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1.	Establish strong company management systems:

•	Conflict Minerals Policy:

◦	Supporting the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (GeSi) Conflict-Free Smelter (“CFS”) program;

◦	Informing the Endo supply base of the Endo Policy on Conflict Minerals, and performing RCOI using the CMRT from suppliers that supply parts that may contain any of the 3TG; and

◦	Conducting due diligence on the source and chain of custody of conflict minerals, if found.

•	Endo’s conflict minerals policy and report are publicly available at: www.endo.com.

•	A cross-functional management team oversees our procedures related to assessing the use of conflict minerals.

2.	Identify and assess risks in our supply chain:

•	Analyzed the bill of materials for each medical device product to assess the presence of conflict minerals.

•	Engaged a third-party service provider to administer the RCOI and assist in the due diligence measures on the source and chain of custody of the necessary conflict minerals in our products that we had reason to believe may have originated from the Covered Countries and may not have come from scrap or recycled sources.

•	Reviewed the CMRT responses from suppliers for accuracy. Where suppliers provided information that was incomplete or inconsistent with AMS’s expectations on the presence of conflict minerals in the parts, the third-party service provider followed up with these suppliers to seek additional clarifying information.

•	Used the recognized due diligence tools created by the CFSI in the evaluation of supplier responses regarding smelters and refiners that may use the necessary conflict minerals in our products.

•	Compared the smelters and refiners identified in the CMRT against the list of those identified as “compliant” by the CFS Program.

•	Documented the country of origin information for the smelters identified in the CMRT responses using CFSI data.

3.	Design and implement a strategy to respond to identified risks

•	Suppliers that were non-responsive or provided incorrect information during the RCOI process are flagged as high-risk.

•	Supply chain management will work to resolve identified issues with the high-risk suppliers.

4.	Support the development and implementation of independent third-party audits of smelters and refiners sourcing:

•	Support industry efforts, such as the CFS Program.

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5.	Report on supply chain due diligence:

•	After conducting the due diligence measures described above, we did not have sufficient information to determine the country of origin of all of the conflict minerals contained in AMS’s BPH products. We have, however, identified CFSI certified smelters that source from the Covered Countries.

•	Appendix A lists smelters and refiners that are compliant with the CFS Program, and Appendix B lists smelters and refiners that have committed to undergo a CFSI audit.

•	Increase engagement with suppliers by informing them of our conflicts mineral policy to help increase the response rate of suppliers’ smelters surveys; and

•	Inform smelters identified as a result of the supply chain survey and encourage their participation in a program, such as the CFS Program, to obtain a “conflict free” designation.

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