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A.	Design of Analog Devices’ due diligence framework

B.	Description of Analog Devices’ due diligence measures performed with respect to products manufactured during 2014

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•	Continuing our participation as a member company in the Conflict-Free Sourcing Initiative (CFSI), under sponsorship of the Electronic Industry Citizenship Coalition (EICC).

•	Communicating to our suppliers and the public our DRC Conflict Free sourcing policy for the supply chain of minerals originating from Conflict-Affected and High-Risk Areas. Our Conflict Minerals Policy Statement can be found on our website at www.analog.com.

•	As part of our risk management plan:

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Updating our purchase order terms and conditions to require suppliers that obtain conflict minerals from smelters whose minerals originate from the Covered Countries to use only those smelters that either (1) submit to a conflict-free certification audit or (2) participate in the EICC/GeSI Conflict – Free Smelter Program (CFSP). Suppliers are subject to an audit by Analog Devices to confirm the supplier’s compliance with these requirements.

◦	Increasing our engagement with direct suppliers and providing guidance regarding training materials from the CFSI, which aims to improve the quality and quantity of smelter information received from suppliers using the CFSI Conflict Minerals Reporting (CMR) template for this reporting period.

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Reassessing all of our products and suppliers in order to identify conflict minerals scope and risk in our supply chain. Analog Devices’ existing suppliers were evaluated for use of conflict minerals through a review of internal documents, including bills of material, materials declarations and purchasing contracts. New suppliers were assessed as part of the General Procurement Specifications (GPS) applied to all new suppliers. Suppliers identified as providing materials to Analog Devices that include conflict minerals were aggregated onto an electronic tracking spreadsheet.

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Conducting a reasonable country of origin inquiry (RCOI) by circulating a supply-chain survey with direct suppliers included on the electronic tracking spreadsheet using the EICC/GeSI CMR Template. The purpose of this supplier survey was to identify, if possible, the smelters and refiners that supply necessary conflict minerals in our Products. In 2014, we surveyed 316 suppliers and received 224 responses or a 71% response rate.

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As part of our risk management plan, verifying that direct suppliers completed all pertinent sections of the CMR template and making follow-up inquiries as necessary to obtain responsive information from as many suppliers as possible. For non-responsive suppliers, we will continue to engage with the supplier to obtain a survey response. If a supplier fails to provide survey information, we will take measures up to and including termination of our relationship with the supplier.

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Comparing the smelters and refiners identified by direct suppliers via the CMR template against the list of smelter and refinery facilities that have received a “conflict free” designation (such as through the CFSP’s lists for tantalum, tin, tungsten and gold) by participating in an independent third party smelter audit. The responses from our suppliers listed 255 entities as smelters or refiners of conflict minerals in their supply chains. 150 of these entities were identified as conflict-free by our suppliers. Analog Devices compared the identified entities to the CFS list of smelters and we confirmed that all conflict-free entities reported by our suppliers were in fact designated as conflict-free by the CFSP. The following is a summary of the smelters used by our suppliers broken out by mineral type:

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•	Selecting a software package to replace the internally managed spreadsheets and allow for improved monitoring of our suppliers.

•	Participating in industry initiatives and engaging in direct contact with vendors to increase the response rate of suppliers’ supply-chain surveys.

•	Contacting smelters identified as a result of the RCOI process and requesting their participation in obtaining a “conflict free” designation from an industry program such as the EICC/GeSI Conflict Free Smelter program or equivalent, if they have not already done so.

•	As more smelters participate in the CFSP, comparing RCOI results to information collected via independent conflict free smelter validation programs.

•	Implementing the software package that we have selected to replace the internally managed spreadsheets and allow for improved monitoring of our suppliers.

•	Obtain an independent assessment of the current state of our due diligence framework for alignment with the OECD Framework.

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