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•	Step 1A - Adopted, and clearly communicated to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas:

•	Implemented a conflict minerals policy;

•	Policy made publicly available at http://www.mallinckrodt.com/about/partner-opportunities/suppliers/conflict-minerals-policy; and

•	Policy communicated directly to suppliers as part of RCOI process.

•	Step 1B - Structured internal management to support supply chain due diligence:

•	Maintained an internal cross functional team to support supply chain due diligence;

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•	Appointed a member of the senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence; and

•	Applied the resources necessary to support the operation and monitoring of these processes, including internal resources and external consulting support.

•	Step 1C - Established a system of transparency, information collection and control over the supply chain:

•	Implemented a process to collect required supplier and smelter RCOI and due diligence data. Full details on the supply chain data gathering are included in the RCOI and due diligence sections of this Report.

•	Step 1D - Strengthened company engagement with suppliers:

•	Directly engaged suppliers during RCOI process;

•	Reviewed supplier responses as part of RCOI process;

•	Added conflict minerals compliance to new supplier contracts and Mallinckrodt’s supplier code of conduct; and

•	Implemented a plan to improve the quantity and quality of supplier and smelter responses year over year.

•	Step 1E - Established a company- and/or mine-level grievance mechanism:

•	Recognized the CFSP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter- or mine-level grievances; and

•	Mallinckrodt’s ethics violations reporting system allows employees to voice confidentially, without any fear of retribution, any concerns with the violations of the Mallinckrodt’s conflict minerals policy.

•	Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance)

•	Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance)

•	Developing a list of suppliers providing 3TG-containing components to Mallinckrodt;

•	Contacting each supplier and requesting the industry standard Conflict Minerals Reporting Template (“CMRT”), including smelter information;

•	Reviewing supplier responses for accuracy and completeness;

•	Amalgamating supplier-provided smelters into a single unique list of smelters meeting the definition of a smelter under one of three industry-recognized audit protocols; and

•	Reviewing the final smelter list (and comparing it to industry peers) to determine if Mallinckrodt identified reasonably all of the smelters in its supply chain.

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•	Identify the scope of the risk assessment of the mineral supply chain (OECD Step 2B);

•	Assess whether the smelters/refiners have carried out all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Step 2C); and

•	Where necessary, carry out, including through participation in industry-driven programs, joint spot checks at the mineral smelter/refiner’s own facilities (OECD Step 2D).

•	For each smelter identified in Mallinckrodt’s supply chain

•	Direct engagement of the smelter to ascertain whether or not the smelter sources from the DRC or surrounding countries.

•	For smelters that declared directly or through their relevant industry association that they did not source from the Covered Countries and were not recognized as conflict free by the CFSP, Mallinckrodt reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration. The sources reviewed included:

•	Public internet search of the facility in combination with each of the covered countries

•	Review of specific NGO publications. NGO publications reviewed included

•	Enough Project

•	Global Witness

•	Southern Africa Resource Watch

•	Radio Okapi

•	The most recent UN Group of Experts report on the DRC

•	For smelters that did not respond to direct engagement, Mallinckrodt reviewed publicly available sources to determine if there was “any reason to believe” that the smelter may have sourced from the Covered Countries during the reporting period.

•	Mallinckrodt reviewed the same sources as those used to compare against smelter sourcing declarations.

•	For high risk smelters (smelters that are sourcing from, or there is reason to believe they may be sourcing from, the Covered Countries), Mallinckrodt requires the smelter be audited and recognized as conflict free by the CFSP.

•	For high risk smelters that have not been audited and recognized as conflict free by the CFSP, Mallinckrodt communicates the risk to designated members of senior management, the Vice President of Procurement and the Vice President of Operations (OECD Step 3A) and conducts risk mitigation on the smelter according to OECD Step 3B.

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•	Additional due diligence to determine if there was any reason to believe the smelter directly or indirectly finance or benefit armed groups in the Covered Countries;

•	Verifying with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Mallinckrodt’s supply chain in the 2015 reporting period; and

•	Direct engagement with each high risk smelter to verify risk and to encourage the smelter to become conflict free.

•	Smelter provided a very detailed due diligence report for 2014.

•	Recognized by the CFSP as “active” (undergoing an independent audit to an industry-recognized protocol).

•	The CFSP does not encourage the removal of a smelter from the supply chain as long as the smelter is recognized as active.

•	No reason to believe, from publicly-available sources and provided due diligence report, that the tin smelter directly or indirectly financed or benefitted armed groups in the DRC or adjoining countries.

•	Does not require removal from supply chain. The smelter’s status will be reviewed in the 2016 reporting period.

•	Smelter provided a very detailed due diligence report for 2014.

•	The refinery was audited and successfully certified to the Dubai Multi Commodities Centre (“DMCC”) responsible sourcing of precious metals.

•	The DMCC responsible sourcing audit is not yet recognized by the CFSP, but is to be reviewed for recognition by the CFSP in 2016.

•	No reason to believe, from publicly-available sources and provided due diligence report, that the gold smelter directly or indirectly financed or benefitted armed groups in the DRC or adjoining countries.

•	Does not require removal from supply chain. The smelter’s status will be reviewed in the 2016 reporting period.

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a.	Including a conflict minerals clause in all new and renewing supplier contracts;

b.	Continuing to drive suppliers to obtain current, accurate, and complete information about the smelters in their supply chain;

c.	Engaging smelters sourcing from the covered countries to become audited and certified to a protocol recognized by the CFSP; and

d.	Follow up in 2016 on smelters requiring risk mitigation, but not removal from Mallinckrodt’s supply chain.

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