Dialogic Corporation Conflict Minerals Policy
(Version 6.0 – July 2015)

The following sets forth, as of the date indicated above, the Policy of Dialogic Corporation and its affiliates and subsidiaries (collectively, “Dialogic”) with respect to what have come to be known as Conflict Minerals.  The purpose of this Conflict Minerals Policy (“Policy”) is to manifest Dialogic’s support of, and progress towards compliance with, applicable Conflict Minerals laws and treaties. 

Dialogic, a global networking software and infrastructure solution provider, understands that certain electronic and telecommunications equipment uses minerals such as tin, tantalum, tungsten and gold (collectively, “TTT&G minerals”) in components and sub-assemblies. Although ores for TTT&G minerals occur globally, it has been established (a) that a non-nominal percentage is being obtained from the Democratic Republic of Congo and certain adjoining countries (the “Conflict Region”) via mines controlled by militia groups and (b) that TTT&G minerals from the Conflict Region (i.e., “Conflict Minerals) are being sold into the global metals-smelting chain whereby the proceeds are being used, at least in part, to fund military conflict, human rights violations, and environmental destruction.

In an effort to curb this type of activity, the United States (US) Congress included Conflict Minerals provisions in Section 1502 in the Dodd-Frank Wall Street Reform and Consumer Protection Act, which was signed into US law in 2010.  Final rules relating to Conflict Minerals were adopted by the SEC in August 2012, for implementation to cover US publicly traded companies beginning in May 2014.

Dialogic fully supports – both in principle and with respect to Dialogic as a company - measures to eradicate the use of Conflict Minerals.  Dialogic believes that measures such as these are not only needed to address this very serious problem, but also are in keeping with what Dialogic stands for as a company -- striving to make the world a better place with respect to technology but also humanity, including not just those who are touched directly by Dialogic technology but also those people who are indirectly but just as importantly affected by decisions that Dialogic and other caring companies make when faced with important problems like this.

Dialogic would like nothing more than to be able to “flip a switch” to make this problem immediately go away for everyone.  But it is important to note that like many other companies, Dialogic does not directly purchase (or control the purchase of) minerals from smelters or other mineral processors, and is several layers removed from these processors within the supply chain.  Dialogic also fully recognizes that the metals supply chain is global and complex, and many component suppliers thus far lack the resources and commercial strength to trace minerals, including TTT&G minerals, all the way back to the sources of the ores.  Notwithstanding these issues and realities, Dialogic is committed to complying with applicable Conflict Minerals laws, starting with requiring that Dialogic’s suppliers demonstrate that metals used in components and sub-assemblies are sourced from mines which have already been certified as free from Conflict Minerals or that are on course to be free from Conflict Minerals. 

Although formal Form SD filing obligations with the SEC no longer apply to Dialogic, our company remains committed to becoming Conflict Minerals free as if these obligations remained in place, since, as noted above, doing so is in keeping with what Dialogic stands for as a company and is important for Dialogic customers, including those with their own continued duty to file Form SD with the SEC.  Moreover, processes and frameworks that were put into place while Dialogic Inc. was still a public company have allowed Dialogic to remain well positioned with respect to developments relating to Conflict Minerals both in the US and worldwide.

Dialogic also continues to be pleased with its progress toward becoming Conflict Minerals free.  This process remains a difficult one, given the multitude of products sold by Dialogic, the vast array of components that comprise these products, and the numerous different suppliers of those components.  But through continued efforts of Dialogic personnel, and via the dedication of significant company time and resources, real progress continues to be made toward Dialogic becoming Conflict Minerals free.  Most notably, Dialogic is gaining further visibility into the smelters that are used by Dialogic suppliers, positioning Dialogic not only to be able to provide more thorough information to its customers with Form SD filing obligations with the SEC but also to assess these suppliers and their continued role in connection with Dialogic.

Despite no longer being subject to Form SD filing obligations with the SEC, Dialogic plans to continue to update this Policy to reflect its further efforts and progress toward becoming Conflict Minerals free.

Israel Zohar
VP Operations & Quality