EMCORE is committed to responsible sourcing from its suppliers and each supplier is required to warrant that it has policies and procedures in place to determine whether parts and products supplied to EMCORE are DRC conflict free. Each of our suppliers must further warrant that it has established policies, due diligence frameworks, and management systems consistent with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold, tin, tungsten, and tantalum (the “OECD Guidance”). Upon EMCORE’s request, each of our suppliers shall permit EMCORE to assess its practices and procedures and shall provide EMCORE with any information reasonably requested. In addition, each supplier agrees to provide information to EMCORE necessary for EMCORE to comply with its conflict minerals reporting requirements, including without limitation information under the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Our Conflict Minerals Policy is available on our corporate website at http://emcore.com/our-company/quality-management/supply-chain-management/

III.     Reasonable Country of Origin Inquiry Information

EMCORE has conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary 3TGs included in and necessary to the functionality of our products described under “Product Description” in Section V below originated in the Covered Countries or came from recycled or scrap sources. We engaged a leading 3TGs data management consultant (the “Consultant”) to assist us in conducting this RCOI. We utilized a SaaS platform provided by the Consultant to complete and track supplier communications, as well as allow suppliers to upload completed CMRTs for assessment and management. The use of the CMRT allowed for some elimination of irrelevant suppliers. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process. Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT.

All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regard to invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors.

The Consultant compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs.

To the extent applicable, EMCORE’s RCOI utilized the same processes and procedures as for our due diligence described in Section IV below. This RCOI process included conducting an inquiry of our direct suppliers using a mechanism common in the technology industry: the CMRT version 5.11. Based on the results of our RCOI, we are required to exercise due diligence on the source and chain of custody of the necessary 3TGs contained in our products. Our due diligence efforts are discussed further in Section IV of this CMR.

IV.    Due Diligence Process and Measures Performed

EMCORE’s due diligence measures have been designed to conform in all material respects to the internationally-recognized due diligence framework of the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict- Affected and High-Risk Areas (Third Edition), and its related supplements. This OECD framework (“Framework”) is the only due diligence framework recognized by the Securities and Exchange Commission (“SEC”) to date. The Framework stresses five main areas of Due Diligence design, detailed below in IV(a) - (e).

a.      Establish Strong Company Management Systems

First, EMCORE has assigned a Senior Director of Operations to (i) manage the 3TGs compliance program, (ii) liaise with the Consultant, (iii) conduct reviews of collected data, and (iv) make decisions regarding the due diligence program, including risk mitigation. Second, EMCORE has requested that suppliers of goods incorporated into our products provide us with CMRTs for their products (see below, §§ IV(i)(b & c)). Third, EMCORE’s position statement with respect to 3TGs, which is located on our website (at http://www.emcore.com/wp-content/uploads/EMCORE-Conflict-Minerals-Policy-Statement.pdf), encourages our suppliers to source responsibly, through their sub-suppliers and on down through their own supply chains. In this position statement, we encourage our suppliers and their sub-suppliers to use smelters or refiners (“smelters” or “SORs”) that are conformant to assessment protocols for conflict-free sourcing wherever possible. Using its Responsible Minerals Assurance Process (“RMAP”) audit program, the RMI, an organization founded by members of the Electronic Industry Citizen Coalition (“EICC”) and the Global e-Sustainability Initiative (“GeSI”), is taking action to address responsible sourcing, using independent third-party audits to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials.)

We established multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Emcore’s policies, including with respect to conflict minerals. Suppliers and others outside of Emcore may contact our conflict minerals team to communicate with us, including to report grievances. In addition, our employees may anonymously report suspected violations using our anonymous ethics hotline.

b.      Identify and Assess Risk in the Supply Chain

•Geographic proximity to the DRC and covered countries;

•Known mineral source country of origin;

•Responsible Minerals Assurance Process (RMAP) audit status;

•Credible evidence of unethical or conflict sourcing;

•Peer Assessments conducted by credible third-party sources.

c.      Design and implement a Strategy to Respond to Identified Risks

d.      Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

e.      Report on Supply Chain Due Diligence

Our Form SD and this CMR are both available under “Supply Chain Management” in the Company section of our website at http://www.emcore.com/company/supply-chain-management/. EMCORE will file a Form SD (and CMRs, as necessary) with the SEC on an annual basis, pursuant to Rule 13p-1 of the Securities Exchange Act of 1934, as amended.

V.    Product Description; Processing Facilities

Product Description - Currently, EMCORE’s business is of a broad portfolio of compound semiconductor-based products for the fiber optics markets.

These include forward and return-path analog lasers, receivers, photodetectors and subassembly components, analog and digital fiber-optic transmitters, and quadrature amplitude modulation (QAM) transmitters, optical switches and CATV fiber amplifiers.

These include lasers, receivers photodetectors, including CWDM (Coarse Wavelength Division Multiplexing) and DWDM (Dense Wavelength Division Multiplexing) products, 1310 nm and 1550 nm Distibuted Feedback lasers and optical receivers optimized for CATV, DOCSIS (Data Over Cable Service Interface Specification) 3.1 and wireless applications.

•Radio Frequency over Glass (RFoG) Fiber-To-The-Premises (FTTP) Products

These include an RFoG Optical Networking Unit (ONU) transceivers, analog fiber optic transmitters for video overlay, high-power Erbium-Doped Fiber Amplifiers (“EDFA”), analog and digital lasers, photodetectors and subassembly components.

•Satellite/Microwave Communications (Satcom) Products

These include transmitters, receivers, subsystems, and systems that transport wideband radio frequency and microwave signals between satellite hub equipment and antenna dishes.

•Wireless Communications Products

These include DFB lasers and optical receivers specifically designed for wireless networks, 3 GHz and 6.5 GHz fiber optic links for cellular backhaul, 4G LTE and Distributed Antenna Systems.

•High-Power Gain Chips Products

These include gain chips for tunable lasers and transceivers utilized in coherent DWDM optical transmission systems.

•GPON Fiber-To-The-Premises (FTTP) and Data Center Chip Products

These include 2.5G and 10G PON DFB and 10G Fabry-Perot laser chips, 2.5G and 10G APD top and bottom illuminated chips and 10G PIN photodiode chips.

•Fiber Optic Gyroscope Products

These include products ranging from tactical to navigational grade fiber optic gyroscopes.

•Inertial Measurement Units and Navigation Systems Products

These include inertial measurement units, inertial navigation systems and micro inertial navigation systems.

Processing Facilities - Based on our RCOI or due diligence process, as applicable, and the information received from our suppliers, the facilities listed on Annex A were identified by the Company’s suppliers as the smelters and refiners that processed the 3TG present in and necessary to the functionality of products manufactured by the Company in the calendar year 2018.

Due to our position in the supply chain, which we discuss above, we rely on our suppliers for accurate smelter and refiner information. Our due diligence measures cannot provide adequate certainty regarding the source and chain of custody of the necessary 3TGs contained in our in-scope products. The information from our suppliers is still evolving and may contain company level declarations. As such, this smelter list is presented in good faith as the best information we have to date. This list may contain smelters that are not in our supply chain and there may be other smelters not yet identified in our due diligence process. We will continue to update the list as our information and the relevant third-party data from RMI, LBMA, and RJC improves.

VI.    Future Due Diligence

We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information globally on the traceability and sourcing of the necessary 3TGs in our products will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a supplier whose due diligence needs improvement, we may continue the trade relationship while that supplier improves its compliance program. We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.

In addition to those above, the Company will undertake the following steps during the next compliance period:

Smelter and Refiner Information

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe