Conflict-Free Sourcing

Ethical Sourcing and Conflict Minerals Policy

Key minerals of Tin, Tantalum, Tungsten, and Gold are widely used in the electronics industry to produce components used in a variety of products.  Central Africa, specifically the Democratic Republic of Congo (DRC) and nine adjoining countries – Angola, Burundi, Central African Republic, Congo Republic, Rwanda, Sudan, Tanzania, Uganda, and Zambia – is one region where these minerals are mined extensively.  Although the mining and trading of these minerals is crucial to the region’s economy, this region has been in conflict since 1998; the resulting extreme levels of violence, human rights abuses, and environmental damage are supported by the trade of Tin, Tantalum, Tungsten, and Gold, often known as: conflict minerals.

Because mineral mining and smelting is several steps removed from final product manufacture, tracing mineral origins is often challenging.  Finisar’s suppliers acquire and use minerals from multiple sources around the world, many from outside the conflict region, some from inside the region.  Finisar Corporation strives to maintain the highest standards of ethical conduct and integrity in all areas of our business.  As a manufacturer of products that contain these minerals, we are committed to procuring materials from environmentally and socially responsible sources.

It is Finisar’s policy to not purchase from known conflict sources, and we expect our suppliers abide by the same standard.  Further, it is our aim to purchase from only responsible, conflict-free sources, as validated by the Conflict Free Sourcing Initiative (CFSI).  Finisar expects our supply chain partners to establish policies, practices, and due diligence measures that work toward ensuring minerals used in our products do not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries while supporting responsible mineral sourcing in that region.

As a member of the CFSI, Finisar has adopted the CFSI standard conflict minerals reporting template.  Additionally, we require our suppliers to use this template when reporting mineral sourcing data to Finisar.  In response to periodic surveys, suppliers are expected to provide prompt, truthful, accurate, and complete data regarding conflict minerals and the smelter and mining sources reported by their suppliers.  In our review of the data we receive from our suppliers, named sources are cross-checked against the list of known smelters / refiners, and the Conflict Free Smelter list, published by the CFSI.  (www.conflictfreesmelter.org)

In addition, should we become aware of concerns about suspect mineral sourcing, from other sources within in the supply chain, which may include conflict sources, Finisar requires the supplier(s) who purchase from those sources to conduct a prompt, reasonable due diligence follow-up to: confirm the traceability of materials used, investigate suspect sources within their supply chain, and implement corrective measures as needed to ensure a conflict-free supply chain.

As a publicly traded US company, Finisar complies with the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 and the implementation guidelines published by the SEC, which require supply chain reporting and reasonable due diligence with respect to the sourcing of conflict minerals, and conflict-free status.  Finisar supports our customers’ efforts to reach the common goal of ensuring a socially and environmentally responsible supply chain.