VASCO Data Security International, Inc. (“VASCO”) utilizes contract manufacturers to assemble components into VASCO hardware products. Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo or an adjoining country.