This report for the year ended December 31, 2025 is presented to comply with Section 13(p) of the Securities Exchange Act of 1934 and Rule 13p-1 (the "Rule") and Form SD thereunder. The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict. 

 

Design of Conflict Minerals Due Diligence Program

 

The design of our conflict minerals due diligence program is in conformity with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, "OECD Guidance"), specifically as it relates to our position in the minerals supply chain as a "downstream" purchaser. We designed our due diligence program, management and measures to conform in all material respects with the framework OECD Guidance. 

 

Description of Performed Conflict Minerals Due Diligence Program

 

(i)	Maintaining of Strong Company Management Systems

 

Suppliers and manufacturers (including smelters and refiners) of products which include Conflict Minerals which are "necessary to the functionality of the products" were identified through our CMRT analysis.

We identified two primary risks in our supply chain: (1) not receiving on time and accurate information from the suppliers and manufacturers; and (2) reliance on suppliers and manufacturers who are not conflict-free while pursuing our goal of becoming a conflict free company. This assessment assisted us to segment our suppliers and manufacturers into three risk levels (high, medium and low), on which we based our risk strategy.

We conducted a survey of our active suppliers and manufacturers using the template developed by RMI, known as the Conflict Minerals Reporting Template ("CMRT"). Suppliers and manufacturers were requested to use version 6.1 of the CMRT, or newer versions.

We encourage our suppliers and manufacturers to purchase from RMI Compliant Smelters, and we rely on the RMI compliant and active smelters list, which is available on the RMI website.

 

Results of our Assessment

 

As a downstream purchaser of conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and manufacturers and those suppliers and manufacturers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also gather required CMRT information from websites of suppliers and manufacturers where conflict minerals reports were available. We also rely, to a large extent, on information collected and provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud because the information gathered from our suppliers and manufacturers is not on a continuous, real-time basis.

 

Supplier Chain Survey Responses

 

 

As we are attentive to market requests, we asked several of these suppliers and manufacturers to provide data at a "Company" level as well as at a "Product" level, and such suppliers and manufacturers provided the data at both levels.

 

Below is a summary of the country of origin information collected as a result of our RCOI efforts.

 

Smelters and refiners verified as conflict free (compliant) or in the audit process:

A number of the smelters and refiners detailed above provided more than one necessary conflict mineral.

 

List of the facilities which, to the extent known, processed the necessary conflict minerals used in our products can be found in Appendix 1.

 

Continuous Improvement Efforts to Mitigate Risks

 

During the reporting period for the calendar year ending December 31, 2025, we are continuing to engage in the diligence process described above.

 

We intend to follow up with high risk non-responsive or non-compliant suppliers and manufacturers, work with suppliers and manufacturers to educate them on conflict minerals sourcing, contact selected smelters and refiners that have not received a "conflict free" designation and more. In the event that any of our suppliers and manufacturers do not cooperate with us and do not respond to our efforts in a satisfactory manner, we will disqualify them and remove them from our approved suppliers and manufacturers list.

 

In the event that we continue to engage with suppliers and manufacturers who have not completed their RCOI process, we will ask such suppliers and manufacturers to complete the process and become conflict free at a company or product level as a condition to our continued engagement with them.

 

In addition, being attentive to the market and to our customers, we are currently in the process of qualifying our line of products as "conflict free" by, among other things, requesting from all of our direct suppliers and manufacturers to qualify the goods supplied by them to Silicom as "Conflict Free", replacing, where possible and appropriate, non-compliant suppliers and manufacturers with compliant ones and removal of non-compliant vendors from our approved vendors list.

 

Appendix 1

 

List of smelters used in Silicom's products: