UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

GARRETT MOTION INC.

(Exact name of registrant as specified in its charter)

Jerome P. Maironi

Senior Vice President, General Counsel and Corporate Secretary

+41 21 695 30 00

(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:

Section 1 — Conflict Minerals Disclosure

A copy of Garrett Motion Inc.’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at https://investors.garrettmotion.com/governance.

The Conflict Minerals Report required by Item 1.01 is filed as an exhibit hereto.

Section 2 — Exhibits

Item 2.01. Exhibits

SIGNATURE

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

Garrett Motion Inc.

Conflict Mineral Report

For the reporting period From January 1, 2020 to December 31, 2020

This Conflict Minerals Report of Garrett Motion Inc. and its consolidated subsidiaries (“Garrett,” “we,” or “our”) has been prepared in accordance with Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act). The Rule calls for certain disclosures from an SEC registrant that manufactures or contracts to manufacture, products for which conflict minerals are necessary to the functionality or production of those products. Conflict Minerals are defined as cassiterite, columbite-tantalite, wolframite, and gold, including their derivatives, which are limited to tin, tantalum, and tungsten (collectively, “3TG”).

If any 3TG are necessary to the functionality or production of products manufactured or contracted to be manufactured, by a registrant, the text of the Rule requires such registrant to conduct in good faith a reasonable country of origin inquiry (“RCOI”) that is reasonably designed to determine whether any of its 3TG originated in the Democratic Republic of the Congo (“DRC”), the Central African Republic, the Republic of the Congo. South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, or Angola (the “Covered Countries”), or are from recycled or scrap sources.

Overview

Garrett’s Business

Garrett designs manufacture and sell highly engineered turbocharger, electric-boosting and connected vehicle technologies for light and commercial vehicle original equipment manufacturers (“OEMs”) and the global vehicle independent aftermarket as well as automotive software solutions. We are a global technology leader with significant expertise in delivering products across gasoline, diesel, natural gas, and electrified (hybrid and fuel cell) powertrains.

Garrett’s Products Covered by this Report

This report relates to Garrett products: (i) for which 3TG are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by Garrett; and (iii) for which the manufacture was completed during the calendar year 2020. These products, which are referred to herein as the “Covered Products,” consist of turbochargers and intercoolers.

Garrett’s Supply Chain

Garrett sells thousands of products containing parts from hundreds of direct and indirect suppliers. As a “downstream” company with many tiers in our supply chain, we have direct relationships with a few smelters and refiners (less than 1% of our direct suppliers) and do not perform or direct audits of entities within our supply chain. It is difficult for us to identify actors upstream from our direct suppliers, and we rely on those suppliers to provide information on the smelters and refiners (“SORs”) as well as the origin of 3TG contained in parts or products supplied to us, including sources of 3TG that are supplied to them from their upstream suppliers. Similarly, our direct suppliers rely on information provided by their suppliers.

The terms and lengths of contracts with our suppliers are varied, and we cannot always unilaterally impose new contract terms. As we renew or enter into new purchase agreements with suppliers, we generally seek to add, where possible, a 3TG compliance provision requiring such suppliers to conduct and document their inquiries into the SORs as well as the country of origin of 3TG in parts or products supplied to Garrett and to provide Garrett with information or representations that Garrett requires to meet its compliance obligations. Although we have already integrated a 3TG compliance provision into certain purchase agreements with our direct suppliers, we anticipate that it will take several years to ensure that all supplier purchase agreements contain appropriate 3TG compliance provisions. In addition, some suppliers may object to the inclusion of such 3TG compliance provisions. In the meantime, as described herein, we are working with our suppliers to obtain 3TG sourcing information.

Reasonable Country of Origin Inquiry

Garrett conducted a good faith RCOI to determine whether the 3TG in the Covered Products may have originated in the Covered Countries and did not come from recycled or scrap sources. The elements of the RCOI were:

Garrett assessed its direct suppliers that were most likely to provide parts or products containing 3TG concerning our turbocharger and intercoolers, and in connection therewith we identified 441 relevant suppliers (the “Supplier Group”).

Garrett engaged a third-party service provider, Assent Compliance (the “Vendor”), to help obtain supplier data. It began with a request for each supplier in the Supplier Group to respond to the 2020 (version 6.01) Responsible Minerals Initiative’s Conflict Minerals Reporting Template (the “Questionnaire”). The Questionnaire is designed to facilitate disclosure and communication of information regarding SORs of 3TG contained in parts or products in our supply chain. It includes questions regarding a supplier’s engagement with its direct suppliers and a listing of the SORs that the supplier and its suppliers use. In addition, the Questionnaire contains questions about the origin of 3TG included in a supplier’s parts or products, as well as supplier due diligence efforts. The Vendor deployed the Questionnaire to the Supplier Group via a tracking tool, which enabled Garrett and the Vendor to manage and maintain records of responses from the Supplier Group in an electronic database. The procedure involved four rounds of follow-up to unresponsive members of the Supplier Group through a defined process via both automated email and personalized email, including offering assistance and further information to the Supplier Group about the requirements of the Rule and the 3TG compliance program. Garrett received responses from 80% of the Supplier Group.

The collected data was then validated by the Vendor to increase the accuracy of submissions and identify any contradictory answers in the Questionnaire. The Vendor’s tracking tool and electronic database facilitated automated data validation on all submitted Questionnaires. All submitted Questionnaires were accepted and classified as valid or invalid. Members of the Supplier Group were contacted with regards to invalid forms and were encouraged to resubmit a valid form. We reviewed the responses to determine where further engagement with our Supplier Group was warranted.

Based on the responses received from the Company’s RCOI, we compiled a list of 321 unique SORs. However, the vast majority were at a supplier-level, and none included information regarding associated countries of origin. Based on the responses to our RCOI and the fact that responses were not received from all members of the Supplier Group to the Questionnaire, Garrett did not have complete and validated information to conclude whether its necessary 3TG in the Covered Products originated in the Covered Countries, and if so, whether they were from recycled or scrap sources or came from sources that directly or indirectly financed or benefitted armed groups, as such term is defined in the Rule. Accordingly, Garrett conducted due diligence on the source and chain of custody of the 3TG contained in parts or products provided by the Supplier Group.

Due Diligence Process

Design of Due Diligence Measures

Our due diligence measures have been designed to conform, in all material respects, with the Organization for Economic Co-operation and Development’s (“OECD”) “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (2016)” and the related Supplements for 3TG (the “OECD Framework”). The OECD Framework is written for the entire mineral supply chain and our due diligence measures were tailored to include steps appropriate for “downstream” companies. Our due diligence included the following elements of the OECD Framework:

Step 1: Establish Strong Company Management Systems

Garrett has established a management system to determine the source and chain of custody of 3TG in our supply chain.

https://s2.q4cdn.com/726657224/files/doc_downloads/governance/Supplier-Conduct.pdf

Step 2: Identify and Assess Risks in the Supply Chain

Step 3: Design and Implement a Strategy to Respond to Identified Risks

As part of our risk management plan under the OECD Framework, if SORs with red flags are reported on a Questionnaire by one of the suppliers surveyed, risk mitigation activities will be initiated. If a supplier indicates that its products may contain 3TG sourced from a Covered Country, we will follow up with the supplier to gather more information, including the basis for the information provided and other information regarding the sourcing country and SOR. Identified risks will be reported to the Product stewardship Team, which will determine appropriate follow-up actions, if any, to mitigate risks. There was no instance in our due diligence for the 2020 reporting period where we determined that there were validated high-risk issues in our supply chain requiring follow-up actions.

To ensure that the Supplier Group understands our expectations concerning compliance with the Rule, we distributed background information on the Rule and our Mission Statement, and we provided access to training materials on 3TG compliance to the Supplier Group in addition to the Questionnaire.

Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

Garrett does not perform or direct audits of entities in our supply chain but relies on the RMI’s Responsible Minerals Assurance Process (“RMAP”) to perform third-party audits of SORs. Our process compares the SORs identified by the Supplier Group to the list of SORs certified as “compliant” or the equivalent by the RMI. If SORs are identified with issues, we engage with the supplier directly to verify the information before reporting the issue to the Product Stewardship Team.

Step 5: Report on Supply Chain Due Diligence

This Conflict Minerals Report, and the Form SD to which it relates, have been filed with the SEC, and are publicly available at: https://s2.q4cdn.com/726657224/files/doc_downloads/governance/2020/06-01-20-GTX-Conflict-Minerals-Report-2019-FINAL-v2.pdf

Due Diligence Results

The Questionnaire requested that the Supplier Group provide Garrett with information on (a) the SORs that the Supplier Group and its suppliers use to supply the 3TG in the Covered Products, (b) whether the 3TG used in the Covered Products originates from the Covered Countries, (c) the mine or location of origin of the 3TG used in the Covered Products, and (d) the scope of its response (company-level responses refer to the supplier’s overall 3TG sourcing; product-level responses specify whether 3TG was used in parts or products provided to Garrett). Garrett must rely on responses from the Supplier Group to our Questionnaire to determine the facilities used to process 3TG used in the Covered Products, whether the 3TG used in the Covered Products originates from the Covered Countries, and the source of 3TG used in the Covered Products.

The responses that we received for this reporting period from the Supplier Group fell into one or more of the following categories: (i) indication that no 3TG is used in parts or products that are provided to Garrett, (ii) data concerning the SORs used by the supplier to process 3TG in parts or products provided to Garrett; (iii) data with respect to the supplier’s overall 3TG sourcing, without specifying whether such 3TG was used in parts or products provided to Garrett or indication that the supplier is unable to provide the information as it specifically relates to the parts or products that are provided to Garrett, (iv) indication that the supplier is unable to provide SOR information at this time, and/or (v) indication that the supplier

is unable to provide or is still in the process of determining the country of origin or mine or location of origin of 3TG from its suppliers. We received responses in category (ii) above from 352 out of 441 suppliers. Such responses identified 321 unique SORs (set forth on Appendix A below) used to process 3TG in parts or products provided to Garrett, and whilst they did not indicate the country of origin of the 3TG processed by such SORs, 236 of these SORs are RMAP Conformant.

As a result of the foregoing, and because responses were not received from all members of the Supplier Group, Garrett does not have complete and validated information to conclude whether its necessary 3TG in the Covered Products originated in the Covered Countries, and if so, whether they were from recycled or scrap sources, or came from sources that directly or indirectly financed or benefitted armed groups therein, as such term is defined the Rule.

However, Garrett received no response (to either the initial communication or any follow-up inquiries) from any supplier indicating that 3TG in our Covered Products originated in the Covered Countries (even when SORs used to process our 3TG were identified) or benefitted or financed armed groups in the Covered Countries.

Besides, we were unable to determine the country of origin or the mine or location of origin of 3TG used in the parts or products supplied to us for use in the Covered Products. Our efforts to identify the specific mine or location or origin of our necessary 3TG included the due diligence measures described above.

Steps to be taken to mitigate risk

We intend to take the following steps to improve the due diligence conducted and to further mitigate any future risk of sourcing 3TG that benefit armed groups in the Covered Countries:

Cautionary Statement about Forward-Looking Statements

We have made statements in this Conflict Minerals Report that may constitute “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended (the “Exchange Act”) about our plans to take additional actions or to implement additional procedures with respect to our due diligence efforts to determine the

origin of conflict minerals included in our products. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report. These forward-looking statements should be considered in light of the information included in this report and our other filings with the SEC, including, without limitation, the Risk Factors, as well as the description of trends and other factors in Management’s Discussion and Analysis of Financial Condition and Results of Operations, set forth in our Form 10-K for the year ended December 31, 2020, as updated by our Form 10-Q for the quarter ended March 31, 2021, and other filings with the SEC.

Appendix A—Smelter list

Includes: Metals, SOR name, SOR Facility location, and SOR ID (SORs indicated with an asterisk* are RMAP conformant; SORs indicated with a double asterisk** are “Active”, i.e., they have committed to undergo an RMAP audit).