UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

Eargo, Inc.

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

Christy La Pierre

Chief Legal Officer

(650) 351-7700

(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:

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

In accordance with Rule 13p-1 of the Securities Exchange Act of 1934, as amended, Eargo, Inc. (the “Company”) hereby files this Specialized Disclosure Report on Form SD and the Conflict Minerals Report for the calendar year ended December 31, 2022 attached hereto as Exhibit 1.01. The Conflict Minerals Report is also available on the Company’s website at: https://ir.eargo.com/static-files/bdf27f63-3383-4f6a-8fab-61816e9f36ed.

Item 1.02 Exhibit

The Conflict Minerals Report required by Item 1.01 is attached as Exhibit 1.01 to this Specialized Disclosure Report on Form SD.

Section 2 – Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

Section 3 – Exhibits

Item 3.01 Exhibits

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.

Exhibit 1.01

CONFLICT MINERALS REPORT

EARGO, INC.

This Conflict Minerals Report (“CMR”) has been prepared by Eargo, Inc. (herein referred to, collectively with its consolidated subsidiaries, alternatively, as “Eargo,” “we,” “our” and “us”). This CMR for the reporting period January 1, 2022 to December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended relating to “conflict minerals” (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement the reporting and disclosure requirements relating to Conflict Minerals in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain “conflict minerals” that are necessary to the functionality or production of their products. “Conflict minerals” are currently defined by the SEC as cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which the SEC has currently limited to tin, tantalum, and tungsten.

To comply with the Rule, we conducted a good faith, reasonable country of origin inquiry (“RCOI”) and due diligence on the origin, source and chain of custody of the conflict minerals that were necessary to the functionality or production of the products that we manufactured or contracted to manufacture to ascertain whether these conflict minerals originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (as defined in Section 1, Item 1.01(d)(1) of Form SD) (collectively, “Covered Countries” and, individually, a “Covered Country”) and financed or benefited armed groups (as defined in Section 1, Item 1.01(d)(2) of Form SD) (“Armed Groups”) in any of these countries.

Pursuant to guidance issued by the SEC’s Division of Corporation Finance on April 29, 2014 and the SEC order issued May 2, 2014, Eargo is not required to describe any of its products as “DRC conflict free” (as defined in Section 1, Item 1.01(d)(4) of Form SD), “DRC conflict undeterminable” (as defined in Section 1, Item 1.01(d)(5) of Form SD) or “having not been found to be ‘DRC conflict free,’” and therefore makes no conclusion in this regard in the report presented herein. Furthermore, given that Eargo has not voluntarily elected to describe any of its products as “DRC conflict free,” an independent private sector audit of the report presented herein has not been conducted.

Company Overview and Description of Products Covered by this Report.

Eargo is a medical device company dedicated to improving the quality of life of people with hearing loss. Our innovative products and go-to-market approach address the major challenges of traditional hearing aid adoption, including social stigma, accessibility and cost.

Eargo offers a variety of virtually invisible, rechargeable, completely in-the-canal, FDA-regulated hearing aids indicated to compensate for mild to moderate hearing loss (collectively, our “Products”).

We currently rely on a limited number of contract manufacturers for our Products, including a primary manufacturer in Asia. In addition, we rely on several third-party suppliers for the components used in our hearing aids, including semiconductor components, such as integrated circuits, as well as batteries, microphones and receivers throughout the world.

Reasonable Country of Origin Inquiry

Our RCOI consisted of the following activities: (a) identification of relevant suppliers; (b) collection of data and information from those suppliers; (c) review and assessment of the data and information collected; and (d) determination of whether further due diligence is required.

For calendar year 2022, we identified four Tier 1 suppliers as in-scope for Conflict Mineral regulatory purposes. We then engaged Source Intelligence, an internationally known expert on responsible sourcing and provider of RCOI services (“Source Intelligence”). The RCOI process followed by Source Intelligence is described further below. Despite having conducted a good faith RCOI through Source Intelligence, we were unable to determine with reasonable assurance the source of all the necessary Conflict Minerals contained in all our Products.

RCOI Process Utilized by Source Intelligence

Use of CMRT

To complete the RCOI required by the Rule, Source Intelligence engaged with Eargo’s suppliers to collect information about the presence and sourcing of tantalum, tin, tungsten and gold (“3TG”) used in the products and components supplied to Eargo in order to manufacture the Products. The program utilized the Conflict Minerals Reporting Template (“CMRT”) developed by Conflict-Free Sourcing Initiative (“CFSI”) for data collection. Only CMRT’s version 6.22 or higher were accepted in this process. Suppliers were offered two options to submit the required information, either by uploading the CMRT in MS Excel format or by completing an online survey version of this template directly in the Source Intelligence platform. In certain cases, if a supplier was unable to complete the survey on the platform, Eargo or Source Intelligence uploaded the CMRT on its behalf.

Supplier Engagement

Eargo provided Source Intelligence with at least one method of contact for each Tier 1 supplier designated as in-scope (email address and telephone number). Email was the preferred method of communication. The RCOI began with an introduction email from Eargo to suppliers describing the Conflict Minerals Compliance Program requirements and identifying Source Intelligence as a partner in the process. Following that introductory email, Source Intelligence sent an email to suppliers containing a registration and survey request link for the online data collection platform.

Following the initial introductions to the program and information request, up to 5 reminder emails were sent to each non-responsive supplier requesting survey completion.

Escalation

If, after these efforts, a given supplier still did not register with the system or provide the information requested, an escalation process was initiated. The escalation process consisted of direct outreach by Eargo. Specifically, Eargo contacted these suppliers by email to request their participation in the program. Source Intelligence followed up with an email in a timely manner.

New Information Cut-off

In recognition that the information requested can take time to collect and aggregate, suppliers were given a final deadline of March 31, 2023 to provide information about the metal processors present in their supply chains for the 2022 calendar year.

Information Requested

Tier 1 suppliers were asked to provide information regarding the sourcing of their materials, with the ultimate goal of identifying the 3TG smelters or refiners (“SORs”) and associated mine countries of origin. Tier 1 suppliers who had already performed a RCOI through the use of the CMRT were asked to either upload this document into the Source Intelligence system or to provide this information in the online survey.

Eargo chose to give their suppliers the ability to share information at a level with which they were most comfortable, i.e., company, product or user-defined, although the declaration scope had to be specified.

Tier 1 suppliers were requested to provide an electronic signature before submitting their data to Eargo to verify that all answers submitted were accurate to the best of the supplier’s knowledge, but the suppliers were not required to provide an electronic signature to submit their data.

Quality Assurance

Supplier responses were evaluated by Source Intelligence for plausibility, consistency, and gaps. If any of the below “quality control” flags were raised, suppliers were automatically contacted by the Source Intelligence platform on a bi-weekly basis up to 3 contacts.

RCOI Results and Determinations

The response rate among the Company’s Tier 1 suppliers was 100%, each of whom indicated one or more 3TG as necessary to the functionality or production of the products they supply to Eargo and its contract manufacturers. Based on Source Intelligence’s smelter/refiner database, there was an indication of sourcing from a Covered Country for 45 out of 217 verified smelters/refiners.

Source Intelligence Review of Covered Countries Sourcing Indications

For those supply chains with SORs that are known or thought to be sourcing from a Covered Country, additional investigation is needed to determine the source and chain-of-custody of the regulated metals. Source Intelligence relies on the following internationally accepted audit standards to determine which SORs are considered “DRC Conflict Free”: the CFSI Conflict-Free Smelter Program, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain-of-Custody Certification. Source Intelligence has become an official vendor member of the CFSI to further facilitate the exchange of supply chain data and technical information in the quest for global ethical sourcing of materials. This membership provides Source Intelligence access to the following working groups: Engage with the CMRT Development Team, Smelter Engagement Team, Smelter Data Management Team, CFSI Stakeholders Call, and CFSI Plenary.

If the SOR is not certified by these internationally recognized schemes, Source Intelligence attempts to contact the SOR to gain more information about its sourcing practices, including countries of origin and transfer, and whether there are any internal due diligence procedures in place or other processes the SORs takes to track the chain-of-custody on the source of its mineral ores. Relevant information to review includes the following: whether the SOR has a documented, effective and communicated conflict-free policy, an accounting system to support a mass balance of materials processed, and traceability documentation. Internet research is also performed to determine whether there are any outside sources of information regarding the SOR’s sourcing practices. Up to three contact attempts are made by Source Intelligence to SORs to gather information on mine country of origin and sourcing practices.

Due Diligence Results

Based on the information obtained pursuant to the due diligence process described above, Eargo does not have sufficient information to reach a conclusion as to all sources of the Conflict Minerals necessary to the functionality of its Products. We are unable to connect specific smelters for all of the materials contained in our Products and are therefore unable to identify and disclose the facilities that processed the necessary Conflict Minerals or determine the country of origin of the necessary Conflict Minerals contained in all our Products. We are also unable to determine whether the necessary Conflict Minerals financed or benefited Armed Groups in the Covered Countries.

However, we also have not identified any information indicating that the Conflict Minerals that are necessary to the functionality or production of our Products that we contracted to manufacture during calendar year 2022 directly or indirectly financed or benefitted any Armed Groups in the Covered Countries.

Our supply chain is complex, and there are multiple tiers between the Company and the mines where minerals originate. We do not purchase Conflict Minerals directly from mines, smelters or refiners, and tracing these minerals to their sources is a challenge that requires us to rely on our suppliers to achieve supply chain transparency, including obtaining information regarding the origin of the Conflict Minerals.

Steps to be Taken to Mitigate Risk

Eargo intends to continue undertaking the following steps to mitigate the risk that the Conflict Minerals necessary to the functionality of its Products benefit Armed Groups in the Covered Countries, including taking the additional due diligence steps noted below:

FORWARD-LOOKING STATEMENTS

This Conflict Minerals Report contains “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995 (the “Act”) that are intended to come within the safe harbor protection provided by the Act. Any statements contained in this report regarding future expectations, beliefs, goals, plans or prospects constitute forward-looking statements. Forward-looking statements in this Conflict Minerals Report include statements regarding future due diligence steps Eargo intends to take relating to Conflict Minerals. By their nature, all forward-looking statements involve risks, uncertainties and assumptions, and actual results may differ materially from those contemplated by the forward-looking statements. Factors that could materially affect Eargo’s ability to complete intended due diligence steps include an inability to complete sourcing of necessary raw materials and components, procurement savings and productivity changes, the timely cooperation by and accuracy of our suppliers in our due diligence efforts, our ability to identify and mitigate related risks in our supply chain, future legal and regulatory developments relating to Conflict Minerals and other factors which are identified in Eargo’s press releases, shareholder communications and SEC filings, including Eargo’s Annual Report on Form 10-K for the fiscal year ended December 31, 2022. Except as required by law, we undertake no obligation to update any forward-looking statements, whether as a result of new information, future events or otherwise.

TABLE 1

Smelter/Refiner Disclosure

Set forth below are the known SORs that processed the 3TG materials present in our manufactured products and the possible countries of origin of such 3TG materials. Eargo’s efforts to determine the mine or location of origin of these 3TGs are described above in this Conflict Minerals Report.