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•	MACOM maintains a conflict minerals policy (the “Policy”). The Policy indicates that we expect all suppliers of our products and materials to cooperate with our 3TG procedures. The Policy is publicly available on MACOM’s website at https://www.macom.com/about/quality-reliability, and is sent to Suppliers as part of the RCOI process. The Policy is also referenced in customer communications.

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MACOM has structured internal management to support its 3TG compliance program. A member of the senior staff from the Compliance and Quality Systems department leads a team directly responsible for the management of our 3TG compliance program. The team also includes members from our Operations, Legal, Procurement and Quality departments. Senior management and key internal stakeholders receive reports regarding the advancement and conclusions of the program. MACOM has also enlisted a third party information management service provider (the “Service Provider”) and specialist outside counsel to assist in our due diligence and/or other 3TG compliance activities. The measures described in this CMR were either taken by the Company or the Service Provider acting on its behalf.

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•	MACOM’s engagement with suppliers to support their compliance with the Rule includes terms and conditions relating to 3TG compliance in our standard form purchasing terms and conditions. In addition, our templates for supplier agreements also reference 3TG compliance.

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MACOM has established a system of transparency, information collection and control over the 3TG supply chain. This system includes a process to collect required supplier RCOI data, utilizing the industry standard Conflict Minerals Reporting Template (“CMRT”). Additional details on supply chain data gathering are included in the RCOI and due diligence sections of this CMR. This information is retained for at least five years, generally in electronic form.

•	MACOM has a plan to improve the quantity and quality of supplier responses year over year. Outreach for specific suppliers is coordinated between MACOM’s 3TG team and our Procurement department to address outstanding and incomplete data.

•	MACOM has a dedicated Conflict Minerals email address through which MACOM’s employees, suppliers and other third parties can voice any concerns regarding potential violations of MACOM’s conflict minerals policy without any fear of retribution. The dedicated Conflict Minerals email address is conflictminerals@macom.com.

•	developing the list of direct Suppliers providing components containing 3TG to MACOM, prioritized by spend;

•	contacting each Supplier and requesting a completed industry standard CMRT, including SOR information;

•	following up by email or phone with Suppliers that did not respond to the request within a specified time frame;

•	reviewing Supplier responses for accuracy, completeness and plausibility;

•	amalgamating the Supplier provided SOR information into a single list of SORs recognized as such by the Responsible Minerals Initiative (the “RMI”).

•	identify the scope of the risk assessment of the 3TG supply chain; and

•	assess whether the SORs have carried out due diligence for responsible supply chains of 3TG from conflict-affected and high-risk areas.

•	Engagement directly with the SOR (including information publicly available on the SOR’s website or its relevant industry association) to ascertain whether or not the SOR sources from the Covered Countries.

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For SORs that declared directly or through their relevant industry association that they did not source from the Covered Countries, and were not listed as Conformant by the RMAP, the Service Provider reviewed the SOR’s declaration against publicly available information to determine if there was any contrary evidence to the SOR’s declaration. The sources reviewed included: (1) a public internet search of the facility in combination with a public internet search relating to each

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•	For SORs that did not respond to direct engagement, the Service Provider reviewed publicly available sources to determine if there was “any reason to believe” that the SOR may have sourced from a Covered Country during the reporting period. For this review, the same sources as listed above were used.

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MACOM’s risk mitigation plan includes a requirement for high risk SORs (SORs sourcing from, or there is reason to believe they are sourcing from the Covered Countries) to be audited and certified “Conformant” by the Responsible Minerals Assurance Process (the “RMAP”) or to be RMAP “Active.” If high risk SORs do not become “Conformant”, MACOM suppliers are requested to identify a path to mitigate the risk of sourcing from these SORs.

•	For high risk SORs that have not been audited and listed as “Conformant” by the RMAP, MACOM conducted risk mitigation on the SOR according to the OECD Due Diligence Guidance and communicated the results of these activities to a designated member of senior management.

a.

Not all of the included SORs may have processed the necessary 3TG contained in MACOM’s in-scope products, since some Suppliers reported at a “company level,” meaning that they reported the 3TG contained in all of their products, not just those in the products that they sold MACOM. Some Suppliers also may have reported SORs that were not in MACOM’s supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. In addition, the SORs reflected above may not include all of the SORs in MACOM’s supply chain, since some Suppliers did not identify all of their SORs and because not all Suppliers responded to MACOM’s inquiries.

b.	The table only includes entities that meet the definition of SORs set out in the RMAP protocols for tin, tantalum, tungsten, and gold.

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c.	SOR status information in the table is as of May 15, 2019. SOR status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by MACOM.

d.	“Conformant” means that a smelter or refiner was listed as Conformant with the Responsible Minerals Assurance Process (“RMAP”) assessment protocols. Smelters and refiners listed as “re-audit in progress” are still considered to be Conformant. Included smelters and refiners were not necessarily Conformant for all or part of 2018 and may not continue to be Conformant for any future period.

e.	“Active” means that the smelter or refiner is a participant in the RMAP and has committed to undergo an RMAP assessment. Smelters and refiners are identified as Active in the RMAP once they have scheduled the assessment date.

f.	“On Smelter Look-up Tab List Only” means a SOR is listed on the Smelter Look-up tab list of the CMRT, but is not listed as “Conformant” or “Active.”

•	Use the CMRT for 2019 supplier outreach.

•	Continue to encourage suppliers to take the steps needed to obtain and provide current, accurate and complete information about their SORs by enhancing training materials and through further outreach.

•	Continue to encourage suppliers to source responsibly from SORs that are listed as “Conformant” or “Active” by the RMAP program.

•	Contact identified SORs that are not certified “Conformant” or “Active” by the RMAP program to request their participation in the program.

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