Dialogic Corporation
Conflict Minerals Policy
(Version 7.0 – July 2016)

This document 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 cloud-optimized applications and infrastructure solutions provider for service providers, enterprises, and developers, 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 continues to support – both in principle and specifically with respect to Dialogic as a company - measures to eradicate the use of Conflict Minerals.  Dialogic believes that such measures 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, which is global and complex.  Notwithstanding these issues and realities, Dialogic continues to strive to comply with applicable Conflict Minerals laws, starting with requiring that Dialogic’s suppliers demonstrate that they are on course to be free from Conflict Minerals.

Although formal Form SD filing obligations with the SEC have not applied to Dialogic since 2015, our company remains eager to become Conflict Minerals free, 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 cognizant of developments relating to Conflict Minerals both in the US and worldwide.

Dialogic also continues to be pleased with its steps taken toward becoming Conflict Minerals free.  Of note is the fact that many products and solutions that have been introduced by Dialogic since the Dodd-Frank Wall Street Reform and Consumer Protection Act was implemented in 2014 are software-based, which in and of itself marks important progress toward becoming Conflict Minerals free. 

Nevertheless, the process of becoming Conflict Minerals free remains a difficult one, especially given the multitude of hardware-based products still being 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 company time and resources, Dialogic continues to gain 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, Logistics & Quality