OECD Guidance Step 1: Establish a strong company management system

The Company adopted and continually reviews and updates its responsible minerals sourcing policy, as appropriate, to reflect the procedures by which the Company and its 3TG suppliers should conduct due diligence related to conflict minerals. The Corporate Responsible Minerals Team reviews any changes to the policy or governing documents. This policy is made publicly available on the Social Responsibility Webpage.

The Company maintains an internal management team to support the supply chain due diligence, and has instituted a systematic process. This team includes employees within the Company’s supplier quality, external manufacturing operations, global sourcing and procurement, and legal departments. Additionally, the Audit Committee of the Board of Directors of the Company reviews the Responsible Minerals Compliance Program quarterly to track the progress towards the program’s goals.

The Company utilizes the conflict minerals reporting template (“CMRT”), standardized by the RMI, to gather sourcing information from its 3TG suppliers in order to identify whether: (i) conflict minerals sourced by such suppliers originated in Covered Countries or CAHRAs; and (ii) smelters and refiners (collectively, “smelters”) in our supply chain have been validated as conformant in accordance with the Responsible Minerals Assurance Process (“RMAP”) and its cross-recognized certification programs, which include the London Bullion Metal Association (“LBMA”) Responsible Gold Certification, the Responsible Jewelry Council (“RJC”) Responsible Jewelry Program Chain-of-Custody Certification and other third-party due diligence certification standards.

In addition, a summary of country of origin information for minerals used in onsemi products that we collected in connection with our RCOI and due diligence efforts is attached hereto as Appendix A.

The Company utilizes an internal compliance audit to assess and confirm that the due diligence approach followed by the Company is in accordance with OECD Guidance.

The Company established communication channels with 3TG suppliers to inquire about conflict minerals and alert such entities about the risk of using non-conformant smelters. These channels also serve as grievance mechanisms under our Responsible Minerals Compliance Program.

OECD Guidance Step 2: Identify and assess risk in the supply chain

The Company conducts an annual outreach campaign requesting the latest CMRT from each of its identified 3TG suppliers in accordance with its responsible minerals sourcing policy. The Company also sends outreach letters when RMI reports a non-conformant smelter, a high-risk smelter or a smelter that ceased operations.

The Company maintains a database and process to monitor, collect, manage and aggregate CMRT declarations received from its 3TG suppliers.

The Company uses the RMI’s facility database report to identify suppliers using smelters that are conformant to a third-party audit program assessing related supply chain risks. Additionally, the Company also utilizes the RMI’s facility database report to perform due diligence and confirm information from its 3TG suppliers.

The Company’s Responsible Minerals Compliance Team (the “RMC Team”) reviews all CMRT responses for completeness and consistency with the latest CMRT revision. As of December 31, 2024, the Company received and reviewed CMRT submissions from its 3TG suppliers.

OECD Guidance Step 3: Design and implement a strategy to respond to identified risks

The RMC Team reviews and updates its own company-level CMRT to identify risk in the supply chain for non-RMAP conformant smelters reported by 3TG suppliers in their submitted CMRTs.

The Company sends outreach or encouragement letters to 3TG suppliers to remove or replace non-conformant or high-risk smelters. When needed, the Company sends out reminders or escalation emails to request updates.

The Company conducts a risk assessment of 3TG suppliers, and suppliers are rated using a risk matrix system based on the CMRT submitted. Each supplier is assigned a risk rating ranging from “Low Risk” to “High Risk,” as further described below:

“Low Risk” means that a supplier is using 100% RMAP conformant smelters.

“Medium Risk” means that a supplier is using an active or non-conformant smelter but one which is identified as eligible to participate in the RMAP.

“High Risk” means that a supplier either is using a high-risk smelter or an ineligible entity.

OECD Guidance Step 4: Carry out an independent third-party audit of smelters’ due diligence practices

The Company is an active member of RMI, which uses an independent third-party assessment of smelter or refiner management systems and sourcing practices to validate compliance with RMAP standards. The Company relies on RMI due diligence and RMAP audit results, including the RMI RCOI report.

The RMC Team is a member of the RMI work groups that continue to develop improvements to the RMI programs and tools.

The Company also supports the RMI Smelter Assessment Fund, which encourages RMAP-eligible smelters and refiners to undergo an independent third-party assessment.

OECD Guidance Step 5: Report annually on supply chain due diligence

The Company is an indirect purchaser of conflict minerals, and its due diligence measures provide reasonable, not absolute, assurance regarding the source and chain of custody of conflict minerals. The Company’s due diligence processes seek data from its direct suppliers and those suppliers seek similar information within their supply chains to identify the original sources of the conflict minerals. We also rely to a large extent on information collected and provided by RMI’s independent third-party audit programs. Such sources of information may produce inaccurate or incomplete information and may be subject to fraud. As required, a CMRT is requested from all 3TG suppliers annually to promote a reliable and consistent due diligence process. If a supplier is found to be non-compliant with the Company’s responsible minerals sourcing policy, an escalation process is initiated to determine appropriate remedial measures, which may include removing the supplier from our supply chain.

The Company publicly posts and regularly updates its own company-level CMRT on its website at https://www.onsemi.com/pub/Collateral/CMRTRM.XLSX.

“Conformant” means that a smelter has been independently assessed and found conformant with the relevant RMAP standard and is included in the Standard Smelter List.

“Active” means that a smelter has been engaged in the RMAP program but has not yet been determined to be conformant and is included in the Standard Smelter List.

“Non-conformant” means that a smelter meets the definition of a smelter or refiner, is identified as an eligible smelter, has been independently assessed and found non-conformant with the relevant RMAP standards and is included in the Standard Smelter List.

The Company has incorporated conflict minerals compliance requirements into its supplier handbook for all suppliers.

The Company has incorporated conflict minerals compliance requirements and checkpoints into its business processes for new product introduction, new supplier qualification and change management.

The Company reviews and evaluates supplier data that it receives, including by comparison with the RMI’s RCOI report and other available data, with a view to increasing the reliability of its information and processes and the completeness and accuracy of such information.