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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 mallinckrodt.com/about/partnering/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;

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

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•	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 CMR.

•	Step 1D - Strengthened company engagement with suppliers:

•	Directly engaged suppliers during RCOI process;

•	Reviewed supplier responses as part of RCOI process; 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 RMAP’s three audit protocols for 3TG as valid sources of smelter or mine level grievances; and

•	Utilized Mallinckrodt’s ethics violations reporting system which allows employees to voice confidentially, without any fear of retribution, any concerns of potential violations of the Company’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 them to complete 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 reasonably identified 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’s own facilities (OECD Step 2D).

•	For each smelter identified in Mallinckrodt’s supply chain:

•	Mallinckrodt attempted direct engagement with the smelter to determine whether or not the smelter sources from the Covered Countries; and

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For smelters that declared directly (e.g., email correspondence, publicly available Conflict Minerals policy, or information available on their website) or through their relevant industry association that they did not source from the Covered Countries, but were not recognized as conflict-free by the RMAP, 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 non-governmental organization (“NGO”) publications. NGO publications reviewed included:

•	Enough Project

•	Global Witness

•	Southern Africa Resource Watch

•	Radio Okapi

•	The most recent United Nations 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 and are not currently conformant to the RMAP), Mallinckrodt communicates the risk to senior management (OECD Step 3A) and conducts risk mitigation on the smelter according to OECD Step 3B.

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

•	Verification with internal stakeholders and relevant suppliers of whether 3TGs from the specific smelter were actually in Mallinckrodt’s supply chain during the Reporting Period; and

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

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a.	Incorporate a Conflict Minerals clause into new and renewing supplier contracts;

b.	Continue to drive Mallinckrodt suppliers to obtain current, accurate, and complete information about the smelters in their respective supply chains;

c.	Request smelters sourcing from the Covered Countries to be audited and certified to a protocol recognized by the RMAP; and

d.	Follow up in 2019 on smelters requiring risk mitigation.

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