Conflict Minerals Policy

Mellanox Technologies, Ltd. and its subsidiaries (collectively, “Mellanox”) are committed to the highest standards, whether measured by the quality of our products, the quality of our services, or the way in which we conduct our business. We manage our business with integrity, and we work with our suppliers, vendors and contractors to ensure the working conditions in our supply chain are safe, affected workers are treated with respect and dignity, and applicable production processes are environmentally and socially responsible.

The U.S. Securities and Exchange Commission (the "SEC") has adopted rules requiring publicly traded companies to disclose whether they use tantalum, tin, gold or tungsten ("Conflict Minerals") which originated in the Democratic Republic of the Congo (the "DRC") or neighboring countries ("Covered Countries") and, if so, "the companies are to exercise due diligence on the source and chain of custody of those Conflict Minerals and report the results of their inquiry and due diligence.

Mellanox does not procure metals directly and only a fraction of the world‘s minerals produce originates from the DRC, but we are taking action to increase transparency, ensure responsible procurement by our suppliers and subsuppliers, and drive positive change. Mellanox is committed to source its raw materials, components and parts from suppliers that respect human rights, integrity and environmental regulations.

Mellanox has implemented measures to comply with Section 1502 of the Dodd- Frank Act, which aims to prevent the use of Conflict Minerals that use of which directly or indirectly helps to finance or benefit armed groups in Covered Countries.

Mellanox complies with all applicable laws and commits to work towards improving traceability of Conflict Minerals and ensure responsible sourcing. We have implemented measures in conformance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and support the Responsible Minerals Initiative ("RMI") formerly Conflict-Free Sourcing Initiative "CFSI".

Mellanox strives to be a "conflict free" company by 30 June, 2018 and is taking the required measures to review and check the processes throughout its supply chain In its efforts to achieve a conflict free supply chain. Mellanox requires that suppliers whose products contain Conflict Minerals to provide information regarding the Conflict Minerals throughout their supply chain using the RMI's Conflict Minerals Reporting Template (CMRT). Mellanox expects suppliers to take similar measures with their suppliers to ensure compliance throughout their supply chain of the Conflict Minerals used in their parts/components/material, and to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free. Mellanox has incorporated the principles of the Conflict Minerals requirements into its business practices, and our approval process for new suppliers contains Conflict Minerals requirements.

Mellanox will communicate this policy to its suppliers and encourage them to set similar policies for their supply chain.

 

Suppliers that will not adhere to conflict minerals regulations, and will not work towards a Conflict free supply chain, will be considered as "risk source of supply", and will be eliminated from future business opportunities with Mellanox.

Contact for Mellanox Conflict Minerals: Yossi Adi (yossiad@mellanox.com)

Adopted: December 2013

Updated: November 2017;

 

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