ASE Technology : ASEH CM Report 2023

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

ASE Technology Holding Co., Ltd.

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

Taiwan, Republic of China	001-16125
(State or other jurisdiction of incorporation)	(Commission file number)
26, Chin 3rd Rd., Nanzih Dist.,
Kaohsiung, Taiwan, Republic of China
(Address of principal executive offices)	(Zip code)

Joseph Tung, [phone]

(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:

• Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.

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Section 1 - Conflict Minerals Disclosure

Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

Our Form SD and our Conflict Minerals Report for the year ended December 31, 2023 filed as Exhibit 1.01 to this Form SD are available at

https://www.aseglobal.com/csr/responsible-procurement/conflict-minerals-compliance

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Section 2 - Exhibits

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2023 to December 31, 2023

* * * * *

	SIGNATURE
ASE Technology Holding Co., Ltd.
By: /s/ Jason C.S. Chang	Date: May 31, 2024
Jason C.S. Chang
Principal Executive Officer

	EXHIBIT INDEX
Exhibit	Description
Number
1.01	Conflict Minerals Report for the reporting period January 1, 2023 to December 31, 2023

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Exhibit 1.01

ASE Technology Holding Co., Ltd.

Conflict Minerals Report

For the year ended December 31, 2023

Corporate Overview

ASE Technology Holding Co., Ltd. ("ASEH", "we", "our", or "us") is the leading provider of semiconductor manufacturing services in assembly and testing, and the provider of electronic manufacturing services. ASEH packages bare semiconductors into finished semiconductors with enhanced electrical and thermal characteristics; provides testing services, including front-end engineering testing, wafer probing and final testing services; engages in the designing, assembling, manufacturing and sale of electronic components and telecommunications equipment motherboards and substrate production.

We have manufacturing facilities located in Taiwan, China, Malaysia, Japan, Singapore, South Korea and the United States of America that provide packaging, testing and materials design and production services to many semiconductor companies around the world. A typical customer engagement involves receiving consigned silicon wafers from the customer, performing a series of manufacturing services to the wafers, and delivering a completed, packaged integrated circuit back to the customer.

We provide a broad range of electronic manufacturing services to a global customer base through USI Inc. and its subsidiaries (collectively "USI") with facilities located in Taiwan, China, Mexico, Poland, Vietnam, Africa, and Europe. In providing these services, we acquire numerous electronic and non-electronic components, and assemble them into sub-assemblies and finished products.

Product Scope

ASEH provides solutions, including integrated design, manufacturing, packaging, testing, and electronic and substrate manufacturing. Raw materials used in aforementioned service or product provided by us are in the scope of this report. We determine gold, tin, tungsten or tantalum ("3TG" or "conflict minerals") are "necessary to the functionality or production" of a product manufactured or contracted to be manufactured by ASEH.

1. For our packaging and materials design and production services, we typically add gold and tin as direct materials in the manufacturing process, and we occasionally add tungsten and tantalum. We do not use gold, tin, tungsten or tantalum in our testing services.
2. For our electronic manufacturing services, typical materials and components which we utilize

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include solder (tin based), electrolytic capacitors (tantalum bearing), integrated circuits (gold wire) and high temperature wires (tungsten). Gold, tin, tungsten and tantalum are essential to our electronic manufacturing services.

All packaging, materials design and production and electronic manufacturing services we provide contain one or more of the conflict minerals: gold, tin, tungsten or tantalum.

Reasonable Country of Origin Inquiry

We conducted a reasonable country of origin inquiry ("RCOI") to determine whether 3TG have originated in the Democratic Republic of the Congo ("DRC") or its adjoining countries (the "Covered Countries"), or are from recycled or scrap sources. Our RCOI included to:

1. Identify our suppliers who provided us with materials containing 3TG and then use the Conflict Minerals Reporting Template ("CMRT") developed by the Responsible Minerals Initiative ("RMI") to facilitate transparency of the supply chain regarding 3TG sourced from the smelters and refiners. We identified 389 suppliers in the reporting period and used the CMRTs to identify the Smelters or Refiners ("SoRs") of 3TG and their origin countries.
2. 1. For our packaging and materials design and production services, a total of 170 suppliers provided us with materials containing 3TG.
   2. For our electronic manufacturing services, we selected 219 suppliers from a total of 4,360 suppliers who provided us with materials containing metals by the following assessment criteria: (1) the suppliers with purchase amounts greater than US$1.2 million in 2023, which in aggregate accounted for more than 90% of our total purchase amount, and (2) the suppliers whose conflict minerals are used in the services we provide to our top one customer.
3. Confirm with our suppliers that they are in compliance with our conflict minerals policy and their covenant to disclose the source information of the smelters and refiners under the representation letters.

Based on our RCOI results, we have reason to believe that the conflict minerals in our products may have originated in the Covered Countries and conflict-affected and high-risk areas ("CAHRA") or may not come from recycled or scrap sources. Therefore, we conducted due diligence on the source and chain of custody of the conflict minerals in our products.

Below are the results of our RCOI.

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Packaging and Materials Design and Production Services

Gold

During 2023, we purchased gold for our packaging and materials design and production services from a total of 83 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from third parties. Based on the CMRTs we collected, we identified a total of 88 SoRs from which we indirectly purchased gold in 2023 for our packaging and materials design and production services. All 83 of our gold suppliers for our packaging and materials design and production services responded to our request to identify the SoRs from which they sourced gold during 2023, representing 100% of our total gold expenditure.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 88 SoRs from which we indirectly purchased gold in 2023 for our packaging and materials design and production services are participants in at least one of (i) the Responsible Minerals Assurance Process ("RMAP") operated by RMI, (ii) the Gold Industry-London Bullion Market Association ("LBMA"), or (iii) the Gold Industry- Responsible Jewellery Council ("RJC").

Tin

During 2023, we purchased tin for our packaging and materials design and production services from a total of 96 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on the CMRTs we collected, we identified a total of 63 SoRs from which we indirectly purchased tin in 2023 for our packaging and materials design and production services. All 96 of our tin suppliers for our packaging and materials design and production services responded to our request to identify the SoRs from which they sourced tin during 2023, representing 100% of our total tin expenditure.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 63 SoRs from which we indirectly purchased tin in 2023 for our packaging and materials design and production services are participants in the RMAP operated by RMI.

Tungsten

During 2023, we purchased tungsten for our packaging and materials design and production services from a total of 17 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tungsten from SoRs or from other third parties. Based on the CMRTs we collected, we identified 31 SoRs from which we indirectly purchased tungsten for our packaging and materials design and production services in 2023. All 17 of our tungsten suppliers for our packaging and materials design and production services responded to our request to identify the SoRs from which

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they sourced tungsten during 2023, representing 100% of our total tungsten expenditure.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 31 SoRs from which we indirectly purchased tungsten for our packaging and materials design and production services in 2023 are participants in the RMAP operated by RMI or participants in the Tungsten Industry-Conflict Minerals Council ("TI-CMC").

Tantalum

During 2023, we purchased tantalum for our packaging and materials design and production services from 7 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on the CMRTs we collected, we identified a total of 28 SoRs from which we indirectly purchased tantalum in 2023 for our packaging and materials design and production services. All 7 of our tantalum suppliers for our packaging and materials design and production services responded to our request to identify the SoRs from which they sourced tantalum during 2023, representing 100% of our total tantalum expenditure.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 28 of the SoRs from which we indirectly purchased tantalum in 2023 for our packaging and materials design and production services are participants in the RMAP operated by RMI.

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Electronic Manufacturing Services

During 2023, we selected 219 suppliers from a total of 4,360 suppliers for our electronic manufacturing services for the purpose of identifying SoRs. The 219 suppliers were selected based on the assessment criteria mentioned in the section entitled RCOI.

Gold

Among the 219 selected suppliers, we purchased gold for our electronic manufacturing services from 171 suppliers in 2023. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from other third parties. Based on the CMRTs we collected, we identified 94 SoRs from which we indirectly purchased gold for our electronic manufacturing services. All 171 gold suppliers responded to our request to identify the SoRs from which they sourced gold during 2023.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 94 SoRs from which we indirectly purchased gold for our electronic manufacturing services in 2023 are participants in at least one of (i) the RMAP operated by RMI, (ii) the LBMA, or (iii) the RJC.

Tin

Among the 219 selected suppliers, we purchased tin for our electronic manufacturing services from 182 suppliers in 2023. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on the CMRTs we collected, we identified 68 SoRs from which we indirectly purchased tin for our electronic manufacturing services. All 182 tin suppliers responded to our request to identify the SoRs from which they sourced tin during 2023.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 68 SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2023 are participants in the RMAP operated by RMI.

Tungsten

Among the 219 selected suppliers, we purchased tungsten for our electronic manufacturing services from 101 suppliers in 2023. None of these suppliers are SoRs, and all these suppliers purchased tungsten from SoRs or from other third parties. Based on the CMRTs we collected, we identified 33 SoRs from which we indirectly purchased tungsten for our electronic manufacturing services. All 101 tungsten suppliers responded to our request to identify the SoRs from which they sourced tungsten during 2023.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 33 SoRs from which we indirectly purchased tungsten for our

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electronic manufacturing services in 2023 are participants in either the RMAP operated by RMI or the TI-CMC program.

Tantalum

Among the 219 selected suppliers, we purchased tantalum for our electronic manufacturing services from 85 suppliers in 2023. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on the CMRTs we collected, we identified 35 SoRs from which we indirectly purchased tantalum for our electronic manufacturing services. All 85 tantalum suppliers responded to our request to identify the SoRs from which they sourced tantalum during 2023.

Based on an inspection of the list available at https://www.responsiblemineralsinitiative.org conducted on December 31, 2023, all 35 SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2023 are participants in the RMAP operated by RMI.

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Part I. Due Diligence

Design of Due Diligence

ASEH designed its due diligence measures to conform to the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (the "OECD Guidance"), including the related supplements on gold, tin, tantalum and tungsten.

Due Diligence Measures Performed

OECD Step 1	Establish strong company management systems
A. Adopt and clearly	The ASE Technology Holding Co., Ltd. Corporate Policy for Sourcing
communicate to	Conflict Minerals is posted on our website (and attached here as Annex A) to
suppliers and public	address our commitment to exercise due diligence in accordance with the
	OECD Guidance.
	Additionally, we distribute our conflict minerals policy to each of our
	suppliers of conflict minerals who must agree that the policy will be complied
	with and require each supplier to certify they understand our conflict
	minerals policy and will comply with its covenants.
B. Structure internal	Our conflict minerals management team is a comprehensive cross-
management to	functional team under the direction of ASEH's Corporate Sustainability
support due diligence	Committee which is chaired by our Principal Executive Officer.
	The team is responsible for implementing the conflict minerals
	compliance mechanism, including planning, analysis, tracking, monitoring,
	and communication and reporting for the business wide initiative.
C. Establish a system	Conflict minerals procedures are documented in our specifications
of controls and
system and managed by our conflict minerals management team. The bills-
transparency over the
of-materials required for different customer products across all
mineral supply chain	manufacturing operations are controlled by our manufacturing execution
	system software.
	The primary method for gathering conflict mineral data is through the
	deployment and gathering of Responsible Minerals Initiative ("RMI"), which
	is developed by Conflict Minerals Reporting Template ("CMRT"). We store
	such data and maintain other related records for a minimum of five years in a
	comprehensive filing system.
	Aligned with industry practice, we utilize a conflict minerals data tool to
	manage a large number of suppliers' CMRTs, auto-validates smelter status
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