EX-1.01 2 d194577dex101.htm EX-1.01

EX-1.01

Exhibit 1.01

Teradata Corporation

Conflict Minerals Report

For The Year Ended December 31, 2015

This Conflict Minerals Report (this “Report”) has been prepared by Teradata Corporation (herein referred to, alternatively, as “Teradata,” “we,” “us” and “our”) for the reporting period January 1 to December 31, 2015, and is presented to comply with the final Conflict Minerals implementing rules (the “Conflict Minerals Rules”) promulgated by the Securities and Exchange Commission (“SEC”) and codified in Section 13(p) of the Securities Exchange Act of 1934, as modified by SEC guidance issued on April 29, 2014 and the SEC order issued on May 2, 2014 (the “Conflict Minerals Rules”). “Conflict Minerals” are currently defined by the SEC as cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which the SEC has currently limited to tin, tantalum and tungsten (collectively, the “Subject Minerals,” “Conflict Minerals” or “3TG”).

To comply with the Conflict Minerals Rules, we conducted due diligence on the origin, source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of the products that we manufactured or contracted to manufacture, for which manufacturing was completed during 2015, in order to ascertain whether these Conflict Minerals originated in the Democratic Republic of Congo or an adjoining country and financed or benefited Armed Groups (as defined in Section 1, Item 1.01(d)(2) of Form SD) in any of these countries. Our due diligence undertakings are described in this Report, which includes the activities of all our affiliates that are required to be consolidated.

When this Report uses the term “conflict-free” it means the applicable Conflict Minerals, smelters or refiners have been verified as complying with the Conflict-Free Sourcing Initiative’s (the “CFSI”) Conflict-Free Smelter Program (the “CFSP”) or an equivalent third-party audit program. When this Report uses the terms the “Covered Countries,” “DRC” or “DRC Region” it means the Democratic Republic of the Congo and adjoining countries, including Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

1. Company Overview

Teradata is a global leader in analytic data solutions and related consulting, support and implementation services. Some of our analytic data solutions are deployed on workload-specific “platforms,” comprised of workload-specific computer hardware and software, that we sell, license or otherwise distribute to, or for the use of, our customers (e.g., on-premises platforms), while others are deployed on cloud, as-a-service or software-only delivery models. Our workload-specific platforms for on-premises use include the Teradata hardware products that are within the scope of this Report. Our workload-specific platforms are used in multiple industries, including communications, ecommerce, financial services, gaming, government, healthcare, insurance, manufacturing, media and entertainment, oil and gas, retail, travel and transportation, and utilities. During 2015, we conducted business in approximately 44 countries, had 1,300 analytic data solutions customers and employed approximately 11,300 people worldwide.

2. Products Overview

The equipment (excluding software) comprising our products typically includes electronic computer processors, boards, servers, data storage, power supplies, cabinetry and related tangible components. Collectively, the tangible components of those products are referred to in this Report as Teradata “hardware” or Teradata “hardware products.” Other products, including third-party equipment, that Teradata does not manufacture or contract to manufacture are outside the scope of this Report.

We engineer, design and establish specifications for our hardware products, leveraging best-in-class components from industry leaders and using industry-standard technologies selected and configured to work optimally with other hardware components and software. Each of our hardware products shares some common hardware components and/or suppliers with our other hardware products.

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During 2015, Teradata did not manufacture any of our hardware products. All Teradata hardware manufactured during 2015 (as well as during 2013 and 2014) for distribution to others was manufactured for us under contract by our sole-source electronics manufacturing services provider, Flextronics International Ltd. (a/k/a Flex) (“Flextronics” or our “Contract-Manufacturer”).

We have determined that certain of these products for which manufacturing was completed during 2015 contain Conflict Minerals. Those products are:

• Teradata Workload-Specific Platforms, including the Teradata Active Enterprise Data Warehouse, Teradata Data Warehouse Appliance, Teradata Data Mart Appliance, Teradata Appliance for SAS^® and Teradata Integrated Big Data Platform;

• Teradata Aster Discovery Platforms, including the Teradata Aster Big Analytics Appliance;

• Teradata Appliance for Hadoop; and

• Teradata Platform Framework Cabinet.

3. Supply Chain Overview

During 2015, 94 suppliers, including our Contract-Manufacturer and its affiliates, directly provided hardware components and materials for Teradata hardware products (“key suppliers”). Our Contract-Manufacturer assembled those hardware components, performed and completed the manufacturing of our hardware products, and initiated distribution of those products from the United States. The hardware components and materials included in our hardware products include components and materials from multiple upstream suppliers, supplier-tiers and sources across the world. Teradata is multiple supplier-tiers downstream from the smelters and refiners that provide materials used in the supply-chain for Teradata hardware components. Teradata has had no direct relationships with those smelters or refiners, and has had no direct presence, direct business activities or employees located in the Covered Countries.

4. Conflict Minerals Analysis

Based upon a review of our product categories, we have concluded that:

• Teradata is subject to the Conflict Minerals Rule;

• the Subject Minerals are commonly known to be used widely in the electronics industry and found in many electronic computing hardware components;

• the Subject Minerals are in various Teradata hardware product components;

• the Subject Minerals included in our hardware products did not originate exclusively from recycled or scrap resources; and

• all of the Subject Minerals included in our hardware products did not originate exclusively from supplies that entered the supply-chain before the period covered by the Rule (e.g., before January 2013).

We determined that our sole-source Contract-Manufacturer has:

• declared it has a Conflict Minerals Policy, program and training module available for its suppliers and publishes documents regarding such (see the Flextronics “Conflict Minerals Policy” by selecting the link under that title at https://www.flextronics.com/supplier-information/supplier-quality and see the Flextronics “Conflict Minerals Supplier Training” by selecting the link under that title at https://www.flextronics.com/supplier-information/supplier-quality).

• declared that it is a member of the CFSI and that it uses the CFSI, CFSP and CFSI Conflict Minerals Reporting Template (“CMRT”) in connection with its Conflict Minerals program (see links above as well as http://www.conflictfreesourcing.org/about/members-and-collaborations/ listing members of the CFSI (which includes Flextronics and Teradata) and http://www.conflictfreesourcing.org/ which provides information about the CFSI, CFSP and CMRT); and

• identified itself as being a reporting company under the Rule and posted such a report in 2015 for products it manufactured during 2014 (see http://d1lge852tjjqow.cloudfront.net/CIK-0000866374/9975f203-1235-49a2-adb8-a79f0ac761fe.pdf?noexit=true) and in 2014 for products it manufactured during 2013 (see http://files.shareholder.com/downloads/ABEA-28U2SZ/0x0xS1104659-14-42967/866374/filing.pdf).

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5. Teradata’s Due Diligence Framework

Teradata has designed its Conflict Minerals Policy and associated due diligence processes to support and align with the CFSI and CFSP frameworks and thereby with the five-step framework set forth in the Third Edition of the Organisation for Economic Co-operation and Development’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” and the supplements thereto. The activities, websites, links and documents summarized and cited throughout this report address these undertakings.

A. Establishment of Robust Company Ethics and Compliance Management Systems

• Teradata has adopted and maintains a policy on Conflict Minerals (the “Policy”), which can be viewed on our website at: www.teradata.com/corporate-social-responsibility. The Policy has been communicated to relevant personnel and is available to all Teradata employees via Teradata’s website. Among other things, the Policy:

• authorizes and assigns responsibilities for a Teradata Conflict Minerals Management Committee;

• encourages respect and protection of human rights and the environment with our supply-chain;

• fosters supply-chain integrity, ethics, compliance and accountability, including with respect to Conflict Minerals, Conflict Minerals legal duties and Conflict Minerals industry/framework initiatives;

• prohibits knowing inclusion of Targeted DRC Conflict Minerals in our hardware products;

• establishes an escalation and corrective actions process in the event of actual or suspected Conflict Minerals compliance risks, exceptions or violations;

• establishes an expectation or requirement with our supply-chain that the 3TG content in our hardware products must become conflict-free as and when required by law and SEC guidance;

• adopted procedures and expectations that our Conflict Minerals initiatives and status are reviewed with Teradata senior management and the Audit Committee of our Board of Directors; and

• adopted procedures and expectations that our Conflict Minerals Policy is reviewed and updated at least annually and on an as-required basis to assure that any new legal developments are accounted for on a timely basis.

• Teradata has prepared this Conflict Minerals Report for 2015 (replacing previously posted versions for 2013 and 2014) and posted it on our website at www.teradata.com/corporate-social-responsibility).

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• Teradata has declared its support for and adopted the principles of the Electronic Industry Citizenship Coalition (“EICC”) Code of Conduct. The EICC Code of Conduct includes provisions regarding responsible sourcing of minerals, including with respect to 3TG and DRC Region Conflict Minerals at section D.7. of the EICC Code of Conduct (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including in the linked “Teradata Code of Conduct” and “Teradata Corporate Social Responsibility Report”; and, see the EICC Code of Conduct at http://www.eiccoalition.org/media/docs/EICCCodeofConduct5_English.pdf).

• Teradata has declared our support for and adopted the principles of the United Nations (“UN”) Global Compact (Principle Two of the UN Global Compact includes that businesses should make sure they are not complicit in human rights abuses), been a signatory to the UN Global Compact, been a financial supporter of the UN Global Compact, submitted UN Global Compact Communications on Progress (the “Teradata Corporate Social Responsibility Report”) and posted related information on our website (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including in the linked “Teradata Code of Conduct” and “Teradata Corporate Social Responsibility Report”; and, see information regarding the UN Global Compact, its principles, its members (including Teradata), its financial supporters (including Teradata) and its members who have submitted Communications on Progress at https://www.unglobalcompact.org/ and https://www.unglobalcompact.org/what-is-gc/participants/15948-Teradata-Corporation).

• Teradata has adopted a company Code of Conduct and posted it for public access on our website, which includes provisions related to respecting and protecting human rights, our adoption of the principles of the EICC Code of Conduct and UN Global Compact and compliance regarding, among other areas, Conflict Minerals (see www.teradata.com/code-of-conduct, including in the linked “Teradata Code of Conduct”) .

• We have adopted a Teradata Supplier Code of Conduct and Teradata Business Partner Code of Conduct (each includes Conflict Minerals compliance provisions and the principles of the EICC Code of Conduct and UN Global Compact) and posted them for public access on our website (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including the documents linked for the “Teradata Code of Conduct for Suppliers” and the “Teradata Code of Conduct for Business Partners”).

• Teradata has maintained and communicated information about the Teradata Ethics Helpline (e.g., a whistleblower hotline) though which anyone may report Teradata-related actual or suspected violations of policies or laws or raise Teradata-related issues for review and guidance, and may do so on an anonymous and confidential basis (anyone may report and seek guidance regarding Teradata-related matters that pertain to Conflict Minerals through our Ethics Helpline (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including the documents linked for the “Teradata Code of Conduct,” the “Teradata Code of Conduct for Suppliers” and the “Teradata Code of Conduct for Business Partners,” as well as the online site for the Teradata Ethics Helpline at https://tdhelp.alertline.com/gcs/welcome).

• Teradata has maintained an Ethics and Compliance program and process for investigating, taking corrective actions and reporting matters related to ethics, compliance, actual or suspected violations of policies and actual or suspected violations of law (these include matters involving policies or laws that pertain to Conflict Minerals, of which there have been none) (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including the documents linked for the “Teradata Code of Conduct,” the “Teradata Code of Conduct for Suppliers,” the “Teradata Code of Conduct for Business Partners” and the “Teradata Corporate Social Responsibility Report”; the linkage between our Conflict Minerals compliance processes and our broader Ethics and Compliance processes is described in our Conflict Minerals Policy).

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• We have issued an annual Teradata Corporate Social Responsibility (“CSR”) Report (which includes reference to our Conflict Minerals policy and program, supply-chain integrity initiatives and initiatives to support and help protect human rights) and posted it for public access on our website (see www.teradata.com/corporate-social-responsibility).

• Teradata has included Conflict Minerals, human rights and third-party due-diligence awareness and compliance in our ethics, compliance and code-of-conduct training for employees and members of our Board of Directors (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including the documents linked for the “Teradata Code of Conduct” and the “Teradata Corporate Social Responsibility Report”).

• Teradata has included requirements that Flextronics and our suppliers comply with our Conflict Minerals Policy in certain relevant specifications and vendor regulatory compliance criteria for our hardware products.

• Teradata has included compliance with Conflict Minerals requirements provisions in certain relevant contracts with our Contract-Manufacturer and/or key suppliers.

B. Supply Chain Risk Identification and Assessment

• Teradata has communicated with our Contract-Manufacturer regarding Conflict Minerals surveying, tracking, reporting, expectations and upstream key supplier communications with respect to direct suppliers of components for our hardware who have not been identified as solely supplying components that do not contain any 3TG (e.g., plastic, aluminum, packaging, labels, documentation and other non-3TG-containing components).

• Teradata has reviewed our Contract-Manufacturer’s Forms SD and Conflict Minerals Reports for 2014 and 2013 (see http://d1lge852tjjqow.cloudfront.net/CIK-0000866374/9975f203-1235-49a2-adb8-a79f0ac761fe.pdf?noexit=true and http://files.shareholder.com/downloads/ABEA-28U2SZ/0x0xS1104659-14-42967/866374/filing.pdf).

• Teradata has reviewed some (e.g., spot-checked) relevant websites, statements, Conflict Minerals Policies and/or Conflict Minerals Reports of some key suppliers regarding their stated Conflict Minerals initiatives, processes, reasonable country of origin inquiry (“RCOI”) processes and due diligence processes.

• Teradata has received and reviewed a CFSI Conflict Minerals Reporting Template form for 2015 (as well as 2013 and 2014) completed by our Contract-Manufacturer with respect to our hardware products; designed our Conflict Minerals program and actions and determinations related to our Conflict Minerals program described in this Report to materially meet RCOI requirements of the Rule and Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas; Second Edition, including related supplements regarding 3TG.

• Teradata has become a participating, membership-fee-supporting member of the CFSI (see http://www.conflictfreesourcing.org/about/members-and-collaborations/).

• Teradata has, through our participation in and support of the CFSI, helped make Conflict Minerals training, guidance and resources available to our employees, suppliers and others (see http://www.conflictfreesourcing.org/media/flash/conflict-minerals-overview/; http://www.conflictfreesourcing.org/resources-and-training/training/ and http://www.conflictfreesourcing.org/resources-and-training/guidance-documents/).

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C. Reasonable Country of Origin Inquiry (“RCOI”)

Our Contract-Manufacturer reported to us the following with respect to our hardware products manufactured during 2015:

• 66 key suppliers of components for our hardware for 2015 were surveyed regarding Conflict Minerals using the CFSI framework; 28 of our total 94 key suppliers were not surveyed because it was determined that they solely provide components or materials that do not to contain any 3TG at all or are outside the scope of the Rule, such as components or materials that are solely plastic, non-metallic fasteners, aluminum, packaging, test media, documentation, ink or a label; and

• as of February 17, 2016, 40 of the responses of those key suppliers for 2015 were deemed complete (an increase of 10 (30%) over the 30 for this category reported in our 2014 Conflict Minerals Report), 23 were open (e.g., awaiting responses or supplemental responses)(a decrease of 5 (18%) from the 28 reported for this category in our 2014 Conflict Minerals Report) , 2 were rejected or repeated (e.g., identity of smelter or refiner not provided or deemed to be invalid)(a decrease of 3 (60%) from the 5 reported for this category in our 2014 Conflict Minerals Report) and 1 had some other identified problem (e.g., response in a form other than through the CMRT) (a decrease of 2 (67%) from the 3 reported for this category in our 2014 Conflict Minerals Report).

The CFSI CMRT completed by our sole-source Contract-Manufacturer and provided to us for 2015 regarding our hardware products includes the following as of February 17, 2016:

• each of the Subject Minerals is intentionally included in Teradata’s hardware products;

• each of the Subject Minerals is necessary to the production of Teradata’s hardware products and contained in our hardware products;

• some of the tantalum, tin and tungsten in Teradata’s hardware products originates from the Covered Countries;

• it is yet unknown if any of the gold in Teradata’s hardware products originates from the Covered Countries;

• 100% of the Subject Minerals in Teradata’s hardware products do not originate from recycled or scrap sources;

• Conflict Minerals data/information has not yet been received from 100% of suppliers of 3TG used in Teradata’s hardware;

• all smelters of the Subject Minerals in Teradata’s hardware products have not yet been identified for all of the Subject Minerals;

• all applicable smelter information received by Teradata’s Contract-Manufacturer has been reported in its CMRT declaration that was provided to us;

• Teradata’s Contract-Manufacturer has a policy in place that addresses Conflict Minerals sourcing, and that policy is publicly available on Flextronics’ website at http://www.flextronics.com/supplier/supplierquality/Files/Conflict%20Minerals%20Policy.pdf;

• Among other things, Flextronics’ Conflict Minerals sourcing policy:

• requires its direct suppliers to be DRC conflict-free;

• it requires its direct suppliers to source 3TG from smelters whose due diligence practices have been validated by an independent private sector audit program;

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• it has implemented due diligence measures for conflict-free sourcing;

• it collects Conflict Minerals due diligence information from its suppliers which is in conformance with IPC-1755 Conflict Minerals Data Exchange standard (e.g., the CFSI CMRT);

• it requests smelter names from its suppliers;

• it reviews due diligence information it receives from its suppliers against its expectations;

• its review process includes corrective action management; and

• it is subject to the SEC Conflict Minerals Rule.

In connection with that CMRT, our Contract-Manufacturer provided us with information regarding 304 smelters/refiners/sourcers of the Subject Minerals included during 2015 in our hardware products as identified in direct supplier surveys. Annex I of this Report includes a list of source countries for each of the Subject Minerals identified through that process. The information provided by our Contract-Manufacturer correspondingly identifies the following for each of the Subject Minerals as of February 17, 2016:

• Gold – 127 smelters/refiners/sources including recycled, scrap and mine sources in 14 countries;

• Tantalum – 48 smelters/refiners/sources including recycled, scrap and mine sources in 16 countries;

• Tin – 86 smelters/refiners/sources including recycled, scrap and mine sources in 8 countries; and

• Tungsten – 43 smelters/refiners/sources including recycled, scrap and mine sources in 1 country.

Of the 127 identified gold smelters/refiners/sources, 81 (64%) were listed as CFSP compliant, 12 (9%) were listed as CFSP active and 34 (27%) were not CFSP listed — for a total CFSP compliant/active rate for identified sources of gold in our supply-chain of 73%.

Of the 48 identified tantalum smelters/refiners/sources, 47 (98%) were listed as CFSP compliant, 1 (2%) was listed as CFSP active and 0 (0%) were not CFSP listed — for a total CFSP compliant/active rate for identified sources of tantalum in our supply-chain of 100%.

Of the 86 identified tin smelters/refiners/sources, 59 (69%) were listed as CFSP compliant, 12 (14%) were listed as CFSP active and 15 (17%) were not CFSP listed — for a total CFSP compliant/active rate for identified sources of tin in our supply-chain of 83%.

Of the 43 identified tungsten smelters/refiners/sources, 29 (67%) were listed as CFSP compliant, 12 (28%) were listed as CFSP active and 2 (5%) were not CFSP listed — for a total CFSP compliant/active rate for identified sources of tungsten in our supply-chain of 95%.

Thus, of the 304 total identified smelters/refiners/sources of the Subject Minerals, 216 (71%) were listed as CFSP compliant, 37 (12%) were listed as CFSP active and 51 (17%) were not CFSP listed — for a total CFSP compliant/active rate for identified sources of the Subject Minerals in our supply-chain of 83%.

Teradata subsequently re-checked CFSI/CFSP data to validate the CFSI/CFSP listing status data for each of the 304 identified smelters/refiners/sources. That process validated the status data as of the effective date for the data provided to us by our Contract-Manufacturer (February 17, 2016), but identified that 10 of those smelters/refiners/sources subsequently had their CFSI/CFSP status changed from active to not-listed. We assessed such status-changes to be a routine part of the CFSI/CFSP process, such as when participating smelters/refiners/sources do not meet the defined criteria for continuing to be listed as “active,” but as identifying potential red flags or areas of risk regarding those smelters/refiners/sources warranting monitoring and follow-up corrective actions regarding those smelters/refiners/sources.

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We assessed the status of responses to the surveys of our key suppliers and the CFSI/CFSP data regarding identified smelters/refiners/sources of the Subject Minerals in our hardware supply-chain for red flags and risks. We determined that the key suppliers whose survey responses were incomplete and the smelters/refiners/sources who are listed as CFSI active or not-CFSI-listed during 2016 should be monitored for progress towards and achievement of complete responses and CFSI/CFSP compliant listing status during 2016, and if they do not, we should implement follow-up corrective actions (such as seeing that such key suppliers and smelters/refiners/sources are removed from our supply-chain for hardware components that include the Subject Minerals).

The actions and determinations relevant to RCOI set forth above in this Report, the information in Annex I, the information provided to us by our Contract-Manufacturer from which we derived the information in Annex I, our review of that information, and the immediately preceding paragraph reflect and summarize our RCOI process and results for our hardware products manufactured during 2015.

D. Teradata’s Responses to Identified Risks

In connection with the CMRT for 2015 from our Contract-Manufacturer and as of February 17, 2016, our Contract-Manufacturer identified to us 7 smelters/refiners/sources for the Subject Minerals included in our hardware products that reportedly source, or reportedly might source, 3TG from mines or sources in the Covered Countries (a decrease of 5 (42%) from the 12 reported for this category in our 2014 Conflict Minerals Report). Those smelters/refiners/sources are listed in Annex II of this Report. Included are 5 smelters/refiners of tantalum and 2 smelters/refiners of tin. Six (6) of those 7 smelters (86%) have been identified as being DRC conflict-free for their respective Subject Minerals. The other 1 (14%) has been identified as “active” and in the process of pursuing conflict-free designation for the Subject Minerals it provides for use in our hardware supply chain (during 2015, only tin) in accordance with the CFSI/CFSP protocols. Thus, the total CFSP compliant/active rate for identified sources of the Subject Minerals in our supply-chain originating from the Covered Countries is 100%.

We subsequently re-checked CFSI/CFSP data to validate the CFSI/CFSP listing status data for each of these 7 identified DRC-sourcing smelters/refiners/sources. That process validated the status data as of the effective date for the data provided to us by our Contract-Manufacturer (February 17, 2016) and confirmed that such status remained the same as of May 4, 2016. We assessed the CFSI/CFSP data for red flags and risks, and determined that the one smelter/refiner/source for tin located in Rwanda who was listed as active should be monitored for progress towards and achievement of CFSI/CFSP compliant listing status during 2016, and if it does not, we should implement follow-up corrective actions (such as seeing that such smelter/refiner/source is removed from our supply-chain for hardware components that include the Subject Minerals).

The actions and determinations relevant to Conflict Minerals due diligence set forth above, the information in Annex II, the information provided to us by our Contract-Manufacturer from which we derived the information in Annex II, our review of that information, and the immediately preceding paragraph summarize our Conflict Minerals due diligence process and results for our hardware products manufactured during 2015.

E. Continued Risk Mitigation

Teradata’s Conflict Minerals program continued to evolve in 2015. We have built upon preexisting program attributes and activities set forth above in this Report. Our further progress during 2015 included the following:

• Teradata reduced the number of our key suppliers from 101 for 2014 to 94 for 2015.

• We maintained the number of key suppliers which were surveyed, 66 for 2014 and for 2015, resulting in an increase of the percentage of total key suppliers surveyed during the year from 65% for 2014 to 70% for 2015.

• We increased the response rate for key supplier surveys from 45% for 2014 to 61% for 2015.

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• Teradata increased the total number of identified smelters/refiners/sources for the Subject Minerals from 238 for 2014 to 304 for 2015.

• All smelters/refiners identified as possible sources of tantalum from the DRC Region were on the CFSP-compliant list for 2015 and 2014 – 3 were not for 2013.

• Teradata continued to include compliance with our Conflict Minerals Policy, the principles of the EICC Code of Conduct and the principles of the UN Global Compact in our Code of Conduct, Supplier Code of Conduct and Business Partner Code of Conduct during 2015, and included information about each of those items in our annual all-employee ethics and compliance training for 2015.

• We reviewed and updated our Conflict Minerals Policy during 2015.

• We reported relevant information regarding Conflict Mineral requirements, compliance and status to our senior management and the Audit Committee of our Board of Directors.

• Teradata further monitored legal developments and guidance related to Conflict Mineral compliance during 2015, and considered and applied relevant developments to our Conflict Minerals program.

• We further assessed, with assistance from subject-matter-experts from an outside consulting firm, independent private sector audit (IPSA) readiness requirements and criteria for application to our Conflict Minerals program, should such undertakings become legally required in the future.

• Teradata maintained and supplemented information and materials on our internal employee Conflict Minerals online resource and collaboration site.

• Teradata added due diligence inquiries regarding Conflict Minerals to our compliance due diligence questionnaire template for merger-and-acquisition candidates.

• Teradata became a member of the CFSI and financially supported the CFSI through paying our CFSI membership-fees.

• By becoming a member of the CFSI during 2015, Teradata gained deeper direct access to CFSI participant data, enabling us to take measures to verify related data reported to us by our Contract Manufacturer and to review relevant data to look for red flags and indicia of risks, rather than relying solely on our Contract-Manufacturer to do so and report such to us.

FORWARD LOOKING STATEMENTS

Statements contained in this Report relating to due diligence and risk mitigation improvements are forward-looking in nature. These statements are not a guarantee or performance and are subject to a number of uncertainties and other factors that may be outside of Teradata’s control and that could cause actual events to differ materially from those expressed or implied by the statements made herein.

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ANNEX I

To Teradata Corporation

Conflict Minerals Report

For The Year Ended December 31, 2015

IDENTIFIED COUNTRIES/PLACES OF ORIGIN FOR CONFLICT MINERALS

Recycled, Scrap and Mines

Gold (14)				Tin (8)
Australia				Bolivia
Belgium				Brazil
Canada				China
Chile				Democratic Republic of Congo
China				Indonesia
Germany				Malaysia
Hong Kong				Peru
Japan				USA
Korea
Mexico
South Africa
Switzerland
Taiwan
USA
Tantalum (16)				Tungsten (1)
Australia				China
Bolivia
Brazil
Canada
China
Democratic Republic of Congo
Ethiopia
India
Japan
Mozambique
Namibia
Russian
Rwanda
Sierra Leone
USA
Zimbabwe

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ANNEX II

To Teradata Corporation

Conflict Minerals Report

For The Year Ended December 31, 2015

IDENTIFIED POSSIBLE SMELTERS/REFINERS/SOURCES OF CONFLICT MINERALS FROM THE DRC REGION

Smelter/Refiner Name		Country		Smelter ID Number		Listed as CFSP Compliant or Active (at conflictfreesourcing.org)?
Tantalum (5)
Duoluoshan		China		CID000410		Compliant
F&X Electro-Materials Ltd.		China		CID000460		Compliant
H.C. Starck GMBH Goslar		Germany		CID002545		Compliant
H.C. Starck Inc.		USA		CID002548		Compliant
Ulba Metallurgical Plant JSC		Kazakhstan		CID001969		Compliant
Tin (2)
Malaysia Smelting Corporation		Malaysia		CID001105		Compliant
Phoenix Metal Ltd.		Rwanda		CID002507		Active
Tungsten (0)
Gold (0)

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