UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

LEGGETT & PLATT, INCORPORATED

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

Jennifer J. Davis

Executive Vice President,

General Counsel

(417) 358-8131

(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:

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

This Form SD of Leggett & Platt, Incorporated is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act, as amended, for the reporting period from January 1, 2023 to December 31, 2023.

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and incorporated by reference herein, and is publicly available at https://leggett.com/supplier-documents. The website and information accessible through it are not incorporated into this document.

Item 1.02 Exhibit

As specified in Section 3, Item 3.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Section 2 – Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not Applicable

Section 3 – Exhibits

Item 3.01 Exhibits

The following exhibit is filed as part of this report.

EXHIBIT INDEX

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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 duly authorized undersigned.

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Exhibit 1.01

Leggett & Platt, Incorporated

Conflict Minerals Report

For the Reporting Period from January 1, 2023 to December 31, 2023

This Conflict Minerals Report (the “Report”) of Leggett & Platt, Incorporated (the “Company,” “we,” “our” or “us”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2023 to December 31, 2023.

The Rule requires disclosure of certain information when a company manufactures, or contracts to manufacture, products which contain certain minerals specified in the Rule that are necessary to the functionality or production of those products. These minerals, which we collectively refer to in this Report as “Conflict Minerals,” are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

The information in this Report includes the activities of the Company and its subsidiaries during the reporting period, excluding Pacoma USA Inc., Pacoma (China) Hydraulic Equipment Co., Ltd., and Pacoma GmbH (collectively, Pacoma USA Inc., Pacoma (China) Hydraulic Equipment Co., Ltd., and Pacoma GmbH are referred to as “Pacoma”). Pacoma was acquired on or after May 1, 2022, and, prior to that acquisition, Pacoma had not been obligated to provide a specialized disclosure report with respect to Conflict Minerals. In accordance with Instruction 3 to Item 1.01 of Form SD, Pacoma was not included in this filing because it was acquired fewer than eight months from the beginning of the reporting period.

The Company

We are a global manufacturer with facilities located around the world. Our manufacturing facilities are located in Austria, Belgium, Brazil, Canada, China, Croatia, Denmark, France, Germany, Hungary, India, Ireland, Mexico, Poland, South Korea, Switzerland, the United Kingdom, and the United States. Our operations are organized into 15 business units, which are divided into seven groups under three segments: Bedding Products; Specialized Products; and Furniture, Flooring & Textile Products.

The Company’s Reasonable Country of Origin Inquiry

Internal Survey and Reasonable Country of Origin Inquiry. We conducted an internal survey of parts and materials we purchased from suppliers. We assigned authority and responsibility to a person or persons for each business unit to (a) compile an internal inventory of the parts and materials that we (i) knew or reasonably suspected contained necessary Conflict Minerals and (ii) knew had been included in a product, the manufacture of which was completed in the reporting period, and (b) identify the associated suppliers. Based on our identified “in-scope” suppliers, we conducted a good faith, reasonable country of origin inquiry (“RCOI”) regarding such necessary Conflict Minerals. This RCOI was reasonably designed to determine whether the Conflict Minerals originated in the Covered Countries and whether the Conflict Minerals came from recycled or scrap sources. We implemented a supplier engagement approach. We sent requests to identified in-scope suppliers for necessary Conflict Minerals and sourcing information; smelter or refiner (the “SOR”) identification; and identification of the origin of the necessary Conflict Minerals used by those SORs (i.e., country of origin, recycled or scrap, etc.). Requests were sent through the SupplierSoft Conflict Minerals Application, a web-based tool designed to communicate and track Conflict Minerals sourcing information throughout the Conflict Minerals supply chain, using the Responsible Minerals Initiative (the “RMI”) Conflict Minerals Reporting Template (the “CMRT”). Along with the CMRT request, we distributed correspondence to each in-scope supplier which briefly described the requirements of the Rule and contained an electronic link to our Conflict Minerals Policy (the “Policy”) and our Purchase Order Terms and Conditions (the “Purchase Order Terms”) (each discussed below).

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Validation and Analysis of Supplier Responses. The supplier responses on the CMRT were validated, to the extent reasonably practicable, by analyzing each CMRT for the existence of “red flags.” Our red flags generally included: (i) an incomplete response; (ii) the CMRT declaration that not all SORs have been listed for each Conflict Mineral declared; (iii) the CMRT declaration of any Conflict Minerals originating from Covered Countries from a SOR that is not active or conformant with RMI’s Responsible Minerals Assurance Process (the “RMAP”); (iv) the CMRT declaration of any Conflict Minerals originating from conflict-affected and high-risk areas from a SOR that is not active or conformant with RMI’s RMAP; (v) the inclusion of any Covered Countries on the SOR page of the CMRT where the SOR that is reported is not active or conformant with RMI’s RMAP; and (vi) conflicting responses within the same CMRT. CMRT information was recorded in our Conflict Minerals Database (the “CM Database”). We prepared and delivered summary reports of supplier responses to senior management in our Conflict Minerals management structure.

Follow-up Request to Suppliers. We sent follow-up letters requesting a response from those in-scope suppliers who did not respond. Also, we sent communications requesting the identity of the non-responsive supplier’s supplier in an attempt to send the CMRT to such “sub-supplier” and ascertain the identity of the SOR and the origin of any necessary Conflict Minerals in our supply chain. As discussed above, where in-scope suppliers provided a CMRT with responses considered to contain red flags, we sent follow-up communications requesting an explanation or elimination of any red flag.

Results of Reasonable Country of Origin Inquiry. We identified 257 in-scope suppliers and achieved a 95% response rate with 243 of these suppliers responding. We concluded that the Company has manufactured or contracted to manufacture products which contain Conflict Minerals that are necessary to the functionality or production of those products. Based on the RCOI, we determined that some parts and materials purchased contain necessary Conflict Minerals that originated from recycled or scrap sources or from outside the Covered Countries. These Conflict Minerals were outside the scope of our due diligence process described below.

The Company also determined that it knows or has reason to believe that a portion of its necessary Conflict Minerals originated or may have originated in the Covered Countries and are not or may not be solely from recycled or scrap sources. Accordingly, with respect to these Conflict Minerals, we conducted due diligence on the source and chain of custody of such Conflict Minerals. These Conflict Minerals are contained in the “Covered Products” described below.

The Company’s Due Diligence Process

Design of Due Diligence. We designed our due diligence measures to conform, in all material respects, to the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition), including the related supplements on tin, tantalum, tungsten, and gold specifically as such supplements relate to our position in the supply chain as a downstream company (the “OECD Guidance”).

Scope of Due Diligence. We conducted due diligence on the source and chain of custody of the necessary Conflict Minerals with the objective of determining the origin of the necessary Conflict Minerals contained in the Covered Products, and whether such Conflict Minerals directly or indirectly financed or benefited Armed Groups, as defined in the Rule. We began our due diligence in October 2023, and it was substantially complete by the end of March 2024. We made resources available to support the due diligence process.

Our supply chain regarding the Covered Products is complex, and there are multiple parties in the supply chain between us and the original sources of Conflict Minerals. In this regard, we did not purchase necessary Conflict Minerals directly from SORs or mines. We rely primarily on our in-scope suppliers to provide information regarding the origin of the necessary Conflict Minerals included in the Covered Products. Moreover, we believe that SORs of Conflict Minerals are best situated to identify the sources of Conflict Minerals, and we took steps attempting to identify the specific SORs of necessary Conflict Minerals in our supply chain.

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Our due diligence process is based on seeking data from our direct suppliers, and those suppliers seeking similar information within their supply chains, to identify the specific SORs of the necessary Conflict Minerals contained in the Covered Products and ultimately the original sources of the necessary Conflict Minerals. As a downstream purchaser of Conflict Minerals, our due diligence measures can provide only reasonable, and not absolute, assurance regarding the source and chain of custody of such necessary Conflict Minerals. We also sent correspondence to verifiable SORs that were identified in the supply chain of any Covered Products and requested country of origin information for the necessary Conflict Minerals where such information was not provided by our supplier. However, we do not have any contractual leverage over such SORs because we do not purchase necessary Conflict Minerals directly from them.

The Company’s Covered Products Subject to Due Diligence. The Company conducted due diligence on Conflict Minerals contained in products: (i) for which Conflict Minerals are necessary to the functionality or production of those products; (ii) that were manufactured, or contracted to be manufactured, by us; (iii) for which the manufacture was completed during calendar year 2023; and (iv) with respect to Conflict Minerals in such products, for which we were unable to reasonably determine that all of the Conflict Minerals contained therein did not originate in the Covered Countries (or did come from recycled or scrap sources) (the “Covered Products”). The Covered Products include the following:

Description of Due Diligence Performed. Below is a description of the measures we performed for the reporting period to exercise due diligence on the source and chain of custody of the necessary Conflict Minerals in the Covered Products.

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OECD Guidance Step 1: Establish Strong Company Management Systems.

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OECD Guidance Step 2: Identify and Assess Risks in the Supply Chain.

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Where in-scope suppliers provided a CMRT that we considered to contain red flags, we sent follow-up communications requesting an explanation or elimination of any red flag.

OECD Guidance Step 3: Design and Implement a Strategy to Respond to Identified Risks.

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In addition, we also executed corrective action plans for suppliers who indicated that Conflict Minerals contained in the parts or materials supplied to us may have originated from the Covered Countries from SORs that were not listed as conformant or active by RMAP. Those corrective action plans included engaging with such suppliers to determine specific information about (i) the Conflict Minerals contained in the part(s) or material(s), (ii) the name and location of the SOR(s) where the Conflict Minerals were processed, and (iii) the name and location of the mine(s) where the Conflict Minerals were extracted.

As part of our risk management plan, the Company also distributed training materials to identified in-scope suppliers to: (i) reinforce the requirements of the Rule; (ii) communicate our Purchase Order Terms and our Policy; (iii) request in-scope suppliers to encourage SORs in our supply chain to become conformant under the RMAP; (iv) notify suppliers of our Conflict Minerals grievance process; and (v) encourage suppliers to join industry initiatives to assist in due diligence. In addition, we distributed training materials to business unit personnel to reinforce the requirements of the Rule, our due diligence process, and our risk management plan.

If the supplier responded on the CMRT and indicated that it had not adopted a Conflict Minerals Policy, we requested, through separate follow-up communication, that the supplier adopt and post such a policy to its website. In addition to monitoring and tracking our suppliers for adoption of a Conflict Minerals Policy, we also monitored and tracked SORs and SOR improvements through our membership in RMI.

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OECD Guidance Step 4: Carry Out Independent Third-Party Audit of SOR Due Diligence Practices.

We therefore primarily relied on the RMAP to coordinate third-party audits of SORs’ due diligence activities. We relied on the results of the RMAP third-party audits available publicly and through our RMI membership to validate the sourcing practices of SORs in our supply chain. However, we did request that our in-scope suppliers encourage SORs in our Conflict Minerals supply chain to undergo an audit in accordance with the RMAP. In addition, we supported the RMAP through our membership in RMI. We also participated in certain Conflict Minerals meetings and training sessions, including with RMI’s Due Diligence Practices Team and the Automotive Industry Action Group.

OECD Guidance Step 5: Report Annually on Supply Chain Due Diligence.

Conclusions of Due Diligence

After exercising the due diligence described above, we were unable to reasonably determine that all of the Conflict Minerals contained in the Covered Products did not originate from the Covered Countries (or did come from recycled or scrap sources). We were unable to determine all of the specific SORs that processed the Conflict Minerals in these Covered Products, and we were unable to determine all of the countries of origin and the specific mines or locations of origin with respect to all of the Conflict Minerals contained in the Covered Products. Many respondents did not provide verifiable SOR information or responded at a company-wide level which did not allow us to conclude that the Conflict Minerals were processed by any particular SOR.

Based on the information provided by our suppliers, we believe, to the extent reasonably known, that some of the facilities used to process some of the Conflict Minerals in our Covered Products include the SORs listed below. We do not believe that the below list represents all of the SORs that processed Conflict Minerals in our Covered Products in the reporting period. Rather, it represents only those SORs that we could reasonably verify as related to our specific Covered Products based on our suppliers’ responses. All SORs on this list are named as smelters or refiners by RMI:

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We leveraged our access to level sourcing information provided by our membership in RMI for any Conflict Minerals processed by verifiable SORs listed in the above table where country of origin or recycled/scrap designations were not provided by suppliers’ responses on the CMRT or verifiable SORs. We also leveraged our access to RMI’s level sourcing information where we knew Conflict Minerals were contained in our Covered Products, but were unable to conclude that any particular verifiable SOR processed such Conflict Minerals in our Covered Products. Based on RMI’s level sourcing information, the origin of these Conflict Minerals may have included the following:

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The level sourcing information provided above is in aggregate form and is derived from information made available by RMI to its members. Except for the DRC, RMI does not indicate individual countries of origin of the Conflict Minerals processed by conformant SORs.

Our efforts to determine country of origin, the mine, and location of origin of the necessary Conflict Minerals in the Covered Products with the greatest possible specificity consisted of the due diligence measures described in this Report. The Covered Products are often composed of multiple component parts containing one or more Conflict Minerals. We do not have sufficient information to determine the country of origin, the mine, or location of origin of all of the Conflict Minerals in all of the component parts in any Covered Product. As a result, we cannot conclusively determine the country of origin, the mine, or location of origin of all of the Conflict Minerals in any individual Covered Product or whether the manufacture of such Covered Product directly or indirectly financed or benefited Armed Groups in the Covered Countries.

Independent Private Sector Audit

Consistent with the provisions of the Rule, the SEC’s ‘‘Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule’’ dated April 29, 2014, and the SEC’s Order Issuing Stay dated May 2, 2014, this Report has not been audited by a third party. Notwithstanding anything to the contrary in this Report, for purposes of clarification and without limitation, we are not claiming, nor are we implying, that any of our Covered Products are “DRC Conflict-Free.” An audit is not required for the reporting period from January 1, 2023 to December 31, 2023.

Improvements to Due Diligence

We expect to take the following steps to improve our due diligence measures:

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Caution Concerning Forward-Looking Statements

Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “plans,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict, including but not limited to, our ability to constructively work with our suppliers to achieve compliance with our Policy and Purchase Order Terms, our ability to obtain complete and accurate information from our suppliers, our ability to provide training to in-scope suppliers, our ability to engage with in-scope suppliers to implement responsible sourcing, our ability to improve the efficiency and effectiveness of our due diligence measures, our ability to identify and constructively engage with SORs in our supply chain, changes in our supply chain, changes to the parts or materials used by or supplied to us, changes in SORs, changes in country of origin information of the necessary Conflict Minerals received from our suppliers, and changes in the Rule and other political and regulatory developments relating to the sourcing of Conflict Minerals, whether in the Covered Countries or elsewhere. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made, and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.

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