MaxLinear Conflict Mineral Policy

As a fabless semiconductor company supplying Integrated Circuits (ICs) to customers worldwide, MaxLinear uses only world-class manufacturers to produce its products. MaxLinear’s supply chain spans the globe, with suppliers in many countries.

MaxLinear’s suppliers also have their own suppliers for the materials used in MaxLinear’s products. In particular, some or all of these minerals may be used in the manufacture of MaxLinear’s products:

  •  Gold 
  •  Tantalum (columbite-tantalite ore and its derivatives) 
  •  Tin (cassiterite ore and its derivatives) 
  •  Tungsten (wolframite ore and its derivatives) 

The United States government has identified these four minerals as being potentially “conflict minerals,” which originate in the Democratic Republic of the Congo (DRC) or certain adjoining countries. In August 2012, the Securities and Exchange Commission (SEC) adopted requirements that require publicly-traded companies to report annually concerning the presence of “conflict minerals” that are necessary to the functionality or production of products they manufacture or contract to manufacture.

  1.  MaxLinear has taken the following actions to ensure that no conflict minerals are used in its products: 
  2.  MaxLinear has notified its manufacturing suppliers that, to the best of their ability or knowledge, they are not to source any conflict minerals and use them in MaxLinear’s products. MaxLinear requires each of its manufacturing suppliers to complete the Electronics Industries Citizenship Coalition (EICC) Conflict Minerals Survey and to comply with the EICC Code of Conduct, which requires that suppliers have a policy to reasonably assure that the tantalum, tin, tungsten, and gold in the products they manufacture are conflict-free. Suppliers must ensure that all parts used to manufacture products supplied to MaxLinear originate from certified conflict-free smelters validated as compliant to the EICC Conflict-Free Smelter (CFS) protocol, using the CFS Compliant Smelter List. The CFS program is a global program where an independent third-party evaluates a smelter’s procurement activities and determines if the smelter demonstrated that materials they processed originated from conflict-free sources. Through this industry-collaborative effort, smelters are audited globally. The list of compliant smelters and refiners is posted at www.conflictfreesmelter.org

The use of conflict minerals in the electronics industry is extremely complicated due to the multi-layered international supply chain. MaxLinear expects its suppliers to use materials that are environmentally safe and sourced from socially responsible suppliers.