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    SEC Form SD filed by A10 Networks Inc.

    5/22/25 4:06:25 PM ET
    $ATEN
    Computer Communications Equipment
    Telecommunications
    Get the next $ATEN alert in real time by email
    SD 1 formsd5222025.htm SD Document

    UNITED STATES
    SECURITIES AND EXCHANGE COMMISSION
    Washington, D.C. 20549

    ___________________________________________________________________________
    FORM SD

    Specialized Disclosure Report
    ___________________________________________________________________________
    a10logojpeg.jpg
    A10 NETWORKS, INC.
    (Exact name of the registrant as specified in its charter)
    ___________________________________________________________________________
    Delaware001-3634320-1446869
    (State or Other Jurisdiction of Incorporation or Organization)(Commission File Number)(I.R.S. Employer Identification Number)

    2300 Orchard Parkway
    San Jose, CA 95131
    (Address of principal executive offices, including zip code)

    Scott Weber (408) 325-8668
    (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:

    x
    Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2024.





    Section 1 - Conflict Minerals Disclosure

    Item 1.01 Conflict Minerals Disclosure and Report

    The Company has filed a Conflict Minerals Report filed as Exhibit 1.01 hereto and it is publicly available at https://investors.a10networks.com/corporate-governance/governance-documents/default.aspx. The content of our website as referred to in this Form SD is included for general information only and is not incorporated by reference into this Form SD.

    Conflict Minerals Disclosures

    (a)The Company conducted a Reasonable Country of Origin Inquiry (“RCOI”) as required by Item 1.01(a) of Form SD. The RCOI began with a multi-department initiative that scoped and evaluated the Company’s product line to determine which suppliers provide the Company with manufactured or contracted to be manufactured products. The Company then looked on a product-by-product level to determine which of these products were most likely to contain Conflict Minerals (as defined by the U.S. Securities and Exchange Commission) that are “necessary to the functionality or production” of the product, or are otherwise sourced from recycled or scrap materials. Suppliers of such products (other than those sourced from recycled or scrap materials) were next identified and surveyed using the basic EICC/GeSI Conflict Minerals Reporting Template or, where appropriate, a custom-designed form. Follow-up was undertaken with those suppliers who provided incomplete forms or were otherwise non-responsive. The Company then evaluated the information provided from suppliers to assess completeness and reliability of the data collected. On the basis of this inquiry and evaluation, the Company has no reason to believe that the Conflict Minerals contained in its products originated in the Democratic Republic of Congo or adjoining countries (the “Covered Countries”).

    (b)On the basis of its RCOI undertaking, the Company has no reason to believe that its necessary Conflict Minerals may have originated in the Covered Countries. Given that the results of its RCOI efforts were inconclusive, the Company proceeded to the due diligence stage of the inquiry as required by Form SD and has filed herewith a Conflict Minerals Report, which is attached as Exhibit 1.01 to this Form SD.

    Item 1.02 Exhibits

    A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto.

    Section 2 - Exhibits

    Item 2.01 Exhibits

    The following exhibit is filed as part of this report:

    Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2024 through December 31, 2024, as required by Items 1.01 and 1.02 of this Form.





    EXHIBIT INDEX

    Exhibit No.    Description
    1.01        Conflict Minerals Report for the reporting period January 1, 2024 through December 31, 2024.





    SIGNATURE

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


    A10 NETWORKS, INC.
    May 22, 2025
    By: /s/ Scott Weber
    Scott Weber
    General Counsel


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