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•	Transmitters which use a laser plus direct or indirect modulation to convert electrical signals into optical signals for transmission over fiber optics;

•	Receivers which incorporate photodetectors and convert incoming optical signals into electrical signals;

•	Transceivers which combine both transmitter and receiver functions in a single device;

•	Transponders which include a data serializer-deserializer function that would otherwise reside in the customer’s equipment if a transceiver were used; and

•	Active Optical Cables that combine two transceivers and a fiber optic cable that are built into an integrated cable assembly.

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•	66 of our direct suppliers confirmed the use of either gold, tin, tantalum, or tungsten in the products they supplied to Finisar;

•	32 of our direct suppliers reported that the products supplied to Finisar do not include gold, tin, tantalum, or tungsten; and,

•	20 of our direct suppliers provided no data as to whether the products supplied to Finisar include gold, tin, tantalum, or tungsten.

•	In April 2011, we adopted our Conflict Minerals policy, which was revised in 2012 and 2014. The current policy statement is posted on our website;

•	We established a cross-functional Conflict Minerals Working Group under the direction of our Global Quality System Manager and including representatives of our Legal, Finance, Global Supply Chain, and Internal Audit Departments. This group reports its activities to our executive management at quarterly-scheduled meetings and bi-annually to the Audit Committee of our Board of Directors;

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•	We communicated the Company Policy to our direct suppliers and requested that they execute and return the EICC-GeSI Conflict Minerals Reporting Template;

•	We established an audit and investigation process in our supply chain to identify processing facilities that serve as sources of Conflict Minerals to our direct suppliers; and,

•	We adopted our Conflict Minerals Due Diligence and Reporting procedure to receive inquiries and grievances regarding our conflict minerals programs and practices.

•	Between February 2012 and December 2013 we followed up with our direct suppliers to obtain additional information regarding their conflict minerals policies and due diligence practices;

•	We identified suppliers with incomplete smelter data or survey responses that suggested additional investigation was required. These suppliers were automatically added to the second round of surveys in the latter half of 2012;

•	Suppliers with incomplete survey responses in 2012 were automatically included in the 2013 survey. Suppliers, whose survey responses warranted, were sent follow-up inquiries on specific elements of the survey;

•	The supplier responses for smelter and mine data were consolidated to eliminate duplicate responses. From this consolidation, the sources or smelters that were reported by multiple suppliers could be identified. We used our suppliers’ responses to begin to identify smelters, processing facilities and country of origin data;

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We followed the guidelines established by the EICC and referenced the Conflict-Free Sourcing Initiative (www.conflictfreesemlter.org), and the smelter lists published therein. We cross-checked information received from our suppliers with data available from industry organizations, information obtained from our customers, and our own research to determine which facilities are compliant with the Conflict Free Sourcing Program developed by the EICC and the GeSI (the “CFSP”); and

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We established a follow up investigation procedure to respond to customers’ or other interested parties’ inquiries regarding potential suspect suppliers. If we become aware of concerns about suspect mineral sourcing, we require the supplier purchasing from the suspect source to investigate and conduct traceability of materials, implement corrective actions if necessary, and provide assurance of a conflict-free supply chain.

•	We have developed procedures for sending supply-chain inquiries to our top 100 suppliers on an annual basis, reviewing their responses, consolidating the information in a central database and following up with the suppliers to address any incomplete or inconsistent responses;

•	We continue to follow and consult the EICC guidelines, CFSI, and other industry-sponsored programs, events, and best practices;

•	We report information on the sources and chain of custody of Conflict Minerals used in our products to our executive management and the Audit Committee of our Board of Directors;

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•	We require our suppliers to conduct investigations of any smelters identified as high-risk and work with our suppliers to address compliance issues and to transition their processing to CFSP compliant smelters; and

•	We will take appropriate action, including the discontinuation of the supply relationships, when we determine that our suppliers are not adhering to the Company Policy.

•	We will file an annual report with the Securities and Exchange Commission (the “SEC”) on Form SD, together with any required Conflict Minerals Report and report of independent private sector auditor;

•	We will make all such SEC reports available on our website;

•	We will refer to our conflict minerals program, as appropriate, in other reports that we file with the SEC; and

•	We will provide our EICC-GeSI Conflict Minerals Reporting template to customers and other qualified interested parties upon request.

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•	We will continue to engage with our direct suppliers and, in partnership with those suppliers, engage with their supply chain, smelters and processing facilities, to obtain current, accurate and complete information regarding our Conflict Mineral sources;

•	We will continue to encourage our direct suppliers to adhere to the Company Policy, to continue to refine their own due diligence program, and to encourage smelters in the supply chain to obtain a “conflict-free” designation from an independent, third-party audit program; and,

•	We will advise our suppliers that we intend to cease doing business with suppliers who continue to source Conflict Minerals from smelters that are not certified as “conflict-free.”

•	We will utilize the services of a leading compliance information solutions vendor, which should provide data on approximately 50 additional vendors whose products we purchase through distributors.