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1.	Introduction

2.	Reasonable Country of Origin Inquiry

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3.	Due Diligence

1.	OECD Step #1: Establish and Maintain Strong Company Management Systems. We took several steps to implement internal management and compliance systems relevant to the sourcing of necessary 3TG Minerals, including the following:

1.1.	We have a 3TG Minerals Policy, which is publicly available on our company website under Investor Relations-Corporate Governance. The content of any website referred to in this Conflict Minerals Report is not incorporated by reference in this Conflict Minerals Report.

1.3	A working group comprised of representatives of our purchasing, compliance, and other functions oversaw and implemented our due diligence procedures.

1.4.

We sent our 3TG Suppliers registration instructions for an on-line data collection platform specifically designed for conflict minerals information, along with links to informational tools relating to conflict minerals compliance. If, after these efforts, a supplier did not register on the on-line data collection platform or otherwise provide the requested information, we initiated a follow-up process that used several means of engagement.

1.5.

Supplier responses were evaluated for plausibility, consistency and omissions, and to determine which called for further engagement to address responses considered to have appreciably inconsistent or incomplete information relative to the products or materials the supplier provided to us. This led to telephone calls or additional correspondence requests for additional or improved responses. We also analyzed their further responses.

1.6	If we noted any of the following quality control “flags,” we contacted the responding supplier for additional information:

a.	Smelter or refiner information was not provided for a conflict mineral that is used by us or smelter or refiner information that was provided was not a verified conflict mineral processor;

b.	The supplier confirmed that it sourced conflict minerals from a Covered Country but none of the smelters or refiners listed in the response is known to be sourced from the region;

c.	The supplier indicated that it had not received data for each conflict mineral from its relevant suppliers;

e.	The supplier indicated that it had not provided all applicable smelter or refiner information received; or

f.	The supplier indicated that all of the conflict minerals for products covered by its response originated from scrap or recycled sources but one or more smelters or refiners listed in its response is not known to be exclusively a recycler.

1.7.	For any direct supplier, and certain second tier suppliers who named smelters or refiners and indicated that those smelters or refiners may have processed conflict minerals from the Covered Countries, the CMRT requested additional information regarding such supplier’s conflict minerals policies and due diligence processes.

1.8.	As suppliers provided information, a series of validation checks were performed to ensure at least the minimum information was supplied, followed by the use of scoring and consistency algorithms to identify those requiring follow-up for additional information.

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2.	OECD Step #2: Identify and Assess Risks In The Supply Chain. We took several steps to identify and assess risks in our supply chain relevant to 3TG Minerals, including the following:

2.1.

For the supplier responses that included information about the smelters or refiners in their supply chains, we compared the names to the list of smelters and refiners identified by the RMI as part of its conformant smelters and refiners program and included on the RMI website. As a result of this review, we were able to categorize the smelters and refiners and determine which were certified as having complied with internationally accepted audit standards on their due diligence procedures.

2.2.	With respect to smelters or refiners that were not certified by an independent auditing program, we requested information on the practices of these smelters.

3.	OECD Step #3: Design and Implement a Strategy To Respond To Identified Risks. We took several steps to design and implement a strategy to respond to identified risks, including the following:

3.1.	We used the information about smelters and refiners and their compliance status to identify steps we can take to respond to future risks.

3.2.

By referring 3TG Suppliers to educational resources emphasizing the purposes of our conflict minerals program, we intended to influence the behavior of 3TG Suppliers who source from smelters or refiners that are not certified conflict-free. We also intended for our processes to encourage our 3TG Suppliers, among other things, to have their own policies in place regarding the responsible sourcing of 3TG Minerals, and particularly towards avoiding the use of 3TG Minerals that originate or are sourced from the Covered Countries in a manner that benefits or finances armed groups.

4.

OECD Step #4: Carry Out Independent Third-Party Audits of Smelters/Refiner’s Due Diligence Practices. We do not have direct relationships with smelters or refiners of 3TG Minerals, and the quantities of our necessary 3TG Minerals are relatively small. We are also a relatively small organization. Consequently, we do not carry out audits of smelters or refiners. For our circumstances, we believe that audits conducted by third-parties are the best way to identify smelters and refiners that have due diligence systems in place that promote responsible sourcing.

5.	OECD Step #5: Report Annually on Supply Chain Due Diligence. We report annually by making this Conflict Minerals Report publicly available on our website at http://investors.formfactor.com/sec.cfm, and filing with the SEC.

4.	Results of Review

1.

Countries of Origin of Our Necessary 3TG Minerals. Despite our efforts and engagement with our 3TG Suppliers, we do not have sufficient information to determine definitively the countries of origin of the necessary 3TG Minerals in our products, and are unable to disclose the countries of origin of the necessary 3TG Minerals in our products during the reporting period. Approximately 94% of our direct suppliers of Applicable Products who completed the CMRT identified some or all of the names of the smelters and refiners in their supply chains. Collectively, they identified an aggregate of 918 smelters and refiners with respect to their supply chains. Over 20% of the smelters and refiners named received conformant designations from the RMI.

a.	Monitor industry trends and expert analyses to help identify and implement improvements;

b.	Work to improve the due diligence we conduct to obtain more complete and reliable information about the sourcing of our necessary 3TG Minerals, and whether our sourcing may benefit or finance armed groups in the Covered Countries;

c.	Continue to engage with our 3TG Suppliers and encourage them to obtain further responses from their suppliers and to provide appropriate detailed information to support our compliance with reporting requirements; and

d.	Require our suppliers, to the extent reasonably possible, to regularly complete the CMRT, or make similar confirmations, about their efforts regarding the responsible sourcing of 3TG Minerals.

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