SEC Form SD filed by Global Payments Inc.

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

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FORM SD

Specialized Disclosure Report

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Global Payments Inc.

(Exact name of registrant as specified in its charter)

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Check the appropriate box to indicate the rule pursuant to which this form is being submitted, and provide the period to which the information in this Form applies:

Conflict Minerals Disclosure

Based in Atlanta, Georgia, and traded on the New York Stock Exchange under the symbol “GPN,” Global Payments Inc. (“Global Payments” or the “Company”) is a leading payments technology company delivering innovative software and services to customers globally. Global Payments’ technologies, services and team member expertise allow it to provide a broad range of solutions that enable its customers to operate their businesses more efficiently across a variety of channels around the world.

Summary

Based on the Company’s reasonable country of origin inquiry (“RCOI”) and the procedures described in this Form SD, the Company has determined that, with respect to the products required to be reported by this Form SD for the period from January 1, 2024 to December 31, 2024 (the “Reporting Period”), the Company has no reason to believe that any conflict minerals that are necessary to the functionality or production of such products may have originated in the Democratic Republic of the Congo or an adjoining country (collectively the “Covered Countries”), as those terms are defined by the Securities and Exchange Commission.

Reasonable Country of Origin Inquiry

The Company follows a conflict minerals policy and related procedures focused on its commitment to sourcing components and materials from suppliers that share the Company’s ethical values and that support compliance with the Securities and Exchange Commission’s regulations as well as the Company’s disclosure obligations related to conflict minerals. These policies and related procedures have guided the Company’s continued development and deployment of internal systems, supply chain due diligence efforts and, ultimately, the Company’s RCOI conducted in connection with this Form SD.

Throughout 2024, the Company’s conflict minerals efforts, and RCOI process, were designed to confirm conflict mineral content in the products the Company contracted to manufacture, further obtain transparency into its product supply chain for such products, and, more generally, to increase engagement from its suppliers concerning conflict minerals issues. The specific goal of the Company’s RCOI was to determine whether the conflict minerals in its relevant products originated in the Covered Countries. In part, the Company’s 2024 RCOI process included:

Specifically, the Company arrived at the determination described in this Form SD by conducting, in good faith, its RCOI regarding the conflict minerals that (i) the Company identified as necessary to the functionality or the production of the products that it contracted to have manufactured and (ii) were subject to review in the Reporting Period. For purposes of the Company’s conflict minerals analysis in this Form SD, the Company considered the specific products that the Company contracted to manufacture for which the manufacturing process was completed during the Reporting Period. Therefore, in connection with this Form SD, the term “Completed Products” refers to the specific products that the Company contracted to manufacture, and the manufacturing process was completed during the Reporting Period.

The Company does not directly purchase any conflict minerals, nor does the Company have any direct relationship with any mines or smelters that process these minerals. As part of the RCOI, the Company identified its suppliers that delivered products, materials or supplies to the Company from January 1, 2024 through December 31, 2024, and surveyed these suppliers soliciting information concerning the presence, if any, and source, of conflict minerals in the items supplied to the Company. The Company also required its direct suppliers of materials for covered products to complete certifications concerning their manufacturing practices and the materials they supply to the Company. In connection with this process and pursuant to further inquiries by the Company’s internal working group, the Company was able to determine that the suppliers whose products were included in the Company’s Completed Products either did not provide conflict minerals or did not provide the Company with a reason to believe that the conflict minerals contained in such products originated in the Covered Countries.

Determination

Based on the results of the Company’s RCOI, the Company has determined that, with respect to necessary conflict minerals in its Completed Products, the Company has no reason to believe that these conflict minerals may have originated in the Covered Countries.

Additional Information

A copy of our conflict minerals policy can be found at investors.globalpayments.com, under “Governance-Governance Documents”, and the information contained in this Form SD can be found at investors.globalpayments.com, under “Financial Info-All SEC Filings,” but the contents of our website are not incorporated by reference into, and are not otherwise a part of, this Form SD.

This Form SD contains statements that are forward-looking, as that term is defined by the Private Securities Litigation Reform Act of 1995 or by the SEC in its rules, regulations and releases. Forward-looking statements also include any statement that is not based on historical fact, including statements containing the words “believes,” “anticipates,” “expects,” “intends,” “plan,” “forecast,” “guidance,” and similar expressions. The Company intends that such forward-looking statements be subject to the safe harbors created thereby. All forward-looking statements are based on current expectations regarding important risk factors and should not be regarded as a representation by the Company or any other person that the results expressed therein will be achieved. The Company assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law. Important factors that could cause actual outcomes to differ materially from those contained in any forward-looking statement include those described in the Company’s reports, including its Form 10-K for the fiscal year ended December 31, 2024 and other forms filed by the Company with the SEC.

Not applicable.

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Not applicable.

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.