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•	Step 1A - Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas.

•	Implemented a conflict minerals policy

•	Policy made publicly available

•	http://files.shareholder.com/downloads/AVID/0x0x758648/A80D5344-ED5B-4136-B377-776F6846BD0E/CONFLICT_MINERALS_STATEMENT.pdf

•	Policy communicated directly to suppliers as part of RCOI process

•	Step 1B - Structure internal management to support supply chain due diligence

•	Maintained an internal cross functional team to support supply chain due diligence

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•	Appointed a member of the senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence

•	Applied the resources necessary to support the operation and monitoring of these processes including internal resources and external consulting support.

•	Step 1C - Establish a system of transparency, information collection and control over the supply chain

•	Implemented a process to collect required supplier and smelter RCOI and due diligence data. Full details on the supply chain data gathering are included in the RCOI and due diligence sections of this Report.

•	Step 1D - Strengthen company engagement with suppliers

•	Directly engaged suppliers during RCOI process.

•	Reviewed supplier responses as part of RCOI process.

•	Added conflict minerals compliance to new supplier contracts and Avid’s supplier code of conduct.

•	Implemented a plan to improve the quantity and quality of supplier and smelter responses year over year.

•	Step 1E - Establish a company and/or mine level grievance mechanism.

•	Recognized the CFSP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter or mine level grievances.

•	Avid’s ethics violations reporting system allows employees to voice confidentially without any fear of retribution, any concerns with the violations of the Avid’s conflict minerals policy

•	Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance)

•	Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance)

•	Developing a list of suppliers providing 3TG containing components to Avid.

•	Contacting each supplier and requesting the industry standard Conflict Minerals Reporting Template (“CMRT”) including smelter information.

•	Reviewing supplier responses for accuracy and completeness.

•	Amalgamating supplier provided smelters into a single unique list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols.

•	Reviewing the final smelter list (and compared it to industry peers) to determine if Avid identified reasonably all of the smelters in their supply chain.

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•	Identify the scope of the risk assessment of the mineral supply chain (OECD Step 2B).

•	Assess whether the smelters/refiners have carried out all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Step 2C).

•	Where necessary, carry out, including through participation in industry-driven programs, joint spot checks at the mineral smelter/refiner’s own facilities (OECD Step 2D).

•	For each smelter identified in Avid’s supply chain

•	Avid attempted direct engagement with the smelter to determine whether or not the smelter sources from the DRC or surrounding countries

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For smelters that declared directly (e.g. email correspondence, publicly available conflict minerals policy, or information available on their website) or through their relevant industry association that they did not source from the DRC or surrounding countries, and were not recognized as conflict free by the CFSP, Avid reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration. The sources reviewed included

•	Public internet search (Google) of the facility in combination with each of the Covered Countries

•	Review of specific NGO publications. NGO publications reviewed included

•	Enough Project

•	Global Witness

•	Southern Africa Resource Watch

•	Radio Okapi

•	The most recent UN Group of Experts report on the DRC

•	For smelters that did not respond to direct engagement, Avid reviewed publicly available sources to determine if there was any reason to believe that the smelter may have sourced from the Covered Countries during the reporting period.

•	Avid reviewed the same sources as those used to compare against smelter sourcing declarations.

•	For high risk smelters (smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries), Avid requires the smelter be audited and recognized as conflict free by the CFSP.

•	For high risk smelters that have not been audited and recognized as conflict free by the CFSP, Avid communicates the risk to a designated member of senior management (OECD Step 3A) and conducts risk mitigation on the smelter according to OECD Step 3B.

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•	Additional due diligence to determine if there was any reason to believe the smelter directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.

•	Verifying with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Avid’s supply chain in the 2016 reporting period.

•	Direct engagement with the high risk smelter to verify risk and to encourage the smelter to become conflict free.

•	Refinery demonstrated an increased level of transparency in the 2016 reporting period

•	Refinery was open to discussing auditing options in 2017, but did not yet make a formal commitment to undergo an audit

•	Refinery’s supply chain due diligence systems were independently reviewed by an international compliance consulting firm

•	Avid recognizes the steps forward this refinery has taken in 2016 and continues to work directly with them to encourage them to become CFSP compliant

•	If Avid determines that this refinery does not continue to move forward towards becoming CFSP compliant in 2017, Avid will reassess the acceptability of this refinery in our supply chain.

•	Recognized by the CFSP as ‘active’ (undergoing an independent audit to an industry recognized protocol).

•	Removal of a smelter was not recommended by the CFSP as long as the smelter is recognized as active.

•	No reason to believe from publicly available sources that the gold refinery directly or indirectly financed or benefitted armed groups in the DRC or adjoining countries.

•	Does not require removal from supply chain. Scheduled for follow up in 2017 reporting period.

a.	Including a conflict minerals clause in all new and renewing supplier contracts.

b.	Continuing to drive our suppliers to obtain current, accurate, and complete information about the smelters in their supply chain.

c.	Engaging smelters sourcing from the Covered Countries to be audited and certified to a protocol recognized by the CFSP.

d.	Follow up in 2017 on smelters requiring risk mitigation, but not removal from Avid’s supply chain.

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