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See page 6.

 

Terradata engaged with suppliers directly by conducting a survey that covers Conflict Minerals issues. I am not sure if this qualifies as them doing their own due diligence considering third party auditors are also involved in the broader due diligence process..

 

Specific statement and survey questions:

 

"During 2013, we engaged with Flextronics to identify key suppliers to be surveyed using the EICC-GeSI CFSI processes, forms and templates, and followed-up and monitored through Flextronics regarding the status of those surveys and report responses.

We determined that a segmented survey and risk-based approach was consistent with how Flextronics and many peer companies were approaching the Rule and compliance with it. In view of the characteristics of our hardware supply chain, we believed a reasonable approach would be to have our sole-source contract-manufacturer, Flextronics, conduct a survey of the segment of our key suppliers, including Flextronics itself, who provided hardware components during 2013 for Teradata hardware most likely to contain 3TG subject to conflict minerals reporting under the Rule.

In connection with that risk-prioritized process we determined not to survey during 2013, 63 key suppliers of Teradata hardware components who were identified by us and/or Flextronics as solely providing plastic, non-metallic fasteners, packaging, labels, printing, documents, or a single part identified on the supplier’s website as containing no 3TG.

The survey of the remaining 48 hardware component key suppliers was based on the EICC-GeSI CFSI Conflict Minerals Report template. The survey included questions along the following lines (the actual questions were from the EICC-GeSI CFSI Report Template; they have been shortened here for purposes of this report):

1. Are any 3TG metals necessary to the functionality or production of your company’s products that it manufactures or contracts to manufacture?

2. Does any of the 3TG originate from Covered Countries?

3. Does any of the 3TG come from a recycled or scrap supplier?

4. Have you received completed Conflict Minerals Reporting Templates from all of your suppliers?

5. Have you identified all of the smelters your company and its suppliers use to supply 3GT?

6. Have all of those smelters been validated as compliant with the Conflict-Free Smelters (CFS) program and listed on the Compliant Smelter List?

A. Do you have a policy in place that includes DRC conflict-free sourcing?

B. Is this policy publicly available on your website?

C. Do you require your direct suppliers to be DRC conflict-free?

D. Do you require your direct suppliers to source from smelters validated as compliant to a CFS protocol using the CFS Compliant Smelter List?

E. Have you implemented due diligence measures for conflict-free sourcing?

F. Do you request your suppliers to fill out this Conflict Minerals Reporting Template?

G. Do you request smelter names from your suppliers?

H. Do you verify due diligence information received from your suppliers?

I. Does your verification process include corrective action management?

J. Are you subject to the SEC Conflict Minerals disclosure requirement rule?"