Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

Introduction

ARM Holdings plc and its subsidiary companies (taken together, “ARM”) design microprocessors, physical IP and related technology and software, and sell development tools to enhance the performance, cost-effectiveness and energy efficiency of high-volume embedded applications. ARM licenses and sells its technology and products to leading international electronics companies, which in turn manufacture, market and sell microprocessors, application-specific integrated circuits, application-specific standard processors and microcontrollers based on ARM’s technology to systems companies for incorporation into a wide variety of end products. By creating a network of partners, and working with them to best utilize ARM’s technology, ARM is establishing its processor architecture and physical IP for use in many high-volume embedded microprocessor applications, including cellular phones, digital televisions, mobile computers and PC peripherals and for potential use in many growing markets, including smart cards and microcontrollers. ARM also licenses and sells development tools directly to systems companies and provides support services to its licensees, systems companies and other systems designers.

While ARM’s core business does not involve the manufacturing of physical products (either itself or by contracting third party manufacturers), ARM’s Development Solutions Group contracts for manufacture small numbers of various development boards, some of which are sold to customers. ARM does not itself manufacture such products and instead provides product and technical specifications (for example, which components are incorporated and which suppliers provide the components) to a small number of contract manufacturers. ARM estimates that the sale of such manufactured products represented substantially less than one percent of ARM’s revenues for the year ended December 31, 2015.

Certain of the products that ARM contracts for manufacture include “conflict minerals” as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”) that are necessary to the functionality or production of such products. As part of its corporate social responsibility policy, ARM’s policy for sourcing the components incorporated into the products ARM contracts to have manufactured includes using the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (“EICC forms”) to collect from its suppliers sourcing information relating to conflict minerals that those suppliers use (whether or not in the particular components ARM sources from any particular supplier). If any component that ARM specifies should be incorporated into the products to be manufactured for it is suspected to include conflict minerals sourced from the Democratic Republic of Congo or any adjoining countries, ARM would expect to take immediate actions and appropriate steps to eliminate such sources from its supply chain. The information received to date has not required ARM to change its sourcing suppliers and distributors due to concerns related to conflict minerals.

In addition to seeking to obtain completed EICC forms from all its suppliers, ARM’s approach to conflict minerals includes:

Reasonable Country of Origin Inquiry

The Dodd-Frank Act requires companies that file reports under the Securities and Exchange Act of 1934 and manufacture or contract to manufacture products for which conflict minerals are necessary to the functionality or production to undertake a reasonable country of origin inquiry. Section 1502 of the Dodd-Frank Act defines “conflict minerals” as columbite-tantalite, cassiterite, gold, wolframite or their derivatives tantalum, tin and tungsten. ARM has conducted, in good faith, a reasonable country of origin inquiry regarding the conflict minerals contained in its products contracted for manufacture for the year ended December 31, 2015.

From its engineering records, ARM identified the suppliers of the components incorporated in the products that ARM contracted for manufacture in the year ended December 31, 2015 and confirmed it was in receipt of conflict minerals policy statements from substantially all such suppliers. Based on a review of such policy statements, ARM believes that the conflict minerals policies of those suppliers for which ARM has received policy statements are consistent with ARM’s own policy and seek to eliminate conflict minerals that originate in the Democratic Republic of Congo or any adjoining countries from the supply chain.

In addition to the conflict minerals policy statements, ARM has sought to receive EICC forms from each supplier and has received completed EICC forms from a significant majority of its suppliers, including a significant majority of its key suppliers. Where required, ARM frequently follows up with suppliers that have not yet completed an EICC form and continues to do so in accordance with its conflict minerals procedures.

Reasonable Country of Origin Inquiry Conclusion

Based on the reasonable country of origin inquiry performed with respect to conflict minerals used in components incorporated in its manufactured products, ARM has no reason to believe that any conflict minerals necessary to the functionality or production of any of its products contracted for manufacture originated in the Democratic Republic of Congo or any adjoining country.

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The information discussed above is also available at www.arm.com/sec. The website and information accessible through it are not incorporated into this specialized disclosure report.

Item 1.02 Exhibit

Not required.

Item 2.01 Exhibits

None.

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.