UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

SCHLUMBERGER N.V.

(SCHLUMBERGER LIMITED)

(Exact name of registrant as specified in its charter)

Dianne B. Ralston

Chief Legal Officer and Secretary

(713) 513-2000

(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

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit

Conflict Minerals Disclosure

In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, Schlumberger Limited (the “Company”) has filed this Specialized Disclosure Report and the Conflict Minerals Report attached hereto as Exhibit 1.01 for the year ended December 31, 2023. Both of these documents are publicly available on the Company’s website at:

https://www.slb.com/about/who-we-are/conflict-minerals.*

Section 3 – Exhibits

Item 3.01 Exhibits

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

* * * * *

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.

Date: May 30, 2024

Exhibit 1.01

Conflict Minerals Report

SLB - For Year Ending December 31, 2023

Company Overview

This report has been prepared by the management of Schlumberger Limited (herein referred to as “SLB,” the “Company,” “we,” “us,” or “our”) pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2023, to December 31, 2023.

SLB is a global technology company focused on driving energy innovation for a balanced planet. With a global presence in more than 100 countries and employees representing almost twice as many nationalities, SLB works each day on innovating oil and gas, delivering digital at scale, decarbonizing industries, and developing and scaling new energy systems that accelerate the energy transition.

Introduction

For the 2023 calendar year, SLB determined that tin, tungsten, tantalum, and/or gold (3TGs) were necessary to the functionality or production of some products that were manufactured or contracted to be manufactured. Therefore, SLB 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”).

Based on the country of origin data, SLB believes some of 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”).

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

Conflict Minerals Program & Policy

The Company has actively engaged with its customers and suppliers for several years with respect to the use of conflict minerals. SLB adopted a conflict minerals policy (the “Conflict Minerals Policy”) articulating the conflict minerals supply chain due diligence process and the Company’s commitments to reporting obligations regarding conflict minerals. The Conflict Minerals Policy is available online and can be found here: https://www.slb.com/about/who-we-are/conflict-minerals.

Description of Products

Only some of SLB’s products fall in scope of the Rule, as they contain (or may contain) one or more of the 3TGs. The following list is an example of products that contain, or may contain, 3TGs:

Permanent multiphase meters; subsea safety valves; oil, gas and core analysis laboratory equipment; perforating hardware and accessories; downhole drilling tools; solids and pressure control equipment for drilling fluids systems; equipment for chemical packages; data acquisition equipment for drilling operations; surface and downhole completions tools; artificial lift pumps; stimulation pumping and cementing equipment; groundwater monitoring products; drilling equipment packages; blowout preventers; drilling risers, top drives; draw works; complete wellhead and Christmas tree systems for onshore and offshore applications; subsea production systems and manifolds and aftermarket parts; valves; actuators; chokes and aftermarket parts; heaters; dehydration and desalting units; gas conditioning units; membrane separation systems; water processing systems; and electronic controls.

Reasonable Country of Origin Inquiry

To determine whether necessary 3TGs in products originated in Conflict-Affected and High-Risk Areas, SLB retained a third-party service provider to assist us in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to its third-party service provider for upload to its third-party service provider’s platform.

To trace materials, and demonstrate transparency procured by the supply chain, SLB utilized the Conflict Minerals Reporting Template (CMRT) Version 6.31 or higher to conduct a survey of all in-scope suppliers. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide material to a manufacturer’s supply chain. It includes questions about a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters/refiners as well as the origin of 3TGs used by those facilities.

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During the supplier survey, the Company contacted suppliers via its third-party service provider’s platform, a software-as-a-service (SaaS) platform provided by the third-party service provider that enables its users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The third-party service provider’s platform 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 third-party service provider’s platform and team, the Company then requested that all identified suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. The third-party service provider monitored and tracked all communications in the third-party service provider’s platform for future reporting and transparency. SLB directly contacted suppliers that were unresponsive to the third-party service provider’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to the third-party service provider.

The Company’s program continues to include automated data validation on all submitted CMRTs. Data validation aims 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 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 forms are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors. Suppliers are contacted by the third-party service provider regarding invalid forms and are encouraged to correct validated errors to resubmit a valid form. Suppliers are also 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 the third-party service provider’s multilingual supplier experience team.

For reporting year 2023, there were 4,208 suppliers in scope of the conflict minerals program and 2,741 provided a completed CMRT. SLB’s total response rate for this reporting year was 65%.

Due Diligence

Design of Due Diligence

SLB 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.

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.

Due Diligence Performed

1. Establish Strong Company Management Systems

Internal Compliance Team

SLB established a cross-functional core team consisting of representatives of the business lines, planning and supply chain, legal, compliance, sustainability, and information technology functions. The core team is responsible for implementing the conflict minerals compliance strategy and briefing their respective Division Presidents or, in certain cases, Basin Presidents, about the results of these due diligence efforts on a regular basis.

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

The Company leverages the third-party service provider’s platform to work with dedicated program specialists who support SLB’s conflict minerals program. The Company communicates regularly with the third-party service provider’s team in order to receive updates on program status. Each member of the third-party service provider’s customer success team is trained in conflict minerals compliance and understands the intricacies of reporting templates such as CMRT and conflict minerals reports, as well as Section 1502 of the Dodd-Frank Act.

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Control Systems

The Company expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to SLB 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. The Company 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.

Additionally, we have (a) adopted various processes related to our conflict minerals compliance efforts and determinations; (b) adopted standardized data templates for all Divisions to promote consistency across various information technology systems; (c) adopted a procedure in our engineering design and manufacturing systems that requires the recording of necessary conflict mineral contents of newly-developed parts included in our products; (d) adopted an electronic repository to retain relevant documentation concerning our conflict minerals compliance efforts and determinations; and (e) adopted written summaries, reviewed by the President of each relevant Division, summarizing how each such Division complied with the Rule and which of its products were subject to the Rule. In addition, certain employees from our planning and supply chain, legal, engineering, manufacturing, sustaining, sales, finance, and compliance functions are targeted for annual training.

Supplier Engagement

SLB has a strong relationship with Tier 1 direct suppliers. As an important part of the supply chain, SLB has leveraged processes and educational opportunities in order to ensure all suppliers have access to a free platform to upload their CMRTs, help desk support, and other multilingual resources. SLB’s suppliers are able to leverage the third-party service provider’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete a CMRT. Suppliers are provided guidance in their native language by the third-party service provider, if needed.

As a downstream company, we are several tiers removed from conflict mineral smelters/refiners. We, therefore, must rely on information from industry sources to compare and assess due diligence responses, identify smelters/refiners in our supply chains and improve our ongoing due diligence efforts. We implemented a supply chain transparency system through the use of due diligence tools developed by the Responsible Minerals Initiative (“RMI”), including the RMI Conflict Minerals Reporting Template (“RMI Template”), which is designed to identify the smelters/refiners that process the conflict minerals in a company’s supply chain. We also support our suppliers’ use of validation, certification and audit programs on smelters/refiners upstream in our supply chain, such as:

The Company engages with suppliers directly to request a valid (free of validated errors) CMRT for the products that they supply to the Company. Feedback from this engagement process has allowed the Company to oversee improvements in supplier responses and supplier compliance for this initiative.

Additionally, SLB’s Conflict Minerals Policy is included in supplier contracts, requiring new suppliers to read and accept the policy as a requirement of doing business with SLB. The Company continues to place a strong emphasis on supplier education and training. To accomplish this, the third-party service provider’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources. Also, the third-party service provider’s automated feedback process that notifies suppliers of risks associated with their CMRT submission serves to educate suppliers of certain conflict minerals’ risks.

The Company believes that the combination of the SLB Code of Conduct, Conflict Minerals Policy, and direct engagement with suppliers for conflict minerals training and support constitute a strong supplier engagement program.

Grievance Mechanisms

The Company has established multiple longstanding grievance mechanisms as described in our Code of Conduct whereby employees and others can anonymously report violations of SLB’s policies, including conflict minerals. We communicate these mechanisms to our employees at various times.

Violations or grievances can be reported via the SLB EthicsLine. This can be done via phone or by filing the report online at: https://www.slb.com/about/who-we-are/our-code-of-conduct.

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2. Identifying & Assessing Risk in the Supply Chain

Supplier Risk Evaluation

In order to identify and assess the risks in our supply chain, we first identified products for sale that we manufactured or contracted to manufacture in 2023 that contained, or that may have contained, necessary conflict minerals. We have adopted a procedure in our engineering design and manufacturing system that is reasonably designed to identify each necessary conflict mineral included in our products. In cases where we determined that a necessary conflict mineral was contained in one of our parts, we identified that specific mineral and flagged both the part and finished product containing that part in our system. If, after our initial research, we were unable to determine whether a necessary conflict mineral was included in a part, we considered that part to be in scope of the Rule, and such part was internally flagged for additional research. For each new part developed or manufactured in 2023, the engineers and métiers in charge of providing materials for such part were required to indicate any necessary conflict minerals included in the part. Where we determined that a newly developed part contained a necessary conflict mineral and that the finished product was in scope of the Rule, we included that part in our further information-gathering efforts. We then identified our Tier 1 suppliers that supplied us with the parts and products considered to be within the scope of the Rule.

Because we are several tiers removed from mining operations and smelters/refiners, we must rely on our suppliers to provide information regarding the source and presence of necessary conflict minerals in our products.

Risks associated with Tier 1 suppliers’ due diligence processes were assessed by their declaration responses on a CMRT, which the third-party service provider’s platform identifies automatically based on established criteria. These risks are addressed by the third-party service provider’s staff and members of the Company’s core team, 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, SLB is unable to determine if all of the specified smelters/refiners were used for 3TGs in the products supplied to the Company.

The third-party service provider’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 takes into account 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. The third-party service provider’s smelter validation program compared listed facilities into 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.

The third-party service provider determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the RMAP. SLB 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. The third-party service provider uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

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Risk mitigation activities are initiated whenever a supplier’s CMRT reports facilities of concern. Through the third-party service provider, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing suppliers to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to SLB. 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 ultimate 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

Together with the third-party service provider, SLB developed processes to assess and respond to the risks identified in the supply chain. SLB has created a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are 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.

For any smelters/refiners known to source conflict minerals from Covered Countries, as well as smelters/refiners located in any Covered Country with unknown sources of conflict minerals, SLB has provided feedback to its suppliers through the third-party service provider, instructing suppliers to take their own independent risk analysis and mitigation actions. Additionally, in 2024, we will continually engage with our Tier 1 suppliers, who may have sourced from such smelters/refiners, to use certified smelters or pursue an alternative source of conflict minerals, and participate in the RMI to support industry efforts to achieve supply chain transparency.

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, the Company will utilize available actions to respond to non-compliant suppliers as part of its overall procurement strategy. The results of the program and risk assessment are shared with the core team and the respective Division or Basin Presidents to ensure transparency within the Company.

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

SLB 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, the Company 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.

The third-party service provider aids us in verifying the information provided by our suppliers with respect to the smelters/refiners that they source from, and to review and confirm the validity of the RMAP, RJC, and LBMA certifications of those smelters/refiners. The third-party service provider directly engages smelters/refiners that are not currently enrolled in an industry recognized audit/assessment program to encourage their participation and for those smelters/refiners already conformant to the corresponding program’s standards, the third-party service provider thanks them for their efforts on behalf of its compliance partners.

5. Report Annually on Supply Chain Due Diligence

SLB has published a Form SD and this report for the year ended December 31, 2023, which is available on the Company’s website at https://www.slb.com/about/who-we-are/conflict-minerals. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. SLB has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission (SEC).

The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through public reports.

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Due Diligence Results

Supply Chain Outreach 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 SLB for the 2023 reporting year.

Supply Chain Outreach Metrics

Upstream Data Transparency

Appendix A includes all smelters/refiners that 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 actually processed the 3TGs contained in the Company’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.

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 the third-party service provider’s supply chain database (or other reasonable country of origin data, in the scenario SLB 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 the Company’s products.

Steps to Be Taken to Mitigate Risk

SLB has taken, or intends to take, various steps to improve the due diligence conducted for the 2023 reporting year, as part of its supply chain risk mitigation plans. For example, SLB continues to evaluate upstream sources through a broader set of tools to evaluate risk. These include, but are not limited to:

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Appendix A: Smelter List

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Appendix B: Countries of Origin

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