Everspin Technologies Inc.

5670 West Chandler Blvd. Suite 100

Chandler, Arizona 852264

Phone: 480-347-1111

Fax: 480-347-1175

April 22, 2019

Everspin

Conflict Minerals Policy

Everspin Technologies is committed to adhering the best ethical and socially responsible practices while

carrying out its business activities.

As part of this responsibility, the firm will fully comply with all pertinent globally sanctioned laws and

regulations. This includes the directly complying to Section 1502 of the Dodd-Frank Wall Street Reform

and Consumer Protection Act (Wall Street Reform Act) enacted in July 2010 in which all US publicly traded

companies to disclose their use of “conflict minerals” if those minerals are “necessary to the functionality

or production of a product” manufactured by those companies.

As currently defined by the SEC, conflict minerals include:

1/ Columbite-Tantalite refined to Tantalum

2/Cassiterite refined to Tin,

3/ Wolframite refined to Tungsten, and

4/ Gold

Everspin Technologies conducts due diligence by working closely with its strategic suppliers to identify 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 to ascertain whether these

conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (collectively,

“Covered Countries”) and financed or benefited armed groups in any of these countries.

Everspin Technologies, expects its direct suppliers:

• To source materials from socially responsible suppliers and manufacturers (and their subsequent next tier

suppliers, etc.), to assure compliance to SEC’s conflict mineral regulations, consistent with Everspin

Technologies conflict minerals policy.

• Have established plans, when and where applicable, for the use of alternative suppliers, as part of ongoing

strategy for elimination in using conflict minerals or derivative minerals sourced from known conflict

mineral mines.

• Provide, upon request, evidential data to Everspin showing active management of conflict minerals that

includes sourcing information using the RMI Conflict Minerals Reporting Template (CMRT) as a standard.

• Provide chain of custody declarations verifying origin of conflict minerals that may be contained in their

products (per SEC regulations).

Per SEC requirements, and on annual basis, Everspin declares that its Purchasing Terms and Conditions

reinforce this subject policy with its suppliers.

____________________

Zuhair Gafur

Director of Quality and Reliability

Everspin Technologies Inc.