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Conflict Minerals Policy Statement

There has been increasing awareness that the mining of certain minerals may be financing armed groups engaged in violence, human rights violations and environmental degradation in the eastern portion of the Democratic Republic of Congo (DRC) and surrounding countries.  These minerals, known as “Conflict Minerals” include: columbite-tantalite (coltan) refined into tantalum, cassiterite refined into tin, wolframite refined into tungsten and gold. 

In order to curtail these social and environmental abuses the U.S. Securities and Exchange Commission (SEC) adopted Conflict Minerals provisions in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  Beginning in 2014, all U.S. publicly traded companies are required to disclose whether the products they manufacture or contract to manufacture contain Conflict Minerals and report on the due diligence measures they have taken to determine the source of those minerals. 

DragonWave-X is committed to ethical practices and our objective is to have a conflict-free supply chain.  We do not source directly from smelters or mines and recognize that the metals supply chain is complex and global.  We are working closely with our own suppliers to understand, to the extent possible, the sources of the metals contained in the products they supply to us.  We expect our suppliers to adopt policies consistent with the SEC’s Conflict Minerals provisions and that they will put in practice steps to ensure that the minerals they include in their products are responsibly sourced.  Each supplier to DragonWave-X that provides products that include Conflict Minerals is required to submit their sourcing information using the EICC-GeSI Conflict Minerals Reporting Template or other similar template that traces the metals back through the supply chain.  If we become aware of a supplier whose supply chain includes metals from a conflict source, we expect to take the appropriate action to remedy this situation in a timely manner, including reassessment of supplier relationships.  We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.