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•	FireEye maintains a Conflict Minerals Policy (the “Conflict Minerals Policy”) that sets forth (i) FireEye’s commitment to complying with Conflict Minerals Regulations and (ii) FireEye’s expectations of its suppliers regarding supporting FireEye’s compliance activities. The Conflict Minerals Policy can be found on our website at https://investors.fireeye.com/corporate-governance/documents.

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As part of its contract manufacturer selection process, FireEye engages in a review of each potential contract manufacturer’s supply chain policies and procedures. FireEye confirms its contract manufacturers have an established system of control and transparency over their mineral supply chain. Further, FireEye has made efforts to communicate to its contract manufacturers and suppliers the need for Rule 13p-1 compliance.

•	The implementation of FireEye’s RCOI and the conducting of due diligence on the source and chain of custody of FireEye’s necessary conflict minerals are managed by FireEye’s legal and operations departments.

•	The legal and operations staff responsible for conflict minerals compliance are knowledgeable regarding conflict minerals compliance and are required to be familiar with FireEye’s Conflict Minerals Policy and with FireEye’s conflict minerals-related processes.

•	Material conflict minerals-related records, including completed CMRTs (as defined below), will be maintained by FireEye for a period of five (5) years from the date of creation.

•	FireEye’s Conflict Minerals Policy has been made available to existing suppliers, and FireEye makes the Conflict Minerals Policy available to new suppliers during the conflict minerals diligence process. Fire Eye has set internal and external expectations that the policy must be followed.

•	Interested parties can report improper activities in violation of the Conflict Minerals Policy via email at environmental-relations@fireeye.com.

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FireEye has requested that its suppliers complete in full the Electronic Industry Citizenship Coalition / Global e-Sustainability Initiative (“EICC/GeSI”) Conflict Minerals Reporting Template (the “CMRT”). The CMRT is designed to request from suppliers sufficient information regarding its suppliers’ practices with respect to the sourcing of conflict minerals to enable it to comply with its requirements under the Conflict Minerals Regulations, including identifying smelters and refiners.

•	FireEye’s legal and operations departments manage the collection of information reported on the CMRT by FireEye’s suppliers and compared the smelters and refiners identified in the supply-chain survey against the list of smelter facilities that have been identified as “conflict free” by programs such as the EICC/GeSI Conflict Free Smelter Program for Conflict Minerals.

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If, on the basis of areas of concern that are identified as a result of either (i) the supplier data acquisition or engagement processes or (ii) the receipt of information from other sources, FireEye determines that a supplier is sourcing conflict minerals that are directly or indirectly financing or benefiting armed groups, FireEye will enforce the Conflict Minerals Policy by means of a series of escalations.

•	Such escalations may range from prompt engagement with the supplier to resolve the sourcing issue, to requiring such supplier to implement a risk management plan (which plan may involve, as appropriate, remedial action up to and including disengagement from upstream suppliers), to disengagement by FireEye from the applicable supplier.

•	Given that we do not have a direct relationship with the smelters and refiners that process the conflict minerals that are present in our products, we rely on the Conflict-Free Sourcing Initiative (the “CFSI”) to conduct third-party audits of smelters and refiners.

•	As required by the Conflict Minerals Regulations, we have filed the Form and this Report as an exhibit thereto for the 2019 reporting year. The Form and this Report are also available on our website at https://investors.fireeye.com/financial-information/sec-filings.

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•	Continue to engage with its suppliers to obtain completed CMRTs; and

•	Encourage the development of supplier capabilities to perform conflict-minerals related due diligence by the implementation of risk mitigation measures, as appropriate.

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