Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act aims to prevent the use of certain “Conflict Minerals” that, directly or indirectly, finance or benefit armed groups in The Democratic Republic of the Congo (DRC) or adjoining countries. “Conflict Minerals” include tantalum, tin, tungsten and gold, or their derivatives, and could expand to include other minerals or their derivatives, as determined by the U.S. Secretary of State.

Accuray is committed to avoiding the use of Conflict Minerals which directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. While Accuray does not have complete visibility into the sources of all component minerals, we are actively engaged with our suppliers to promote responsible sourcing practices.

Accuray has implemented a due diligence process, including an evaluation of relevant suppliers concerning the potential use of conflict minerals and the origin of such minerals that are used in Accuray’s products. Due to the complexity of Accuray’s supply chain, this undertaking is ongoing, and will require a significant investment of time and resources.

Accuray works with its direct suppliers to support it in carrying out these steps and fulfilling disclosure and reporting requirements under the rules issued by U.S. Securities and Exchange Commission.

In addition, Accuray expects its suppliers (and their sub-suppliers) to exercise due diligence on the sources of the tantalum, tin, tungsten and gold used in components or products they supply to us.

Accuray evaluates its relationships with its suppliers on an ongoing basis to ensure continued compliance with this policy.

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