Exhibit 1.01

CONFLICT MINERALS REPORT

for the Calendar Years 2016 and 2017

This Conflict Minerals Report (“CMR”) of Sears Holdings Corporation (“Sears Holdings” and, together with its subsidiaries, “we”, “us” or “our”) has been prepared pursuant to Rule 13p-1 (“Rule 13p-1”) promulgated under the Securities Exchange Act of 1934, as amended, for the period January 1, 2016 through December 31, 2017 (“Reporting Period”).

COMPANY OVERVIEW

Sears Holdings is a holding company that conducts operations through its subsidiaries and is the parent company of Kmart Holding Corporation and Sears, Roebuck and Co. (collectively, the “Operating Companies”). We are an integrated retailer with significant physical and intangible assets, as well as virtual capabilities enabled through technology.

The Operating Companies sell products in the following categories (among others not applicable to this CMR): private label products (made specifically for us), exclusive brand products (designed for us with licensed trademarks) and national brand products (made and sold by other companies). The private label and exclusive brand products include home appliances, tools, sporting goods, outdoor living, lawn and garden equipment, seasonal merchandise, tires, batteries, home fashions, apparel, footwear, jewelry and accessories under such well-known labels such as Kenmore, Craftsman, DieHard, Covington and other brands.

Rule 13p-1 requires certain investigation and reporting if a company manufactures or contracts to manufacture products containing one or more of the following minerals necessary to the functionality or production of any of the Covered Products: tin, tungsten, tantalum and gold (“3TG”) (the “Conflict Minerals”). Rule 13p-1 focuses on 3TG originating from the Democratic Republic of the Congo and countries that share an internationally recognized border with the Democratic Republic of the Congo (together, the “Covered Countries”). If, based on a reasonable country of origin inquiry (“RCOI”), a registrant knows that any of its necessary Conflict Minerals originated in any Covered Country and are not from recycled or scrap sources, or has reason to believe that its necessary Conflict Minerals may have originated in any Covered Country and has reason to believe that they may not be from recycled or scrap sources, then the registrant must exercise due diligence on such Conflict Minerals’ source and chain of custody that conforms to a nationally or internationally recognized due diligence framework.

We believe that we exercise a degree of influence with respect to certain private label and exclusive brand products that we sell. We are committed to ensuring that 3TG used in these products are obtained in a socially responsible manner. Sears Holdings and its subsidiaries, including the Operating Companies, do not manufacture any products. As a result, we must rely upon our suppliers’ representations for information related to Conflict Minerals. To that end, Sears Holdings has adopted a Conflict Minerals Policy and communicated its Conflict Minerals Policy requirements to its suppliers through its Vendor Information Guides, which are incorporated into our contracts with suppliers.

1

This CMR, together with the Conflict Minerals Policy, is available via the following URL: http://searsholdings.com/corporate-responsibility/conflict-minerals (information contained on, or accessible through, internet websites is not a part of this CMR).

DUE DILIGENCE

Sears Holdings conducted due diligence and a good faith reasonable country of origin inquiry using a third-party provider (“Service Provider”) to collect information from suppliers with whom we directly contract (“Tier 1 Suppliers”) to determine the presence and sourcing of 3TG in Covered Products. We utilized the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative Conflict Minerals Due Diligence Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI” formerly known as the Conflict-Free Sourcing Initiative) to identify whether Tier 1 Suppliers include 3TG in their private label and exclusive brand products that we contract to manufacture and to identify smelters and refiners (each a “SOR”, collectively “SORs”) in our supply chain. Information was collected and stored using a secure online platform.

As a retail company that purchases goods from suppliers, we are several levels removed from the actual mining of Conflict Minerals. We do not make direct purchases of raw ore or unrefined 3TG.

In accordance with the due diligence framework recommended by the Organization for Economic Cooperation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals, Sears Holdings has fulfilled the five OECD Guidance steps as follows:

Sears Holdings has established the following expectations for its suppliers:

Sears Holdings periodically reviews and assesses the effectiveness of its Conflict Minerals Policy.

A dedicated email address is published in the Operating Companies’ Vendor Information Guide and provided to suppliers to facilitate supplier communication regarding Conflict Minerals.

We developed a questionnaire that was used to discuss design process and development with the associates involved in sourcing for the Operating Companies to identify whether we contract to manufacture any products. After narrowing the products to those private label and exclusive brand products which we contract to manufacture (“Covered Products”), our due diligence process involved those Tier 1 Suppliers for the Covered Products. We developed our supplier list by compiling and comparing the answers to the questionnaire and supplier information from both internal and external sources.

2

Supplier Engagement

The following section describes the activity undertaken by Sears Holdings or the Service Provider with respect to supplier engagement in connection with our reasonable country of origin inquiry:

Assessing Risks

Assessment measures included investigation regarding the SORs identified in the supply chain for the Covered Products, based on completed CMRTs received from suppliers. Specifically, to the extent that a completed CMRT identified a SOR, the Service Provider reviewed this information against the list of conflict-free compliant smelters and refiners published by the RMI’s Conflict-Free Smelter Program (“CFSP”), the London Bullion Market Association’s (“LBMA”) Good Delivery List, and the Responsible Jewellery Council (“RJC”) Chain-of-Custody Certification. For SORs identified by a supplier that were not listed as compliant by RMI, LBMA or RJC, the Service Provider attempted to contact the SOR to gain more information about the SOR’s sourcing practices and to determine the source and chain of custody of the 3TG. Internet research was also performed by the Service Provider to determine whether there are any outside sources of information regarding the SOR’s sourcing practices.

Identified Smelters and Refiners

Based on information provided by our Tier 1 Suppliers and due diligence efforts with respect to verified SORs, we believe that the SORs that may have been used to process the Conflict Minerals in the Covered Products for the Reporting Period include the verified SORs listed in Appendix A.

Notwithstanding our due diligence process, not all of the suppliers responded to the country of origin inquiry and some provided incomplete or inconsistent information. We do not have sufficient information to determine the source of all of the 3TG contained in potentially in-scope products for 2016 and 2017.

3

The Operating Companies intend to continue their efforts through the following areas to mitigate the risk that 3TG minerals contained in the Operating Companies’ products could benefit armed groups in the Democratic Republic of the Congo or adjoining countries:

The Operating Companies do not carry out their own independent audit of smelters. We have contracted with a third party, which is a vendor member of the RMI, in order to identify, audit and verify smelters.

A list of the smelters that process Conflict Minerals and were identified by our suppliers for 2016 and 2017 is attached to this CMR as Appendix A. A list of the countries of origin of the Conflict Minerals processed by the smelters listed on Appendix A that are known to us is attached to this CMR as Appendix B. The listed countries of origin are derived from information provided by RMI.

This Conflict Minerals Report for the calendar years 2016 and 2017 is being filed with Sears Holdings’ Form SD and is also available at http://searsholdings.com/corporate-responsibility/conflict-minerals.

Cautionary Statement on Forward-Looking Statements

This CMR contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995, including, but not limited to, statements about our plans to improve our due diligence efforts regarding future Conflict Minerals Reports. Words such as “believe,” “expects,” and other terms of similar meaning are intended to identify such forward-looking statements. These forward-looking statements are based on information available to us as of the date

4

of this CMR and are based on management’s current views and assumptions. These forward-looking statements also involve a number of known and unknown risks, uncertainties, and other factors that could cause actual events to differ materially from those expressed or implied in the forward-looking statements. For those statements, we claim the protection of the safe harbor for forward-looking statements contained in the U.S. Private Securities Litigation Reform Act of 1995. Such risks and uncertainties include the veracity of information directly or indirectly provided to us by others and expectations regarding future smelter-refiner participation in conflict-free verification regimens. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the filing of this CMR or to reflect the occurrence of unanticipated events, except as required by law.

5

Appendix A

6

7

8

9

10

11

12

13

Appendix B

Countries of Origin

Based on our due diligence, the identified countries of origin of the Conflict Minerals processed by the smelters and refiners listed in Appendix A may have included the countries listed below. The listed countries or origin are derived from information provided by RMI.

14