Conflict Minerals Policy

Mazor Robotics Ltd. ("Mazor," “we,” “our,” or the "Company") is committed to the highest ethical standards and to conducting its business with the highest level of integrity, as defined in our Code of Business Conduct and Ethics. This Policy provides further clarifications to the principles of the Code of Business Conduct and Ethics' and Mazor's approach regarding illegal trade of natural resources.

Mazor is concerned that the trade of conflict minerals mined in the eastern provinces of the Democratic Republic of the Congo ("DRC") or adjoining countries (together "Covered Countries") may be fueling human rights atrocities in the region. These minerals and their refined metals - tantalum, tin, tungsten and gold ("3TG") - are widely used in the end markets served by Mazor. As a result, we support the action of governments and organizations to increase supply chain transparency and enable companies to source conflict-free minerals.

Mazor does not procure metals directly and only a fraction of the world‘s minerals produce originates from the DRC, nonetheless, Mazor is continuing to take actions to increase transparency in its supply chain, promote responsible procurement by our suppliers and sub-suppliers.

On August 22, 2012, the U.S. Securities and Exchange Commission ("SEC") approved the final rule regarding the sourcing of conflict minerals under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Under this rule, publicly traded companies must report to the SEC the presence of conflict minerals originating in the Covered Countries in the products they manufacture or contract to manufacture if the conflict minerals are necessary to the functionality or production of a product.

We have identified that several of our products contain 3TG minerals. For these products, we are working with our suppliers to identify these minerals’ source and origin.

Mazor is striving to source materials from companies that share our values around human rights, ethics and environmental responsibility. We expect our suppliers to comply with our Conflict Mineral Policy. Furthermore, we support industry efforts such as the Conflict Free Sourcing Initiative ("CFSI") to enable companies to source conflict-free minerals.

As part of the activities, Mazor is implementing the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Mazor is communicating the principles of this policy to its suppliers and is working with them to increase transparency in the supply chain.

We take into use the standardized CFSI Conflict Minerals Reporting Template ("CMRT") to continue mapping and monitoring our suppliers' commitment and activities.

Mazor's actions assessing and responding to identified risks:

  1. Mazor's approach is to establish long-term relationships with suppliers, always seek sustainable solutions, and work with suppliers to drive improvements.
  2. If Mazor identifies a reasonable risk that a supplier is acting in contradiction to the guidelines set forth in this policy, Mazor will require that the supplier will commit to and implement a corrective action plan within a reasonable timeline.

Mazor will address any concerns regarding this policy. We will disclose information, as applicable, about this policy through public reporting, including our website and SEC reporting.

Suppliers and other external parties are invited to contact Mazor at Ran@Mazorrobotics.com,

or their regular contact, should they wish to seek further guidance or report concerns regarding conflict minerals.

 

Approved by:     Conflict Mineral Steering Committee

Updated:           May 2017

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