Document

SD 1 delltechnologiesconflictmi.htm SD Document

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

Dell Technologies Inc.

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

Delaware

001-37867

80-0890963

(State or other jurisdiction of
incorporation or organization)

(Commission
File Number)

(I.R.S. Employer
Identification No.)

One Dell Way, Round Rock, Texas

78682

(Address of principal executive offices)

(Zip code)

Richard J. Rothberg, Esq.

General Counsel and Secretary

(800) 289-3355

(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 submitted, and provide the period to which the information in this Form applies:

þ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2025.

o Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____.

Section 1 — Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

A copy of the Conflict Minerals Report of Dell Technologies Inc. for the period January 1, 2025 to December 31, 2025 required by Item 1.01 is filed as Exhibit 1.01 hereto and is publicly available at

https://www.delltechnologies.com/asset/en-us/solutions/business-solutions/legal-pricing/dell-technologies-conflictminerals-report.pdf.

Item 1.02 Exhibit

The Conflict Minerals Report of Dell Technologies Inc. for the period January 1, 2025 to December 31, 2025 required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 3 — Exhibits

Item 3.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 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 undersigned hereunto duly authorized.

DELL TECHNOLOGIES INC.

(Registrant)

By:

/s/ Richard J. Rothberg

May 29, 2026

Richard J. Rothberg, Esq.
General Counsel and Secretary

Date

(Duly Authorized Officer)

SEC Form SD filed by Dell Technologies Inc.