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1.	OECD Guidance Step One: “Establish strong company management systems”

a.

We have a cross-functional team that is responsible for our 3TG compliance program. Leadership of the compliance program resides with senior members of our legal and sustainability teams. In addition, we utilize specialist outside counsel to advise us in connection with our Conflict Minerals Rule compliance and a service provider (the “Service Provider”) to, on our behalf, engage in supplier outreach and follow-up, validation of supplier responses and electronic storage of supplier responses. Some of the compliance activities described in this Conflict Minerals Report were performed by the Service Provider on our behalf.

b.	We communicate our Conflict Minerals Policy internally and externally to suppliers, in each case in writing. The Conflict Minerals Policy is available on our website at https://www.sonos.com/en-us/sustainability.

c.	We use the Conflict Minerals Reporting Template (the “CMRT”) developed by the RMI to identify SORs in our supply chain.

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d.	We maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, on a computerized database. Under our business records policy, this information is to be retained for at least five years.

e.	We have a mechanism for employees and other interested parties to anonymously report violations of our Conflict Minerals Policy or other policy violations and issues, online or by telephone, and encourage our suppliers to have such mechanism as well.

2.	OECD Guidance Step Two: “Identify and assess risk in the supply chain”

a.	For 2019, the Service Provider sent requests to 155 Suppliers to provide us with a completed CMRT. We or the Service Provider followed up by email or phone with the Suppliers that did not provide a response within the time frame specified in the request. Approximately 92% of our Suppliers responded to the Service Provider’s request for information.

b.	We and the Service Provider reviewed the responses received from the Suppliers. The Service Provider reviewed the responses received for plausibility, consistency and gaps. It followed up by email or phone with Suppliers that submitted a response that triggered any one of seven specified quality control flags.

c.	To the extent that a completed CMRT identifies a SOR, the Service Provider reviewed the information provided against the list of Conformant SORs published in connection with the RMI’s Responsible Minerals Assurance Process (the “RMAP”), the London Bullion Market Association (“LBMA”) Good Delivery List and the Responsible Jewellery Council’s (“RJC”) Chain-of-Custody Certification.

d.

To the extent that a SOR identified by a Supplier was not listed as Conformant, the Service Provider attempted to contact that SOR to gain information about its sourcing practices, including origin and transfer, and to determine the source and chain of custody of the 3TG. Internet research was also performed to determine whether there are any outside sources of information regarding the SORs sourcing practices.

e.

If a Supplier was unable to provide information concerning the processors of 3TG in its supply chain, the Service Provider requested information on the Supplier’s suppliers of products or components which may have required 3TG for their functionality or production (“Tier 2 suppliers”). The Tier 2 suppliers, and subsequent tiers of suppliers as identified to the Service Provider, were then contacted by the Service Provider.

3.	OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks”

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a.	Our 3TG compliance team reported the findings of its supply chain risk assessment to our Chief Legal Officer.

b.	Our risk mitigation strategy allows for a flexible response that is commensurate with the risks identified.

4.	OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain”

5.	OECD Guidance Step Five: “Report on supply chain due diligence”

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1.	The SORs listed in the table were identified by the Suppliers as being part of our 2019 supply chain. However, the SORs listed above were not necessarily the only SORs in our

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2.	All information in the table is as of April 20, 2020.

3.	“Conformant” means that a SOR has successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment. Included SORs were not necessarily conformant for all or part of 2019 and may not continue to be conformant for any future period.

4.	A SOR is listed as “On Smelter Look-up Tab Only” if it was not Conformant or listed as “Active” but appears on the Smelter Look-up tab list of the CMRT.

5.	The conformant status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by us.

6.	Country location is the location of the SOR and is based solely on information made publicly available by the RMI without independent verification by us.

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