PSNYW Polestar Automotive Holding UK PLC

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

Polestar Automotive Holding UK PLC

(Exact Name of Registrant as Specified in Charter)

Assar Gabrielssons Väg 9

405 31 Gothenburg, Sweden

(Address of principal executive offices) (Zip Code)

Thomas Ingenlath

Chief Executive Officer

Tel: +1 551 284 9479

(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

A copy of the Conflict Minerals Report of Polestar Automotive Holding UK PLC (the “Company”) for the reporting period from January 1, 2023 to December 31, 2023 is filed as Exhibit 1.01 hereto.

The Company’s Conflict Minerals Report is also publicly available on the Company’s website at https://www.polestar.com/global/legal/ethics/. The reference to the Company’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD and the Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.

Item 1.02 Exhibit

The Company has filed, as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.

Section 2 – Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable

Section 3 – Exhibits

Item 3.01 Exhibits

2

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has caused this report to be signed on its behalf by the undersigned, hereunto duly authorized.

3

Exhibit 1.01

Polestar

Conflict Minerals Report by Polestar

For the Year Ending December 31, 2023

Company Overview

This report has been prepared by the management of Polestar Automotive Holding UK PLC (herein referred to as “Polestar,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated.

Polestar is determined to improve society by accelerating the shift to sustainable mobility. Polestar is a pure play, premium electric performance car brand headquartered in Sweden, designing products engineered to excite consumers and drive change. Polestar believes that it defines market-leading standards in design, innovation and sustainability. Polestar was established as a premium electric car brand by Volvo Cars and Geely in 2017. Polestar benefits from the technological, engineering and manufacturing capabilities of these established global car manufacturers. Polestar has a capital-efficient, asset-light business model.

Forward-Looking Statements

This Report includes statements that express Polestar’s opinions, expectations, beliefs, plans, objectives, assumptions or projections regarding future events or future results and therefore are, or may be deemed to be, “forward-looking statements” as defined in Section 27A of the U.S. Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, that involve significant risks and uncertainties. These forward-looking statements can generally be identified by the use of forward-looking terminology, including the terms “believes,” “estimates,” “anticipates,” “expects,” “seeks,” “projects,” “intends,” “plans,” “may,” “will” or “should” or, in each case, their negative or other variations or comparable terminology. These forward-looking statements include all matters that are not historical facts. They appear in a number of places throughout this Report and include statements regarding Polestar’s intentions, beliefs or current expectations concerning, among other things: the due diligence of suppliers, risk mitigation measures, and efforts to increase transparency through data collection and risk evaluation. These forward-looking statements involve a number of risks, uncertainties (some of which are beyond Polestar’s control) or other assumptions that may cause actual results or performance to be materially different from those expressed or implied by these forward-looking statements. These risks and uncertainties include, but are not limited to, those factors described in the section entitled “Risk Factors” and “Cautionary Note Regarding Forward-Looking Statements” in Polestar’s Form 20-F, and other documents filed, or to be filed, with the SEC by Polestar. Should one or more of these risks or uncertainties materialize, or should any of the assumptions prove incorrect, actual results may vary in material respects from those projected in these forward-looking statements. Polestar will not undertake any obligation to update or revise any forward-looking statements, whether as a result of new information, future events or otherwise, except as may be required under applicable securities laws.

Introduction

For the 2023 calendar year, Polestar determined that tin, tungsten, tantalum, and/or gold (3TGs) were necessary to the functionality or production of its Polestar 2, Polestar 3 and Polestar 4 product lines that were manufactured or contracted to be manufactured. Therefore, Polestar conducted a reasonable country of origin inquiry in good faith to determine whether any of the 3TGs in its products originated from Conflict-Affected and High-Risk Areas (CAHRAs), such as the Democratic Republic of the Congo (DRC) or an adjoining country (collectively referred to as the “Covered Countries”).

Internal Information - Polestar

Polestar

Based on the country of origin data, Polestar believes its products could contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), due diligence was performed on the source and chain of custody of the 3TGs in question to determine whether its products are “conflict free or responsibly sourced.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework of the Organization for Economic Co-Operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum, and tungsten (the “OECD Guidance”).

Polestar is committed to complying with the requirements and upholding responsible sourcing practices. As such the Company has put into place a robust due diligence program to help ensure its contributions to upholding human rights and responsible practices across the supply chain.

Conflict Minerals Program & Policy

The Company has actively engaged with suppliers with respect to the use of conflict minerals. Polestar adopted a Conflict Minerals Position articulating the conflict minerals supply chain due diligence process and the Company’s commitments to reporting obligations regarding conflict minerals. The Conflict Minerals Position is available online, and can be found here:

https://legal.polestar.com/global/ethics/

The Company has contributed to industry efforts to address conflict minerals through involvement on the Polestar Board and through serving as an active and affiliate member of the Responsible Business Alliance (RBA) and the Responsible Minerals Initiative (RMI). This engagement and the contributions made have helped develop standards, best practices, and tools that benefit all companies working to end the link between 3TGs and conflict in the DRC.

Reasonable Country of Origin Inquiry

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, Polestar retained Assent Inc. (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. Polestar provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager. To trace materials, and demonstrate transparency procured by the supply chain, Polestar utilized the Conflict Minerals Reporting Template (CMRT) Version 6.31 or higher to conduct a survey of all in-scope suppliers.

For the 2023 calendar year, Volvo Cars has manufactured Polestar cars and contracted the suppliers of components and parts used in Polestar 2 and 3, and Geely has manufactured and contracted the suppliers of components and parts used in Polestar 4. During the CMRT campaign 2023/2024 there were 2 suppliers, Polestar’s business partner Volvo Cars and Geely, in scope of the conflict minerals program/survey. Volvo Cars and Geely provided a completed CMRT. The Company’s total response rate for this reporting year was 100%.

In addition, Polestar conducted further actions to identify Tier 2 suppliers, which are Volvo Cars’ and Geely’s direct material suppliers, to track program gaps of Polestar 2,3 and 4 and discuss with our Tier 1 and business partners future improvement opportunities.

Internal Information - Polestar

Polestar

Polestar’s ambition is to use the Assent Compliance Manager, a software-as-a-service (SaaS) platform provided by Assent, as it enters into further agreements with other manufacturing business partners as well direct supplier sourcing.

The Assent Compliance Manager enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management.

The Assent Compliance Manager also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations, are managed through this platform.

Via the Assent Compliance Manager and Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the Assent Compliance Manager for future reporting and transparency. According to the process, Polestar will contact suppliers that are unresponsive to Assent’s communications during the diligence process and request these suppliers to complete the CMRT and submit it to Assent.

Polestar’s program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which helps identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of Tier 1 and Tier 2 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

All submitted declaration forms are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors (see Appendix C for CMRT validation criteria). Suppliers are contacted regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses, and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Polestar tracks program gaps to account for future improvement opportunities.

Through reasonable due diligence practices, Polestar was able to take advantage of a broader set of country-of-origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Polestar can determine all the possible countries minerals (such as 3TGs) used in its product originated from. As such, Polestar can then perform further due diligence on the source and chain of custody of the minerals in question.

Due Diligence

Polestar designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.

Internal Information - Polestar

Polestar

Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot be fully owned by the Company. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, risk gaps can be mitigated. This aligns with industry standards and market expectations for downstream companies’ due diligence.

1) Establish Strong Company Management Systems

Internal Compliance Team

Polestar has just finalized its conflict mineral campaign and has established a cross-functional Conflict Minerals Compliance Team led by our Inclusion Lead and our Supply Chain Inclusion Expert. The Conflict Minerals Compliance Team will be responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts.

Polestar also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that Polestar will undertake with suppliers and/or respective stakeholders about conflict minerals.

Polestar leverages Assent’s Managed Services to work with dedicated program specialists who support Polestar’s conflict minerals program. Polestar communicates regularly with the Assent team to receive updates on program status.

Control Systems

Polestar expects all of its manufacturers and suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Polestar are “conflict free or responsibly sourced.” This means that the products should not contain minerals (3TGs) sourced from areas that have been identified to be in the presence of widespread human rights abuses and violations of law either directly or indirectly. Polestar expects direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.

Polestar’s Supplier Code of Conduct applies to all direct suppliers and outlines certain expected behaviors and practices. This code of conduct is based on industry and internationally accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Code of Conduct for Business partners is provided to all direct suppliers. If a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. The Code of Conduct for Business partners is reviewed annually to ensure it continues to align with industry best practices.

For the 2023 calendar year, Volvo Cars has contracted the suppliers manufacturing components and materials used in Polestar 2 and 3, and these suppliers have by contracts agreed to adhere to Volvo’s Code of Conduct for Business partners, which contains similar principles as Polestar’s Code of Conduct for Business partners. Geely has contracted the suppliers manufacturing components and materials used in Polestar 4, and these suppliers have agreed to Polestar’s Code of Conduct for Business Partners. The supplier code of conduct can be found here: https://www.polestar.com/global/legal/ethics/

Supplier Engagement

Polestar has a strong relationship with Tier 1 direct suppliers Volvo Cars and Geely and is also, through Volvo Cars and Geely, identifying response status of Tier 2 suppliers. Polestar’s Tier 1 and Tier 2 suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete a CMRT. Tier 1 and Tier 2 suppliers are provided guidance in their native language, if needed.

Internal Information - Polestar

Polestar

For the 2023 calendar year, Polestar engaged with Volvo Cars and Geely directly to request a valid (free of validated errors) CMRT for the products that Volvo Cars and Geely supplies to Polestar. Polestar’s ambition is to engage with suppliers directly to request such CMRT for the products they supply to Polestar, as it enters into further direct supply agreements with other parties.

With respect to the OECD requirement to strengthen engagement with suppliers, Polestar will develop an internal procedure that includes a supplier risk identification process that then leads to further steps of supplier engagement in the form of escalations.

Additionally, the Company’s policy on conflict minerals is included in the Code of Conduct for Business Partners, which is part of supplier contracts, requiring new suppliers to read and accept the rules as a requirement of doing business with Polestar. When entering into or renewing supplier contracts, a clause is added that requires suppliers to provide information about the source of 3TGs and smelters.

Polestar places a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources will be leveraged, and all in-scope suppliers will be provided with access to their library of conflict minerals training and support resources. Also, Assent’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain conflict minerals’ risks.

Polestar believes that the combination of the Code of Conduct for Business partners, the Conflict Minerals Position, and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.

Grievance Mechanisms

Polestar established grievance mechanisms whereby employees, suppliers and others outside Polestar can report grievances, suspected violations or other concerns to the Company, including conflict minerals. Suppliers and others outside of Polestar can direct such reports via the whistleblowing channel SpeakUp, available in the Code of Conduct for Business partners, on Polestar’s external website and in other communications with suppliers. Please find link https://legal.polestar.com/global/ethics/

Violations or grievances at the industry level can be reported to the RMI directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/

Maintain Records

Polestar has a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. Polestar stores all the information and findings from this process in a database that can be audited by internal or external parties.

Internal Information - Polestar

Polestar

2) Identifying & Assessing Risk in the Supply Chain

Supplier Risk Evaluation

Risks associated with Tier 1 suppliers’ due diligence processes as well as to some extent Tier 2 suppliers is assessed by their declaration responses on a CMRT, which the Assent Compliance Manager identifies automatically based on established criteria. These risks are addressed by members of Polestars internal Conflict Minerals Team, in collaboration with Assent staff, who engage with suppliers to gather pertinent data and ask for corrective actions if needed, performing an overall assessment of the supplier’s conformity status, which is referred to as “conflict minerals status.”

Risks at the supplier level may include non-responsive suppliers or incomplete CMRTs. In cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Polestar is unable to determine if all the specified smelters/refiners were used for 3TGs in the products supplied to the Company.

Assent’s supplier risk assessment (flagging suppliers’ risk as high, medium, low) identifies problematic suppliers in a company’s supply chain. The risk assessment is derived from the smelter validation process, which establishes risk at the smelter level via an analysis that considers multiple conflict minerals factors.

Smelter/Refiners Risk Evaluation

Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters/refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent’s Smelter validation program compared listed facilities to the list of smelters/refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operational during the 2023 calendar year.

Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Polestar does not have a direct relationship with smelters/refiners and does not perform direct audits of these entities within their pre-supply chain.

Smelters that are conformant to RMAP audit standards are considered to have their sourcing validated as “conflict-free or responsibly sourced.” In cases where the smelter/refiner’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, further due diligence steps are followed to notify suppliers reporting these facilities. Smelters/refiners are actively monitored to proactively identify other risks pertaining to conflict minerals.

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing suppliers to take their own independent risk mitigation actions.

Internal Information - Polestar

Polestar

Examples include the submission of a product specific CMRT to better identify the connection to products that they supply to Polestar. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the goal of progressive elimination of these smelters of concern from the supply chain.

In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

3) Design & Implement A Strategy to Respond to Risks

Polestar, in consultation with Assent, has developed processes to assess and respond to the risks identified in the supply chain. Polestar has a risk management plan, through which the conflict minerals program will be implemented, managed, and monitored. As the program progresses, escalations will be sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and the Company’s expectations.

Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, Polestar will assess if replacing that supplier is feasible. The results of the program and risk assessment are shared with the Conflict Minerals Team and the Polestar’s Management Team to ensure transparency within the Company.

For the 2023 calendar year, Volvo Cars and Geely has contracted the suppliers manufacturing components and materials used in Polestar 2, 3 and 4 together with Volvo Cars’ and Geely, Polestar will discuss the outcome of conflict mineral reports and align necessary risk mitigation needed.

4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

Polestar does not have a direct relationship with any 3TG smelters/refiners and does not perform or direct audits of these entities within the supply chain. Instead, Polestar relies on third-party audits of smelters/refiners (industry recognized audit/assessment programs). As an example, RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters/refiners that agree to participate in the program.

Assent directly engages smelters/refiners that are not currently enrolled in an industry recognized audit/assessment program to encourage their participation. Smelters/refiners already conformant to the corresponding program’s standards, are complemented for their efforts. Polestar is a signatory of these communications in accordance with the requirements of downstream companies detailed in the OECD Guidance.

Through Polestar’s membership with the RMI, smelters/refiners have been encouraged to participate in the RMAP. Any smelters/refiners that were reported by suppliers who were not part of the RMAP were also contacted directly by Assent to encourage them to participate in the RMAP as stated earlier.

Internal Information - Polestar

Polestar

5) Report Annually on Supply Chain Due Diligence

Polestar is publishing the Conflict Mineral Report for the year ended December 31, 2023. This report will be made available in the Ethics section of Polestar’s website at https://www.polestar.com/global/legal/ethics/.

Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. Polestar has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission (SEC).

This year Polestar has also considered impacts from the EU Conflict Minerals Regulation when disclosing details with regards to due diligence efforts. Polestar will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public reporting.

Due Diligence Results

Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten, and gold. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by Polestar for the 2023 reporting year.

Supply Chain Outreach Metrics

Upstream Data Transparency

Appendix A includes all smelters/refiners that Tier 1 and Tier 2 suppliers listed in completed CMRTs that met the recognized definition of a 3TGs processing facility and were operational during the 2023 calendar year. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters/refiners have the practice to list all smelters/refiners they may purchase from within the reporting period. Therefore, the smelters/refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters/refiners which processed the 3TGs contained in Polestar’s products.

Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance, as stipulated in the previous sections.

Internal Information - Polestar

Polestar

Country of Origin

Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on reasonable identification of country-of-origin data obtained via Assent’s supply chain database (or other RCOI data, in the scenario Polestar decides to use alternative data sources). As mentioned in the above section, it is understood that overreporting might occur which could result in Appendix B having more countries than those strictly relevant to Polestar’s products. Smelters sourcing from the Russian Federation melters were identified as high-risk smelters during our CM due diligence.

Steps to Mitigate Risk

Polestar has taken, or intends to take, the following steps to improve the due diligence conducted to further mitigate the risk that the necessary 3TGs in Polestar’s products could originate from Conflict-Affected and High-Risk Areas:

Internal Information - Polestar

Polestar

Appendix A: Smelter List

Includes: mineral, smelter/refinery name, location

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Internal Information - Polestar

Polestar

Appendix B: Countries of Origin

Internal Information - Polestar

Polestar

Appendix C: CMRT Declaration Rejection/Approval Criteria

The following tables map the Assent Sustainability Platform’s status outputs and CMRT logic structure when determining supplier conflict mineral statuses as displayed on the dashboard. Using this table, and referencing the CMRT questions listed above, users will be able to determine what answers were provided by their suppliers to earn their conflict minerals statuses.

Internal Information - Polestar