UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM SD

Specialized Disclosure Report

ALPHATEC HOLDINGS, INC.

(Exact Name of Registrant as Specified in Charter)

Delaware	000-52024	20-2463898
(State or Other Jurisdiction of Incorporation)	(Commission File Number)	(I.R.S. Employer Identification No.)

5818 El Camino Real

Carlsbad, California 92008

(Address of Principal Executive Offices)

Jeffrey G. Black

Executive Vice President and Chief Financial Officer

(760) 431-9286

(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 applies:

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.

Section 1 – Conflict Minerals Disclosure

Item 1.01    Conflict Minerals Disclosure

This disclosure for the year ended December 31, 2016, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“the Rule”). Numerous terms in this disclosure are defined in the Rule and Form SD. The reader is referred to those sources and to the 1934 Act Release No. 34-67716 (August 22, 2012) for such definitions.

In accordance with the Rule, Alphatec Holdings, Inc. (“the Company”) conducted a good-faith, reasonable country of origin inquiry (“RCOI”) for the calendar year ended December 31, 2016, and has concluded that there is no reason to believe that necessary conflict minerals used in its business operations may have originated in the Democratic Republic of Congo or any adjoining country (the “Covered Countries”).

The Company’s RCOI efforts were based on the Electronic Industry Citizenship Coalition and Global e-Sustainability (“EICC/GeSI”) initiative with the smelters and refiners of conflict minerals who provide those conflict minerals to our suppliers. The Company does not directly purchase raw ore or unrefined conflict minerals and makes no purchases directly in the Covered Countries.

The Company’s RCOI efforts were performed in good faith and included:

• conducting a supply-chain survey with direct suppliers of materials containing conflict minerals using the EICC/GeSI Conflict Minerals Reporting Template to identify the smelters and refiners; and

• comparing the smelters and refiners identified in the supply-chain survey against the list of smelter facilities which have been identified as “conflict free” by programs such as the EICC/GeSI Conflict Free Smelter program for the Company’s identified conflict minerals, which are tantalum and gold.

As a result of the RCOI efforts described above, the Company has concluded that there is no reason to believe that its necessary conflict minerals may have originated in the Covered Countries. The RCOI efforts and results are publicly available at www.alphatecspine.com.

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.

Date: May 31, 2017	ALPHATEC HOLDINGS, INC.
	By:	/s/ Jeffrey G. Black
	Name:	Jeffrey G. Black
	Title:	Executive Vice President and Chief Financial Officer