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1.

We have established and committed to a company statement regarding our responsibility for addressing Conflict Minerals in our supply chain. A copy of our Conflict Minerals Policy can be provided upon request. In addition, Quantum contractually requires compliance with the Responsible Business Alliance Code of Conduct, Conflict Minerals, and Environmental Requirements Specification in our supplier and purchase order terms and conditions and in our supplier code of conduct.

2.	Our internal Conflict Minerals processes are led by our legal department, with assistance from the Company’s supply chain and engineering teams. Senior management is updated on the status of Quantum’s Conflict Minerals compliance efforts.

3.

As we do not have a direct relationship with the 3TG smelters and refiners, we engage with other major manufacturers in our industry and take advantage of third-party industry resources including the Responsible Business Alliance’s Responsible Minerals Initiative (“RMI”) (of which Quantum is a member) to gather information and influence supply chain practices. In calendar year 2019, we also utilized the services of Assent Compliance to help us gather, analyze, and address Conflict Minerals data and compliance status.

4.	We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Quantum’s policies, including reports to our ethics committee and our third-party hotline. Information about these mechanisms is available in our Code of Conduct, which is posted on the investor relations section of our website.

5.	We have adopted a policy to retain documentation relevant to our conflict minerals due diligence and reporting.

1.

We participate in the industry-wide RMI to evaluate and disclose upstream actors in the supply chain. As part of our risk assessment plan and to ensure suppliers understand our expectations, we provided feedback, either directly or through our relationship with Assent Compliance, to applicable suppliers regarding reporting that we believed was incomplete, inaccurate or may have indicated smelters in their supply chain that do not show progress towards a conflict free supply chain.

2.

For consistency of data content and formatting, Quantum requests our suppliers complete a current version of the RMI conflict minerals reporting template (“CMRT”). We have determined that this process represents the most reasonable effort to determine the mines or locations of origin of the 3TG in our supply chain. Our focus has been on obtaining CMRTs from the suppliers who, in the aggregate, account for at least 80% of our annual direct supplier purchase expenditures. While not all suppliers provided the requested CMRT data, given the volume of smelters and refiners that were identified by other suppliers, it is unlikely that a 100% response rate would have identified a significant number of additional valid smelter or refiner locations.

3.	Risk is assessed by reviewing information contained in the declaration tab of each supplier’s CMRT and by comparing the CMRT data against the RMI smelter and refiner list. In CY19,

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1.	Quantum has an enterprise risk management plan through which the Conflict Minerals program is implemented, managed and monitored. Updates regarding the risk assessment with respect to 3GT/Conflict Minerals and their usage in the supply chain are provided to senior management.

2.

Quantum suppliers and contract manufacturers are contractually obligated to comply with our Environmental Requirements Specification, including by providing CMRTs and supporting a conflict-free supply chain. Assent Compliance was used to identify and evaluate smelter and refiner data included on CMRTs against the RMI database. Corrections were requested from suppliers for any data inconsistencies or inaccuracies identified during that process.

3.

We request data from suppliers whom we have reason to believe (based on part type and material) may be supplying us with 3TG, with the focus being suppliers who represent the top 80% of material purchase spend. Suppliers providing CMRT information that suggests their supply chains may support conflict in the Covered Countries are encouraged to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. Requirements to comply with Conflict Minerals reporting and conflict free sourcing efforts are included in Quantum’s supplier agreements, purchase order terms and conditions, and Environmental Requirements Specification.

4.

Some of our suppliers were unable to represent to us that 3TG from the entities they listed had actually been included in components they supplied to Quantum. In addition, some identified processing facilities were not validated as being verified smelters or refiners. We have therefore elected to present only the smelter and refiner names identified by the RMI in this report (Table 1). Of those smelters that have been identified, 81% have been found to be RMI conformant or active. Quantum will continue to encourage suppliers to utilize only compliant smelters. Table 2 lists the countries where the 3TG originated, based on RMI data.

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