In August 2012, the Securities and Exchange Commission (SEC) published regulations implementing the conflict minerals reporting obligations of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The SEC’s conflict minerals regulations apply to United States companies required to report to the SEC. Conflict Minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tin, gold, tantalum and tungsten (collectively, referred to as “3T&G”) that originate in the Democratic Republic of the Congo or an adjoining country.

MoSys, Inc. (MoSys or the Company) is committed to a socially responsible supply chain that is free of Conflict Minerals from sources that finance armed conflict. MoSys does not purchase directly from smelters or refineries and must rely upon its manufacturing subcontractors to identify their sources of 3T&G minerals, identify the sources of 3T&G minerals used in the manufacture of MoSys’ products and declare whether any of the 3T&G used in the manufacture of MoSys products is a Conflict Mineral. MoSys’ due diligence was based on the Electronic Industry Citizenship Coalition and Global e-Sustainability (“EICC/GeSI”) initiative with the smelters and refiners that provide 3T&G to MoSys’ suppliers. MoSys’ due diligence measures included:

  • Conducting a supply-chain survey with direct suppliers of materials containing 3T&G using the EICC/GeSI Conflict Minerals Reporting Template to identify the smelters and refiners
  • Comparing the smelters and refiners identified in the supply-chain survey against the list of smelter facilities which have been identified as “conflict free” by programs such as the EICC/GeSI Conflict Free Smelter (“CFS”) program for 3T&G; and
  • Reviewing our suppliers’ conflict minerals policies to ensure that they are encouraging their suppliers to not source from refiners, smelters and other suppliers that may use Conflict Minerals.

MoSys expects its manufacturing subcontractors to have in place policies and due diligence measures that will enable the Company to obtain reasonable assurance that purchased materials do not include Conflict Minerals or that steps are being implemented by the manufacturing subcontractors to ensure Conflict Minerals will not be used in the future to manufacture MoSys’ products.