Exhibit 1.01

NeoPhotonics Corporation

Conflict Minerals Report

For the reporting period from January 1, 2019 to December 31, 2019

This Conflict Minerals Report (this “Report”) of NeoPhotonics Corporation (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2019 to December 31, 2019. 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.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture a product and any mineral specified in the Rule is necessary for the functionality or production of such products. The specified minerals, which we collectively refer to in this Report as the “3TG Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo and its adjoining countries, which include the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this

Report, certain of the Company’s operations manufacture, or contract to manufacture, the Covered Products (as defined below), and the 3TG Minerals are necessary for the functionality or production of those products.

Description of the Company’s Products Covered by this Report

This Report relates to products: (i) for which 3TG Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the calendar year 2019.

The Company is a leading developer and manufacturer of silicon photonics and advanced hybrid photonic integrated circuit-based lasers, modules and subsystems for bandwidth-intensive, high speed communications networks. Our products, which are referred to in this Report collectively as the “Covered Products,” include electro-optical transceivers for telecom and datacom applications, optical semiconductor devices for amplification and modulation of optical signals, semiconductor lasers and laser assemblies for transmission and modulation of optical signals, passive optical devices for optical signal management, MEMS-based optical attenuation devices and optical receivers.

The Company’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of 3TG Minerals. In this regard, the Company does not purchase 3TG Minerals directly from mines, smelters or refiners. The Company must therefore rely on its direct suppliers to provide information regarding the origin of 3TG Minerals that are included in the Covered Products, including sources of 3TG Minerals that are supplied to them by sub-tier suppliers. Moreover, the Company believes that the smelters and refiners of the 3TG Minerals are best suited to identify the sources of 3TG Minerals, and therefore has taken steps to identify the applicable smelters and refiners of 3TG Minerals in the Company’s supply chain.

Reasonable Country of Origin Inquiry

The Company conducted a good faith reasonable country of origin inquiry regarding the 3TG Minerals in its Covered Products. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the 3TG Minerals originated in the Covered Countries and whether any of the 3TG Minerals may be from recycled scrap or scrap sources. In designing its reasonable country of origin inquiry, the Company employed a combination of measures, as described in this Report, to determine whether the 3TG Minerals in its Covered Products originated from the Covered Countries and, to the extent applicable, these measures were the same as the processes and procedures the Company used for its due diligence as described below, including in particular Step 1 and Step 2 below.

In connection with its reasonable country of origin inquiry, the Company has requested information regarding 3TG Minerals in its supply chain from all of the Company’s direct suppliers sourcing materials in the Covered Products, using the Conflict Minerals Reporting Template (the “Conflict Minerals Survey”) developed by the Responsible Minerals Initiative (RMI). During the course of the year, the Company also followed up with those suppliers who had not responded to the Company’s previous requests for completion of the Conflict Minerals Survey and who previously provided incomplete responses to the Conflict Minerals Survey. The Company’s outreach for 2019 included 134 suppliers, 93% of which responded to our request for information and 8.9% of which responded that the products they supply to the Company do not include 3TG Minerals. In addition, for 2019, the Company did not send a Conflicts Minerals Survey to suppliers of its packing, chemical and optical products after concluding that 3TG Minerals are not necessary to the functionality or production of such products.

Based on the results of its reasonable country of origin inquiry, the Company has reason to believe that, during the period covered by this Report, certain 3TG Minerals used in its Covered Products may have originated in the Covered Countries and, as a result, the Company was required to conduct due diligence for 2019. These due diligence efforts are discussed below.

Due Diligence Process

Based on the results of the Company’s reasonable country of origin inquiry, the Company exercised due diligence on the source and chain of custody of the 3TG Minerals in its Covered Products. The Company’s due diligence measures are designed to attempt to ascertain the facilities used to process any 3TG Minerals in our Covered Products, the country of origin of any 3TG Minerals in our Covered Products and the mine(s) or location of origin with the greatest possible specificity.

The Company’s due diligence measures have been designed to conform in all material respects to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance specifies a five-step framework for risk-based due diligence for responsible supply chains of minerals sourced from conflict-affected and high-risk areas.

Step 1: Establish Strong Company Management Systems

Step 2: Identify and Assess Risk in the Supply Chain

As described above, the requests for information regarding 3TG Minerals in the Company’s products were sent to all of the Company’s direct suppliers sourcing materials in the Company’s products, using the Conflict Minerals Survey. Members of the Conflict Minerals Compliance Team collected and reviewed supplier responses to the Conflict Minerals Survey to identify incomplete, inaccurate or inconsistent responses, and consolidated this information in a central database. The Company followed up with those suppliers that failed to respond to the Conflict Minerals Survey or that submitted incomplete responses or responses that contained inaccuracies or inconsistencies or were otherwise determined not to be suitable. The Company also continues to work with those suppliers who have not yet provided responses or have provided incomplete responses.

To the extent that a completed response identified a smelter or refiner, the Company reviewed this information against the list of conflict free and “active” smelters and refiners and country of origin information published by RMI’s Responsible Minerals Assurance Process. For non-certified smelters and refiners, we attempted outreach to encourage their participation in certification programs. The Company also attempted to ascertain whether the smelter or refiner information provided was specific to the products supplied to the Company to determine whether the identified smelters are in the Company’s supply chain.

Step 3: Design and Implement a Strategy to Respond to Identified Risks

The Conflict Minerals Compliance Team reported the findings of its compliance efforts in respect of 2019 to the Conflict Minerals Free Management Committee who will report on an annual basis to the Board of Directors.

Pursuant to our Conflict Minerals Statement and Conflict Minerals Policy, if the Company becomes aware of instances where 3TG Minerals in our supply chain potentially finance armed groups, as defined in the Rule, we will work with our suppliers to find alternate conflict-free sources.

Further, to mitigate the risk that 3TG Minerals in our supply chain potentially finance armed groups, we intend to engage in the additional measures discussed under “Risk Mitigation Efforts” below.

Step 4: Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

Because the Company does not source 3TG Minerals directly from smelters or refiners, we rely on third parties, including RMI, to coordinate and conduct third party audits of these facilities. The Company utilizes the published results of these third-party audits to determine whether a specified smelter or refiner processes 3TG Minerals that directly or indirectly finance or benefit armed groups.

Step 5: Report on Supply Chain Due Diligence

The Company has filed a Form SD and this Conflict Minerals Report with the SEC and has made the Conflict Minerals Report available in the section on Sustainability on the Company’s website at www.neophotonics.com.

Identified Smelters and Refiners

In connection with the our reasonable country of origin inquiry or due diligence, as applicable, the Company’s suppliers identified to us the smelters and refiners listed on Annex A as having processed the necessary 3TG Minerals contained in the Covered Products. Due to the Company’s position in the supply chain, the Company relies on its suppliers for accurate smelter and refiner information. The Company’s due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG Minerals contained in the Covered Products.

As indicated in the table in Annex A, the Company has gathered the names of 359 smelters and refiners identified by its direct suppliers in the Conflict Minerals Survey. Among them, 266 are on RMI’s list of “Conformant” smelters and refiners, five are included on RMI’s list of “Active” smelters and refiners, and 88 are listed on RMI’s Smelter Look-up tab of the Conflicts Minerals Survey but are not listed as “Conformant” or “Active.” See Annex A for definitions of Conformant and Active.

Due to our position in the supply chain, which we discuss above, we rely on our suppliers for accurate smelter and refiner information. Our due diligence measures cannot provide adequate certainty regarding the source and chain of custody of the 3TG Minerals contained in the Covered Products. Of the suppliers that responded to the Conflict Minerals Survey and confirmed that 3TG Minerals are included in the products supplied to the Company, a majority (93%) of the responses received provided smelter and refiner information at the company level or were unable to specify the smelters and refiners used for products supplied to the Company. The Company is unable to determine whether any of the 3TG Minerals reported by these suppliers were contained in components or parts supplied to us, or to validate that any of these smelters and refiners are actually in the Company’s supply chain. In addition, 16% of responses to Conflict Minerals Survey Question 6 (Have you identified all of the smelters supplying the 3TG to your supply chain?) were “No”. Therefore, in addition to being unable to determine whether reported smelters and refiners are part of the Company’s supply chain, we are also unsure as to the completeness of the population of smelters and refiners received. Accordingly, the list of smelters and refiners in the table in Annex A may contain smelters and refiners that are not in our supply chain and there may be other smelters and refiners not yet identified in our due diligence process. We will continue to update the list as our information improves.

Country of Origin Information and Efforts to Determine Mine Location

Based on the Company's due diligence efforts to date, the Company does not have sufficient information to determine the country of origin of the 3TG Minerals in its Covered Products or the facilities used to process the 3TG Minerals, including whether the 3TG Minerals were from recycled or scrap sources.

Risk Mitigation Efforts

In the next compliance period, the Company will take the following steps to improve its due diligence and mitigate any risk that the 3TG Minerals in the Covered Products could benefit armed groups in the Covered Countries:

Annex A

Smelter and Refiner Information

* The information in this column is based on smelter or refiner information made publicly available by RMI as of May 14, 2020. The terms used have the following meanings: