Exhibit 1.01

Cubic Corporation (“Cubic”) is a leading international provider of cost-effective systems and solutions addressing the mass transit and global defense markets’ most pressing challenges. We have significant transportation and defense industry expertise which, combined with our innovative technology capabilities, contributes to our leading positions with our customers.

Cubic’s manufacturing processes use a wide array of products which may contain tin, tantalum, tungsten or gold (collectively known as “3TG”). As these materials are necessary to the functionality of many Cubic products, our company is dedicated to tracing the origin of these metals. Cubic is working to ensure our sourcing practices do not support conflict or human rights abuses in the Democratic Republic of the Congo (“DRC”) and surrounding areas (collectively with the DRC, the “Covered Countries”). Cubic’s statement on supply chain responsibility can be found at https://www.cubic.com/corporate-responsibility.

Over the past fiscal year, Cubic made great strides in organizational commitment to programs supporting supply chain and vendor risk with the acquisition of the OneTrust Vendor Risk Management module. This tool is the keystone of Cubic’s Supply Chain Compliance department supporting the supplier risk evaluation and documentation process. Cubic’s strategy of increased resource building for top tier suppliers advanced further this year with an increased supplier response rate and more complete data reported on the Conflict Minerals Reporting Templates (“CMRT”) that we received from our suppliers. Cubic takes its responsibility as an ethical company seriously, and we continue to perform diligence on our supply chain and report our findings accordingly.

During calendar year 2019, Cubic and its subsidiary companies have manufactured or contracted to manufacture products for which 3TG is necessary to the functionality or production. Cubic’s reasonable country of origin inquiry (“RCOI”) and subsequent due diligence identified 34 smelters who our supply chain has reported as potentially sourcing from at least one of the covered countries. All 34 smelters that were identified to us by our suppliers as sourcing from at least one of the covered countries were conformant with the Responsible Mineral Assurance Process (“RMAP”), which means that the smelters complied with the RMAP due diligence assessment protocols or an equivalent cross-recognized assessment. Notwithstanding this assurance, since we rely on information from our suppliers as reported to us in the CMRTs and since not all of our suppliers were able to identify country of origin from which the smelters they use source minerals as further described below, we have concluded in good faith that Cubic cannot definitively state whether its sourcing practices directly or indirectly funded armed groups in the Covered Countries.

9333 Balboa Avenue, San Diego, CA 92123 • P.O. Box 85587, San Diego, CA 92186-5587

858-277-6780 • Fax 858-277-1876

www.cubic.com • NYSE: CUB

Cubic employed a combination of measures to determine whether the necessary 3TG in Cubic’s products originated from the Covered Countries. Cubic’s RCOI methods are discussed in Section 3 of this disclosure. As a result of these findings, Cubic has exercised and continues to exercise due diligence on the source and chain of custody of 3TG minerals in a manner that conforms to an internationally recognized due diligence framework (the Organization for Economic Cooperation and Development, or “OECD”)¹. Cubic hereby submits its Conflict Minerals Report as the attached Exhibit 1.01, as required by Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”).

The table below shows improved metrics on supplier scoping and response and highlights the work Cubic’s Supply Chain Compliance team has done to improve strategic development of its supply-base, targeted inquiries, vendor communications, and vendor capacity building.

The table below shows the number of responsive suppliers who stated that their products contained the 3TG minerals and indicates the number of those suppliers who stated that all smelters/refiners for that mineral had been identified. Increased ability to identify all smelters within a mineral supply chain indicates maturity in a mineral sourcing program.

Proper smelter identification continues to be a difficult issue to resolve in conducting diligence. Smelters are often known by different names and smaller smelting operations may not be identified. The table below shows how many smelters or refiners (“SORs”) Cubic identified in its supply chain and their RMAP conformance status. Although Cubic does not have any direct relationships with SORs, Cubic’s membership with the Responsible Mineral Initiative (“RMI”) supports the audit and process development of the remaining 63 identified smelters not yet conformant with the RMAP audit protocol and still in operation.

¹ Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

To begin the RCOI for this reporting year, Cubic’s Supply Chain Compliance Analyst collected consolidated purchasing data from Cubic’s ERP system in October of 2019.

Cubic’s transition to a company-wide ERP system aided the process of supplier scoping for 3TG by providing a baseline of vendor identification data and commodity/cost data. As is Cubic’s standard process, the commodity list is reviewed by our Engineering team to determine which commodities would contain 3TG. Using this list as a basis, suppliers are sorted by whether they are in-scope of our RCOI (where it is likely that 3TG is intentionally added or used in the purchased product or production process) and arranged by total cost of purchased products. Suppliers providing parts containing 3TG to Cubic account for a small minority of Cubic’s total suppliers (roughly 14% of Cubic’s total suppliers).

Cubic assigned suppliers into three risk level groups based on the amount of spend (higher spend equates to a higher risk level). These risk levels are shown in the table below.

The table below reflects a shift in the way Cubic approaches supplier management. In accordance with OECD best practice guidelines, we are developing long-term strategic partnerships with fewer suppliers as opposed to short-term arrangements with many suppliers.

Once the grouping was complete, Cubic’s Compliance Analyst requested in-scope suppliers to report their 3TG sourcing information on the most recent revision (5.12) of the industry standard CMRT provided by the RMI (Responsible Mineral Initiative).

As in past years, Cubic encountered some resistance from distributors, who frequently state that they do not track this information. As compliance with these requests is mandated by our standard terms and conditions, Cubic continued to engage with these suppliers and stress the importance of our requirements.

The table below illustrates the breakdown of mineral origin from supplier responses containing a CMRT:

Conflict Minerals Report

Cubic’s due diligence process is modeled after the 3^rd Edition of the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains, Supplements on Tin, Tantalum, Tungsten, and Gold (“OECD Guidance”). The OECD Guidance highlights the importance of risk assessment and mitigation, supplier and smelter engagement, and the identification of red flags in the supply chain.

Due to the high non-response or incomplete response rate of several Cubic suppliers coupled with Cubic’s downstream position in the supply chain, Cubic has relied heavily on industry initiatives, such as the RMI CMRT and its membership in the Responsible Mineral Initiative in order to ascertain the origin of the minerals in the components Cubic purchases. Cubic continues to explore ways to increase its participation in these industry efforts in order to facilitate a greater transparency and more open communication from mine to manufacturer.

Cubic has adopted a supply chain policy entitled Corporate Social Responsibility in Supply Chain Management which is based on the OECD Model Supply Chain Policy. This policy sets forth Cubic’s commitment to avoiding doing business with any company sourcing from the DRC or otherwise contributing to armed conflict or human rights abuses anywhere in the world. It also sets forth a summary of Cubic’s diligence process as detailed in Appendix A to this Conflict Minerals Report below.

As Cubic continues to improve its supply chain processes, Cubic has amended and improved its policy to reflect current best practices in fuller detail in accordance with OECD guidance and its policy is publicly available on its website (via the link to this filing). Cubic has also either amended or is in the process of amending U.S. and International terms and condition to require our suppliers to source only from conflict-free smelters and mines, and to provide us confirming information upon request.

In accordance with the OECD Guidance, Cubic has assigned senior level representatives from procurement and legal to oversee and jointly run its Conflict Minerals Team. Part of the Team’s legal function is to periodically report to the Board to outline current status of RCOI, diligence, and overall compliance efforts. Cubic continues to improve its communication processes and ensure availability of resources to support the Conflict Minerals Team and its overall supply chain compliance efforts.

We have established a dedicated email address for employee and supplier questions or concerns on conflict minerals and included that email address in the training seminars. Senior management’s goal is to create and maintain awareness around conflict minerals and supply chain transparency generally and to continue to live our core value of “Doing The Right Thing” in all procurement activities. This is reflected in annual training to procurement staff on Cubic’s ethical sourcing program and how their actions affect the risk of contributing to human rights abuses within Cubic’s supply chain. They are advised to review and consider a supplier’s conformance to Cubic’s ethical sourcing program requirements as part of the procurement decision during supplier selection.

Cubic has historically encountered considerable difficulty in identifying upstream suppliers in its supply chain. This is because Cubic purchases many components necessary to its products from large distribution companies which are not subject to Rule 13p-1. Those distribution companies often purchase their stock of components from other distributors, and chain of custody and origin information is not being passed through the distribution network.

Cubic continues to work with its direct suppliers and distributors to reach further upstream and engage those upstream companies in a more effective way — namely, to avoid the use of non-Conflict Free Smelters and move towards sourcing from Conflict Free Smelters only. Cubic sometimes requires obsolete parts which limit our choice of suppliers; however, these parts were generally manufactured prior to the conflict mineral rule’s cut-off date and any 3TG in them would therefore be considered outside of the scope of Section 1502 of the Dodd-Frank Act.

All the relevant supplier compliance documentation is housed on a dedicated file share website where quality, procurement and legal employees can easily check or reference the documentation. We continue to work on a system where supplier ratings will be more informative and complete and will allow us to act accordingly when presented with red flags during the diligence process.

Due to Cubic’s position as a downstream manufacturer, Cubic does not have any direct relationships with smelters or refiners. To help support the third party audit work done by RMI, Cubic became a member of RMI in 2014 and remained a member throughout this reporting period and presently. Cubic considers third party audits by the RMI to be vital to the continued development of the mining industry in the Democratic Republic of the Congo and will continue to support RMI audit initiatives.

Cubic is committed to compliance with Rule 13p-1 not only as a legal requirement, but as a responsible business practice. We strive for transparency in our supply chain and will present our diligence and risk findings annually, as well as provide details about our ongoing efforts on our website at https://www.cubic.com/corporate-responsibility. Cubic is also trying to improve the quality and nature of existing information about smelters, so we have included our own research notes on each smelter within the CMRT we provide our own customers.

Cubic has not been able to ascertain with certainty the origin of all the 3TG minerals necessary to the production of its products. These minerals are present in all of the electronics Cubic manufactures (specific products and components which contain 3TG are mentioned below in conjunction with the manufacturing facility mentioned). Tin is used as a base for solder on all circuit boards, wires and cables, and in alloys; tantalum is the primary mineral component in capacitors; gold is a non-corrosive lead on circuit boards and connectors; and tungsten is used in wire or as counterweights. This is just a sample of the many uses for these minerals in Cubic’s products and is not exhaustive. As nearly all of Cubic’s products lines depend on 3TG minerals, all of these product lines are similarly affected. Cubic maintains manufacturing facilities in San Diego, California; Tijuana, Mexico; Tullahoma, Tennessee; Orlando, FL; Auckland, New Zealand; and Salfords, Redhill in the United Kingdom (“UK”).

Cubic’s facilities in San Diego, Tijuana, Orlando, and Auckland are dedicated to manufacturing processes for Cubic’s defense-related businesses. The Tijuana facility supports manufacturing for both the defense and the transportation business. These four facilities manufacture systems and components for its air, ground, and virtual training systems, data links, and personnel locator systems. Tijuana also manufactures hardware and cabling to support Cubic’s transportation business’s point-of-sale and farebox devices.

GATR Technologies in Huntsville, Alabama manufactures inflatable, portable satellite communication antennas. GATR’s location in Ashburn, Virginia manufactures a range of rugged deployable and tactical communications products including specialized gateways to vehicular telematics systems.

Cubic’s facility in Tullahoma is the primary manufacturing location for Cubic Transportation Systems. The Tullahoma facility manufactures Cubic’s point-of-sale and farebox devices, driver control units, gates, ticket validators, vending devices, back office encoders, and depot computers.

Cubic’s facility in the UK performs light manufacturing work, such as installing upgrades or repairing equipment.

Cubic’s diligence process revealed that many of its responding suppliers provide Cubic with products which are sourced from recycled and scrap, as well as from RMAP-conformant smelters. Without the software solution used in previous years, supplier data gathering, compiling and cleansing was done manually by our Compliance Analyst. The processing of 22,875 lines of smelter data was made more manageable with an excel file created by our Compliance Analyst that validates incorrect data using previous year’s smelter analysis. This in-depth analysis produced a list of 330 legitimate smelters. However, as mentioned above, we were encouraged by the high representation of RMAP-conformant smelters in our supplier CMRTs.

Cubic’s current process identified the RMAP-conformant or LBMA-certified smelters (LBMA has added a materials traceability element to their certification process which meets the requirements of the RMI Conformance Program) set forth in Appendix B.

Appendix A

Corporate Social Responsibility in Supply Chain Management Policy

Cubic Corporation recognizes the significant adverse impacts of procuring goods that fund human rights abuses. As a responsible corporate citizen, we take a stand to respect human rights and not contribute to global conflict in the way we do business. Cubic has developed this policy on Corporate Responsibility in Supply Chain Management to set forth its commitment to refrain from any action which contributes to the financing of conflict or which supports or encourages unlawful labor practices, and to comply with relevant United Nations sanctions resolutions and, where applicable, domestic laws implementing such resolutions.

This Policy is applicable to all Cubic companies.

Cubic will neither tolerate, nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:

We will immediately suspend or discontinue engagement with any supplier where we identify a reasonable risk that it is sourcing from, or linked to, any party committing serious abuses as defined in this paragraph.

Cubic will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling, or export of minerals. "Direct or indirect support" includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:

We will immediately suspend or discontinue engagement of any supplier where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in this paragraph.

To aid in the fight against human rights abuses, Cubic has developed diligence frameworks based on the OECD Due Diligence Guidance on Responsible Supply Chains to target the use of conflict minerals in funding non-state armed groups as well as human trafficking in our supply chain worldwide. These frameworks are unique; however, both programs involve supplier audits and certifications; risk analysis, verification, and mitigation; diligence; training (both internal and external); and public reporting. Supplier certification is required in order to do business with Cubic.

Cubic’s manufacturing operations often require the use of components containing tantalum, tin, tungsten, and gold (“3TG”). Regardless of their country of origin, these minerals are known as “conflict minerals.” Cubic strives to procure components that are not manufactured using conflict minerals that directly or indirectly fund non-state armed groups. To achieve this goal, Cubic has implemented procedures to conduct diligence on and analyze its supply chain. This diligence includes periodic supplier visits, conducting an onsite Supplier Business Survey with questions on supply chain compliance, and annual country of origin inquiries. These inquiries consist of contacting Cubic’s suppliers of components containing 3TG and inquiring as to the country of origin of their component parts. Cubic maintains this information in a database so it can easily ascertain whether a certain supplier provides conflict-free components to Cubic.

Cubic also requires suppliers to supply conflict-free materials to Cubic, and to provide records evidencing the conflict-free status of the materials upon our request.

APPENDIX B

List of RMI-Conformant or LBMA-Certified Smelters

GOLD

Mine locations: Afghanistan, Albania, Angola, Argentina, Australia, Austria, Azerbaijan, Belgium, Bolivia, Brazil, Bulgaria, Burkina Faso, Burundi, Canada, Central African Republic, Chile, China, Colombia, Dominican Republic, Ecuador, England, France, Germany, Ghana, Guinea, Guyana, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, Kenya, Korea, Kyrgyzstan, Liberia, Malaysia, Mauritania, Mexico, Mongolia, Peru, Philippines, Poland, Portugal, Republic of the Congo, Russia, Rwanda, Singapore, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan, Tanzania, Thailand, The Netherlands, Turkey, Uganda, USA, Uzbekistan, Zambia, Zimbabwe, countries identified as L1, L2, and L3, and “Europe.”

TIN:

Mine Locations: Australia, Belgium, Bolivia, Brazil, Burundi, Central Africa, China, DRC, Indonesia, Laos, Malaysia, Morocco, Myanmar, Peru, Philippines, Portugal, Republic of Congo, Rwanda, Spain, Thailand, Uganda, Viet Nam, and countries identified as L1, L2, and L3.

TUNGSTEN

Mine locations: Australia, Austria, Bolivia, Brazil, Canada, China, Colombia, Georgia, Germany, Korea, Mexico, Nigeria, Portugal, Russia, Rwanda, Spain, Thailand, USA, Viet Nam, and countries identified as L1 and L3.

TANTALUM

Mine locations: Australia, Austria, Bolivia, Brazil, Burundi, China, DRC, Ethiopia, Germany, India, Japan, Kazakhstan, Mexico, Mozambique, Namibia, Nigeria, Russia, Rwanda, Sierra Leone, Thailand, USA, Zimbabwe, and countries identified as L1, L2, and L3.