Securities and Exchange Commission (SEC) and are available on our website.

Section 5: Due Diligence Results

Tracing the conflict minerals we use in our SORs and country of origin of each such mineral is a complex endeavor, but an important aspect of responsible sourcing. To help establish and maintain our supply chain compliance sourcing program, we have followed currently established industry guidelines such as those developed by the RMI under the OECD Framework, which enables companies to source minerals from SORs that have been subjected to a rigorous, independent third-party audit.

To implement our RCOI survey process, we adopted the RMI’s industry approach and leveraged the RMI CMRT to gather information from our first-tier suppliers to help us trace the origin of necessary conflict minerals used in our products by identifying SORs, recyclers and scrap supplier sources of conflict minerals. We also utilized the RMI and its RMAP to trace the mine of origin of conflict minerals when such information was available. The RMI conducts independent audits of SORs to ensure that all certified SORs are Conformant or actively engaged in the RMAP.

The responses from our suppliers listed 248 entities as SORs of conflict minerals in their supply chains. A recognized responsible minerals assurance process verified 240 of these entities as Conformant by the RMI. The following is a summary as of April 3, 2024 of SORs used by our suppliers by mineral type:

After exercising the due diligence described above, Analog Devices concluded that some of its necessary conflict minerals originated in the Covered Countries. Analog Devices was unable to determine whether or not such conflict minerals directly or indirectly financed any armed group(s) in the Covered Countries.

Section 6: Other Matters

Based on the information provided by our suppliers through December 31, 2023, we believe that the facilities that may have been used to process conflict minerals in our products include the SORs listed in Annex I below.

Based on information provided by our suppliers and from the RCOI data from the RMI, we believe that the origin of the conflict minerals contained in our products may include the countries listed in Annex II below as well as recycled and scrap sources.

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Analog Devices will undertake the following steps during the next compliance period to continue to improve the due diligence conducted and to further mitigate the risk that our necessary conflict minerals benefit armed groups in the Covered Countries:

This report includes forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, which involve risks and uncertainties. Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward-looking statements can also be identified by words such as “expects,” “plans,” “intends,” “will,” “may,” and similar terms. Forward-looking statements are not guarantees of future actions or performance. Analog Devices assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law.

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ANNEX I ⁽¹⁾

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ANNEX II

Algeria

Andorra

Antigua and Barbuda

Australia

Argentina

Austria

Azerbaijan

Bahamas

Barbados

Bangladesh

Belgium

Benin

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Belarus

Bolivia

Bosnia and Herzegovina

Botswana

Brazil

Bulgaria

Burkina Faso

Burundi

Cambodia

Cameroon

Canada

Cayman Islands

Chile

China

Chinese Taipei

Colombia

Costa Rica

Côte D’ivoire

Congo, Democratic Republic of The

Croatia

Curacao

Cyprus

Czech Republic

Denmark

Dominican Republic

Egypt

El Salvador

Ecuador

Estonia

Ethiopia

Fiji

Finland

France

French Guiana

Georgia

Germany

Ghana

Grenada

Greece

Guatemala

Guinea

Guyana

Honduras

Hong Kong

Hungary

Iceland

India

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Indonesia

Ireland

Israel

Italy

Jamaica

Jordan

Korea, Republic of

Kazakhstan

Kenya

Kuwait

Kyrgyzstan

Lao People’s Democratic Republic

Laos

Latvia

Lebanon

Liberia

Liechtenstein

Lithuania

Luxembourg

Macao

Madagascar

Mali

Malta

Mauritania

Mauritius

Mexico

Monaco

Mongolia

Morocco

Mozambique

Myanmar

Namibia

Netherlands

New Zealand

Nicaragua

Niger

Nigeria

Norway

Oman

Pakistan

Panama

Papua New Guinea

Peru

Philippines

Poland

Portugal

Puerto Rico

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Romania

Russia

Rwanda

Saint Kitts and Nevis

Saint Maarten

Saudi Arabia

Senegal

Serbia

Sierra Leone

Singapore

Slovakia

Slovenia

South Africa

Spain

St Vincent and Grenadines

Sudan

Suriname

Sweden

Tajikistan

Tanzania

Thailand

Trinidad and Tobago

Tunisia

Turkey

Turks and Caicos

Uganda

Ukraine

United Arab Emirates

United Kingdom of Great Britain and Northern Ireland

United States of America

Uruguay

Uzbekistan

Vietnam

Zambia

Zimbabwe

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