Exhibit 1.01
Conflict Minerals Report of Vistance Networks, Inc. (formerly known as CommScope Holding Company, Inc.)
For the Calendar Year Ended December 31, 2025
Pursuant to Rule 13P-1 Under The Securities Exchange Act of 1934
Vistance Networks, Inc. (formerly known as CommScope Holding Company, Inc.) presents this Conflict Minerals Report for the reporting period of January 1, 2025 to December 31, 2025 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission. The Company changed its name from CommScope Holding Company, Inc. to Vistance Networks, Inc. effective January 14, 2026. Unless otherwise specified or unless the context otherwise requires, references to “the Company,” “we,” “us” or “our” refer to Vistance Networks, Inc. (formerly known as CommScope Holding Company, Inc.) and its consolidated subsidiaries.
Effective April 1, 2025, following the divestiture of the Distributed Antenna Systems (DAS) business unit on January 1, 2025, the Company renamed its Networking, Intelligent Cellular & Security Solutions (NICS) segment to RUCKUS.
On January 9, 2026, the Company finalized the sale of its Connectivity and Cable Solutions (CCS) segment to Amphenol Corporation. In connection with the divestiture of the CCS segment, and effective upon the closing of that transaction on January 9, 2026, the Company renamed its Access Network Solutions (ANS) segment to Aurora Networks (Aurora).
Overview of our Conflict Minerals Program
The Company is a leading global provider of infrastructure solutions for communication, data center and entertainment networks. In 2014, our leaders defined a sustainability philosophy on corporate responsibility that embraces our core company values. In keeping with our values and supporting our efforts to respect people and our planet, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner and source raw materials only from reputable organizations pursuant to our Conflict Minerals Policy (the “Policy”) and following the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, third edition. The Policy is available on our website at https://webresources.vistancenetworks.com/download/assets/Responsible+Mineral+Sourcing+Policy/a373bfcaf76511f089076a092ffd85e3
Our Products
Conflict minerals in the form of tin, tantalum, tungsten and gold were necessary to the functionality or production of products we manufactured or contracted to have manufactured during 2025 within our reportable segments (as reported in our Annual Report on Form 10-K for the year ended December 31, 2025) as follows:
•RUCKUS (formerly known as NICS) - Provides wireless networks for enterprises and service providers. Product offerings include indoor cellular solutions such as indoor and outdoor Wi-Fi and long-term evolution access points, access and aggregation switches; an Internet of Things suite, on-premises and cloud-based control and management systems; and software and software-as-a-service applications addressing security, location, reporting and analytics.
•Aurora (formerly known as ANS) - Includes cable modem termination systems, video infrastructure, public key infrastructure solutions, distribution and transmission equipment and cloud solutions that enable facility-based service providers to construct a state-of-the-art residential and metro distribution network.
The CCS segment provides fiber optic and copper connectivity and cable solutions for use in telecommunications, cable television, residential broadband networks, data centers and business enterprises. The CCS portfolio includes network solutions for indoor and outdoor network applications. Indoor network solutions include optical fiber and twisted pair structured cable solutions, intelligent infrastructure management hardware and software and network rack and cabinet enclosures. Outdoor network solutions are used in both local-area and wide-area networks and “last mile” fiber-to-the-home installations, including deployments of fiber-to-the-node, fiber-to-the-premises and fiber-to-the-distribution-point to homes, businesses and cell sites. This segment was reflected as a discontinued operation, retrospectively for all periods presented beginning in the fourth quarter of 2025, in our Annual Report on Form 10-K for the year ended December 31, 2025, and was sold in the first quarter of 2026 as discussed above. However, the CCS products are included in this report, since the Company manufactured or contracted to have these products manufactured in the year ended December 31, 2025.
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) and due diligence on the source and chain of custody using the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”) to determine whether any of the necessary conflict minerals in our 2025 products originated in the Democratic Republic of the Congo (“DRC”) and the adjoining countries (the “Covered Countries”) or were conflict minerals from recycled or scrap sources. The term "conflict minerals" comes from section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the Conflict Minerals Rule, 17 CFR Parts 240 and 249b, and is defined as columbite-tantalite, also known as coltan (from which tantalum is derived); cassiterite (tin); gold; wolframite (tungsten); or their derivatives; or any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the DRC or any of the Covered Countries. To make the RCOI determination, we engaged our suppliers to identify the smelters and refiners (“facilities”) of necessary conflict minerals that may have been contained in our products and reviewed available information on the sourcing of conflict minerals by facilities, including information about the facilities provided by RMI regarding processors of conflict minerals.
Our RCOI included:
•Identifying relevant in scope suppliers from our Enterprise Resource Planning software for inclusion in the RCOI Conflict Mineral survey. These suppliers provided materials, parts, components containing necessary conflict minerals.
•Performing risk assessments or collecting data from suppliers using the RMI CMRT which included questions about the location or mine of origin from in scope suppliers.
•Requiring, as part of the survey and our accompanying communications, that, when requested, suppliers provide a statement indicating that conflict minerals are not in use in the supplied parts or complete the CMRT. The CMRT is used to provide the Company with information from the vendors’ supply chains regarding facilities and the origin of necessary conflict minerals processed at these facilities.
•If needed, following up with suppliers to clarify, update or complete information reported to us through the CMRT or their statement. Responses requiring follow-up included issues with completeness, consistency, supplier’s completeness of facility data, traceability, and indicating conflict minerals were not used in their products when assessed high risk as containing conflict minerals.
We have communicated to our suppliers that we expect all materials supplied to the Company to be free of conflict minerals from facilities which directly or indirectly support the illegal armed groups in the DRC region. However, continuing to source from conformant facilities from Covered Countries is acceptable.
RCOI Conflict Minerals Status
We have determined with respect to our products containing necessary conflict minerals that we know or have reason to believe that some of the necessary conflict minerals originated or may have originated in the Covered Countries. All smelters and refiners identified by our suppliers sourcing from Covered Countries are RMI conformant facilities.
Conflict Minerals Due Diligence Measures
Our conflict minerals due diligence process is based on the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition 2016), including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (the “OECD Guidance”), a recognized due diligence framework. We conducted due diligence measures on the source and chain of custody of our conflict minerals to determine whether these conflict minerals originated in the DRC or any of the Covered Countries and financed or benefited non-state armed groups in any of these countries.
Design of our Due Diligence Measures
The design of our due diligence measures is specific to our downstream position in the minerals supply chain and the OECD recommendations for downstream actors that have no direct relationships to facilities. As a member of RMI, we evaluate all facilities reported by suppliers against the RMI Smelter Database and the RMI RCOI Data to determine facility validity and country of origin.
The design of our due diligence process includes the following steps:
1.Establishment of strong internal company management systems, including the following:
•Responsible Minerals Sourcing Policy.
•Cross-functional Team that includes Procurement, Quality, Product Compliance, and Legal, with executive management support.
•Conflict minerals process document as part of our ISO 9001/TL9000 Quality Management System “Due Diligence Process for Reporting of Responsible Minerals Sourcing.”
•Identifying and assessing conflict minerals risks in our supply chain.
•Designing and implementing strategies to respond to conflict minerals risks identified.
•Supplier agreement language that includes supplier responsible minerals sourcing requirements.
•Utilizing a responsible minerals sourcing management system that includes data storage, analysis and reporting.
•Employees and external parties have access to an ethics reporting system, the EthicsAlert Line (866-277-2410), or may report via the website EthicsPoint - Vistance Networks or email the Company’s Corporate Ethics Officer at ethics@vistancenetworks.com.
•Contributing to independent third-party audits of the due diligence practices of conflict minerals facilities by participating in industry organizations.
•Report on our conflict minerals supply chain due diligence activities.
2.Design and implementation of a strategy to respond to identified risks
We follow the OECD Due Diligence Guidance for Responsible Supply Chains Five-Step Framework, step #2 Identify and assess risk in the supply chain. As a downstream supplier, we do not assess the due diligence practices of facilities. We assess supplier responses against internally established criteria for completeness, consistency and risk. We contact suppliers that provided incomplete, inaccurate or untraceable information to correct and/or obtain additional information. Unresponsive suppliers are identified and forwarded to the Procurement Team for further review. Each unresponsive supplier is indicated in a report provided to the Responsible Minerals Corporate Management Team for supplier review to determine if alternative sourcing will be pursued. We encourage in scope suppliers to urge facilities in their supply chain to join the Responsible Minerals Assurance Process (“RMAP”). We evaluate all facilities reported by suppliers against the RMI Smelter Database and the RMI RCOI Data to determine facility validity and country of origin.
3.Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices
We support the industry initiative that conducts audits of facilities’ due diligence activities and we encourage our suppliers to source from facilities that participate in the RMAP. As a downstream supplier, we do not have a direct relationship with conflict minerals facilities and do not perform or direct audits of these entities within our supply chain. As a member of RMI, we utilize information made available by RMI concerning independent third-party audits of facilities and country of origin.
4.Annual reporting through this Conflict Minerals Report.
Future Goals to Mitigate Risk
We are committed to continuously improving our RCOI and due diligence process and intend to take the following steps in 2026:
1.Continue participation in RMI to drive the improvement of industry tools, resources and traceability programs.
2.Continue to educate our suppliers and clearly communicate our expectations of compliance with our responsible minerals requirements.
3.Review and follow-up with suppliers on reported unknown, incorrect and high-risk facilities.
4.As applicable, review unresponsive or high-risk suppliers to determine if alternative sourcing is available.
Due Diligence Results
We had a response rate of 99% to our supplier RCOI and due diligence performed for facilities indicated by suppliers.
Based on the RMI RCOI Data (dated April 23, 2026) 31 smelters or refiners were identified as sourcing from the Covered Countries and all 31 are conformant according to RMI.
Overall, of the 243 unique smelters and refiners identified by our suppliers and verified against RMI known smelters and refiners, 211 are listed as “Conformant” by RMI (including the 31 identified as sourcing from Covered Countries) and 5 are “Active” (RMI Smelter Database, dated April 23, 2026). The remaining facilities have various statuses according to RMI.
Countries of origin and facilities used to process conflict minerals in OUR products
The following list represents the facilities provided by suppliers, verified against RMI known smelters and refiners.
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|
|
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List of Facilities |
Smelter/Refinery Name |
Conflict
Mineral |
Location |
RMI ID |
Advanced Chemical Company |
Gold |
UNITED STATES
OF AMERICA |
CID000015 |
Aida Chemical Industries Co., Ltd. |
Gold |
JAPAN |
CID000019 |
Agosi AG |
Gold |
GERMANY |
CID000035 |
Almalyk Mining and Metallurgical Complex (AMMC) |
Gold |
UZBEKISTAN |
CID000041 |
AngloGold Ashanti Corrego do Sitio Mineracao |
Gold |
BRAZIL |
CID000058 |
Argor-Heraeus S.A. |
Gold |
SWITZERLAND |
CID000077 |
ASAHI METALFINE, Inc. |
Gold |
JAPAN |
CID000082 |
Asaka Riken Co., Ltd. |
Gold |
JAPAN |
CID000090 |
Aurubis AG, Hamburg |
Gold |
GERMANY |
CID000113 |
Bangko Sentral ng Pilipinas (Central Bank
of the Philippines) |
Gold |
PHILIPPINES |
CID000128 |
Boliden Mineral AB (Ronnskar) |
Gold |
SWEDEN |
CID000157 |
C. Hafner GmbH + Co. KG |
Gold |
GERMANY |
CID000176 |
Glencore Canada Corporation - CCR Refinery |
Gold |
CANADA |
CID000185 |
Yunnan Copper Southwest Copper Branch |
Gold |
CHINA |
CID000197 |
Chimet S.p.A. |
Gold |
ITALY |
CID000233 |
Chugai Mining |
Gold |
JAPAN |
CID000264 |
DSC (Do Sung Corporation) |
Gold |
KOREA,
REPUBLIC OF |
CID000359 |
Dowa |
Gold |
JAPAN |
CID000401 |
Eco-System Recycling Co., Ltd. East Plant |
Gold |
JAPAN |
CID000425 |
LT Metal Ltd. |
Gold |
KOREA,
REPUBLIC OF |
CID000689 |
Heimerle + Meule GmbH |
Gold |
GERMANY |
CID000694 |
Heraeus Metals Hong Kong Ltd. |
Gold |
HONG KONG |
CID000707 |
Heraeus Germany GmbH Co. KG |
Gold |
GERMANY |
CID000711 |
Inner Mongolia Qiankun Gold
and Silver Refinery Share Co., Ltd. |
Gold |
CHINA |
CID000801 |
Ishifuku Metal Industry Co., Ltd. |
Gold |
JAPAN |
CID000807 |
Istanbul Gold Refinery |
Gold |
TURKEY |
CID000814 |
Japan Mint |
Gold |
JAPAN |
CID000823 |
Jiangxi Copper Co., Ltd. |
Gold |
CHINA |
CID000855 |
Asahi Refining USA Inc. |
Gold |
UNITED STATES
OF AMERICA |
CID000920 |
Asahi Refining Canada Ltd. |
Gold |
CANADA |
CID000924 |
JX Advanced Metals Corporation |
Gold |
JAPAN |
CID000937 |
Kazzinc Ltd |
Gold |
KAZAKHSTAN |
CID000957 |
Kennecott Utah Copper LLC |
Gold |
UNITED STATES
OF AMERICA |
CID000969 |
Kojima Chemicals Co., Ltd. |
Gold |
JAPAN |
CID000981 |
LS MnM Inc. |
Gold |
KOREA,
REPUBLIC OF |
CID001078 |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
Gold |
CHINA |
CID001093 |
Materion |
Gold |
UNITED STATES
OF AMERICA |
CID001113 |
Matsuda Sangyo Co., Ltd. |
Gold |
JAPAN |
CID001119 |
Metalor Technologies (Suzhou) Ltd. |
Gold |
CHINA |
CID001147 |
Metalor Technologies (Hong Kong) Ltd. |
Gold |
CHINA |
CID001149 |
Metalor Technologies (Singapore) Pte., Ltd. |
Gold |
SINGAPORE |
CID001152 |
Metalor Technologies S.A. |
Gold |
SWITZERLAND |
CID001153 |
Metalor USA Refining Corporation |
Gold |
UNITED STATES
OF AMERICA |
CID001157 |
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List of Facilities |
Smelter/Refinery Name |
Conflict
Mineral |
Location |
RMI ID |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
Tungsten |
CHINA |
CID002551 |
Niagara Refining LLC |
Tungsten |
UNITED STATES
OF AMERICA |
CID002589 |
China Molybdenum Tungsten Co., Ltd. |
Tungsten |
CHINA |
CID002641 |
Lianyou Metals Co., Ltd. |
Tungsten |
TAIWAN, PROVINCE
OF CHINA |
CID003407 |
Hubei Green Tungsten Co., Ltd. |
Tungsten |
CHINA |
CID003417 |
Cronimet Brasil Ltda |
Tungsten |
BRAZIL |
CID003468 |
Fujian Xinlu Tungsten Co., Ltd. |
Tungsten |
CHINA |
CID003609 |
Tungsten Vietnam Joint Stock Company |
Tungsten |
VIET NAM |
CID003993 |
Lianyou Resources Co., Ltd. |
Tungsten |
TAIWAN, PROVINCE
OF CHINA |
CID004397 |
Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
Tungsten |
CHINA |
CID004430 |
Philippine Carreytech Metal Corp. |
Tungsten |
PHILIPPINES |
CID004438 |
KENEE MINING VIETNAM COMPANY LIMITED |
Tungsten |
VIET NAM |
CID004619 |
Jing Yuan Tungsten Technology Co., Ltd. |
Tungsten |
TAIWAN, PROVINCE
OF CHINA |
CID005012 |
Countries of origin for these facilities are believed to include: Andorra, Australia, Austria, Belgium, Plurinational State Of Bolivia, Brazil, Canada, Chile, China, Colombia, Democratic Republic of the Congo, Czechia, Estonia, France, Germany, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, Republic Of Korea, Malaysia, Mexico, Netherlands, Peru, Philippines, Poland, Rwanda, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan Province Of China, Tanzania, United Republic of Thailand, Turkey, Uganda, United States of America, Uzbekistan, Viet Nam.
Efforts to Determine the Conflict Minerals’ Mine or Location of Origin
Through our participation in the RMI and requiring our suppliers to complete the CMRT, and given our downstream position in the minerals supply chain, we have determined that seeking information about conflict mineral smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the conflict minerals in our supply chain.