EXHIBIT 1.01
RADISYS CORPORATION
Conflict Minerals Report
For the Year Ended December 31, 2013
This is the Conflict Minerals Report of Radisys Corporation (herein referred to as “Radisys” or the “Company”) report for the year ended December 31, 2013 in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the Exchange Act). Rule 13p-1 was adopted by the Securities and Exchange Commission (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 Act). Numerous terms in this report are defined in Rule 13p-1, Form SD promulgated under the Exchange Act and Exchange Act Release No. 34-67716 and the reader is referred to those sources for such definitions.
This Conflict Minerals Report has not been subject to an independent private sector audit as allowed under Rule 13p-1, which provides a temporary accommodation for the first two years following November 13, 2012.
In accordance with Rule 13p-1, the Company undertook a reasonable country of origin inquiry that was reasonably designed to determine whether the conflict minerals necessary for the functionality or production of its products originated in the Democratic Republic of the Congo or an adjoining country (a “Covered Country”) or are from recycled or scrap sources. As a company in the telecommunications equipment manufacturing business, Radisys is several levels removed from the actual mining of conflict minerals. Radisys does not make purchases of raw ore or unrefined conflict minerals and makes no purchases in the Covered Countries. The Company designed and implemented its due diligence measures as to the source and chain of custody of its conflict minerals to be in conformity, in all material respects, with the nationally or internationally recognized framework in the OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas (OECD 2011) and related supplements for each of the conflict minerals.
The Company’s due diligence measures included;
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A. | Conflict Minerals Compliance Plan |
The company has developed and implemented a Conflict Minerals Compliance Plan that establishes standards and procedures for compliance with Section 1502 of the Act and Rule 13p-1.
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B. | Conflict Minerals Policy |
Radisys has adopted a Conflict Minerals Sourcing Policy to reasonably assure its products are “DRC conflict free”. Suppliers are expected to have in place policies and due diligence measures that will enable the company to reasonably report the country of origin for products and components being supplied. Radisys’s Conflict Minerals Sourcing Policy can be found at: www.radisys.com
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C. | Risk Assessment and Mitigation |
All products and suppliers were assessed to determine conflict mineral scope and risk. Suppliers were assigned risk ratings for prioritization of due diligence activities. Focus was placed on high risk suppliers for completion of due diligence procedures.
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D. | Reasonable Country of Origin Methodology |
A reasonable country of origin inquiry (RCOI) was conducted with direct suppliers using the EICC/GeSI Conflict Minerals Reporting Template to identify the smelters and refiners that contribute refined conflict minerals to the products supplied to Radisys.
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E. | Maintenance of Reviewable Business Records |
Radisys maintains electronic copies of supplier responses and other documents that support the due diligence process to demonstrate transparency and compliance with recommended best practices per the OECD as well as the long-term evolution and improvement of its program to its shareholders.
Through our Conflict Mineral Compliance Plan, Radisys surveyed 100% of the suppliers within the scope of our RCOI and has been able to determine that 33% either do not provide materials that contain conflict minerals or do not provide any reason to believe that the conflict minerals they use originated in Covered Countries. Due to lack of information from our remaining suppliers, we have not been able to conclude whether the products purchased from them include Conflict Minerals and if so, whether they originated in the Covered Countries.
Due to the breadth and complexity of Radisys' products and respective supply chain, as well as being several layers removed from the mining of conflict minerals, it will take time for many of our suppliers to verify the origin of all of the minerals. Radisys will continue to perform due diligence activities in accordance with its Conflict Mineral Compliance Plan with suppliers that were unable to provide sufficient information during the initial reasonable country of origin inquiry to determine the source and chain of custody of its conflict minerals. The Company will undertake the following steps during the next compliance period to improve the results of its due diligence and to reduce the risk that its necessary conflict minerals do not benefit armed groups, including;
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• | Work directly with suppliers to increase the response rate. |
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• | Compare RCOI results to the EICC/GeSI Conflict Free Smelter List. |
The following is a link to Radisys Corporation’s public disclosure for conflict minerals: www.radisys.com.
Smelter List
Based on the information obtained pursuant to our RCOI and the due diligence process, Radisys does not have sufficient information to determine the country of origin of all the Conflict Minerals in the Covered Products; however, based on the information that was provided by the responding suppliers and otherwise obtained by Radisys through the due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the Conflict Minerals contained in some of the Covered Products included the smelters and refiners listed below:
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Metal | Smelter Name | Smelter Country |
Gold | Western Australian Mint trading as The Perth Mint | Australia |
Gold | Western Australian Mint trading as The Perth Mint | Australia |
Gold | Royal Canadian Mint | Canada |
Gold | Johnson Matthey Limited | Canada |
Gold | Royal Canadian Mint | Canada |
Gold | Royal Canadian Mint | Canada |
Gold | Xstrata Canada Corporation | Canada |
Gold | Codelco | Chile |
Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | China |
Gold | Shanghai Gold Exchange | China |
Gold | The Refinery of Shandong Gold Mining Co. Ltd | China |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
Gold | Allgemeine Gold- und Silberscheideanstalt A.G. | Germany |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
Gold | Heraeus Ltd Hong Kong | Hong Kong |
Gold | Heraeus Ltd Hong Kong | Hong Kong |
Gold | Heraeus Ltd Hong Kong | Hong Kong |
Gold | Metalor Technologies (Hong Kong) Ltd | Hong Kong |
Gold | Metalor Technologies (Hong Kong) Ltd | Hong Kong |
Gold | Matsuda Sangyo Co. Ltd | Japan |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
Gold | Aida Chemical Industries Co. Ltd. | Japan |
Gold | Asahi Pretec Corporation | Japan |
Gold | Asaka Riken Co Ltd | Japan |
Gold | Chugai Mining | Japan |
Gold | Dowa | Japan |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
Gold | JX Nippon Mining & Metals Co., Ltd | Japan |
Gold | Matsuda Sangyo Co. Ltd | Japan |
Gold | Mitsubishi Materials Corporation | Japan |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
Gold | Nihon Material Co. LTD | Japan |
Gold | Kojima Chemicals Co. Ltd. | Japan |
Gold | Sumitomo Metal Mining Co. Ltd. | Japan |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
Gold | Tokuriki Honten Co. Ltd | Japan |
Gold | Yokohama Metal Co Ltd | Japan |
Gold | LS-Nikko Copper Inc | Korea, Republic of |
Gold | Daejin Industries | Korea, Republic of |
Gold | Daeryung ENC | Korea, Republic of |
Gold | Do Sung Metal | Korea, Republic of |
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Gold | Hwasung CJ Co., Ltd | Korea, Republic of |
Gold | Korea Metal | Korea, Republic of |
Gold | Samwon Metal | Korea, Republic of |
Gold | Torecom | Korea, Republic of |
Gold | Argor-Heraeus SA | Switzerland |
Gold | Metalor Technologies SA | Switzerland |
Gold | Solar Applied Materials Technology Corp. | Taiwan |
Gold | Johnson Matthey Inc | United States |
Gold | Johnson Matthey Inc | United States |
Gold | Materion | United States |
Gold | Metalor USA Refining Corporation | United States |
Gold | Ohio Precious Metals LLC. | United States |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
Tin | Metallo Chimique | Belgium |
Tin | Metallo Chimique | Belgium |
Tin | Jean Goldschmidt International | Belgium |
Tin | EM Vinto | Bolivia |
Tin | EM Vinto | Bolivia |
Tin | OMSA | Bolivia |
Tin | Mineração Taboca S.A. | Brazil |
Tin | Mineração Taboca S.A. | Brazil |
Tin | Coopersanta | Brazil |
Tin | White Solder Metalurgia | Brazil |
Tin | AIM | Canada |
Tin | Yunnan Chengfeng | China |
Tin | Geiju Non-Ferrous Metal Processing Co. Ltd. | China |
Tin | Gejiu Zi-Li | China |
Tin | Gold Bell Group | China |
Tin | Jiangxi Nanshan | China |
Tin | Liuzhou China Tin | China |
Tin | Taicang City Nancang Metal Meterial Co.,Ltd | China |
Tin | Yunnan Chengfeng | China |
Tin | Yunnan Chengfeng | China |
Tin | Yunnan Chengfeng | China |
Tin | Yunnan Tin Company Limited | China |
Tin | Yunnan Tin Company Limited | China |
Tin | Yunnan Tin Company Limited | China |
Tin | CV Duta Putra Bangka | Indonesia |
Tin | CV JusTindo | Indonesia |
Tin | CV Makmur Jaya | Indonesia |
Tin | CV Nurjanah | Indonesia |
Tin | CV Serumpun Sebalai | Indonesia |
Tin | CV United Smelting | Indonesia |
Tin | CV United Smelting | Indonesia |
Tin | PT Alam Lestari Kencana | Indonesia |
Tin | PT Artha Cipta Langgeng | Indonesia |
Tin | PT Babel Inti Perkasa | Indonesia |
Tin | PT Babel Surya Alam Lestari | Indonesia |
Tin | PT Bangka Kudai Tin | Indonesia |
Tin | PT Bangka Putra Karya | Indonesia |
Tin | PT Bangka Timah Utama Sejahtera | Indonesia |
Tin | PT Belitung Industri Sejahtera | Indonesia |
Tin | PT BilliTin Makmur Lestari | Indonesia |
Tin | PT Bukit Timah | Indonesia |
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Tin | PT Eunindo Usaha Mandiri | Indonesia |
Tin | PT Fang Di MulTindo | Indonesia |
Tin | PT HP Metals Indonesia | Indonesia |
Tin | PT Koba Tin | Indonesia |
Tin | PT Koba Tin | Indonesia |
Tin | PT Koba Tin | Indonesia |
Tin | PT Mitra Stania Prima | Indonesia |
Tin | PT Refined Banka Tin | Indonesia |
Tin | PT Sariwiguna Binasentosa | Indonesia |
Tin | PT Stanindo Inti Perkasa | Indonesia |
Tin | PT Stanindo Inti Perkasa | Indonesia |
Tin | PT Sumber Jaya Indah | Indonesia |
Tin | PT Tambang Timah | Indonesia |
Tin | PT Tambang Timah | Indonesia |
Tin | PT Timah | Indonesia |
Tin | PT Timah | Indonesia |
Tin | PT Timah Nusantara | Indonesia |
Tin | PT Tinindo Inter Nusa | Indonesia |
Tin | PT Yinchendo Mining Industry | Indonesia |
Tin | PT DS Jaya Abadi | Indonesia |
Tin | Mitsubishi Materials Corporation | Japan |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
Tin | Minsur | Peru |
Tin | Minsur | Peru |
Tin | Minsur | Peru |
Tin | Minsur | Peru |
Tin | Novosibirsk Integrated Tin Works | Russian Federation |
Tin | Thaisarco | Thailand |
Tin | Thaisarco | Thailand |
Tin | Thaisarco | Thailand |
Tin | Thaisarco | Thailand |
Tin | Cookson | United States |
Tin | Cookson | United States |
Tin | Nathan Trotter & Co | United States |
Tungsten | Xiamen Tungsten Co Ltd | China |
Tungsten | Chaozhou Xianglu Tungsten Industry Co Ltd | China |
Tungsten | Ganzhou Grand Sea W & Mo Group Co Ltd | China |
Tungsten | Jiangxi Rare Earth & Rare Metals Tungsten Group Corp | China |
Tungsten | Jiangxi Tungsten Industry Group Co Ltd | China |
Tungsten | China National Nonferrous | China |
Tungsten | Hunan Chun-chang Non-ferrous Smelting & Concentrating Co., Ltd. | China |
Tungsten | Dayu Weiliang Tungsten CO.,LTD | China |
Tungsten | Nanchang Cemented Carbide Limited Liability Company | China |
Tungsten | NingHua XingLuoKeng TungSten Mining CO.,LID | China |
Tungsten | Xiamen Golden Egret Special Alloy Co. Ltd. | China |
Tungsten | Xiamen Tungsten Co Ltd | China |
Tungsten | Zhuzhou Cemented Carbide Group Co Ltd | China |
Tungsten | HC Starck GmbH | Germany |
Tungsten | Global Tungsten & Powders Corp | United States |
Tungsten | Global Tungsten & Powders Corp | United States |