"As contemplated by the OECD Guidance, our due diligence program leveraged independent SOR audits. The audits conformed to the RMAP and other similar programs. Microsoft obtained SOR data from the RMAP Conformant Smelter List using Reasonable Country of Origin Inquiry Data for member MSFT. The list identifies SORs that have undergone assessment through the RMAP or industry equivalent programs, such as Responsible Jewelry Council (“RJC”) or London Bullion Market Association (“LBMA”). We used the list to support certain statements contained in this CMR. Microsoft also participated in RMAPs Smelter Engagement Team during the 2018 reporting year."