Specialized Disclosure Report (Form SD)

CONFLICT MINERALS REPORT OF ACCURAY INCORPORATED

FOR THE REPORTING PERIOD FROM JANUARY 1, 2025 TO DECEMBER 31, 2025

Background

This Conflict Minerals Report ("Report") of Accuray Incorporated ("Accuray") for calendar year 2025 (the "Reporting Period") has been prepared in accordance with Rule 13p-1 and Form SD under the Securities Exchange Act of 1934, as amended (together, the "Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to Conflict Minerals (as defined below) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which are collectively referred to in this Report as the "Conflict Minerals," are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The "Covered Countries" for the purposes of the Rule and this Report are the Democratic Republic of the Congo ("DRC") and adjoining countries, which currently include the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

If Conflict Minerals are necessary to the functionality or production of products manufactured or contracted to be manufactured by a company, the company is required to conduct a good faith reasonable country of origin inquiry ("RCOI") to determine whether any of the necessary Conflict Minerals in those products originated in the Covered Countries and whether any of the necessary Conflict Minerals may be from recycled or scrap sources. If, as a result of the RCOI, a company has reason to believe that any of the necessary Conflict Minerals in its supply chain may have originated in the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the company must perform due diligence on the Conflict Minerals' source and chain of custody.

Company Overview

Accuray is a radiation therapy company that develops, manufactures, sells and supports market-changing solutions that are designed to deliver radiation treatments for even the most complex cases, while making commonly treatable cases even more straightforward, to meet the full spectrum of patient needs. Accuray's innovative technologies, the CyberKnife and TomoTherapy platforms, including the Radixact System, it's next generation TomoTherapy platform, are designed to deliver advanced treatments, including stereotactic radiosurgery (SRS), stereotactic body radiation therapy (SBRT), intensity modulated radiation therapy (IMRT), image-guided radiation therapy (IGRT), and adaptive radiation therapy (ART). The CyberKnife and TomoTherapy platforms have complementary clinical applications with the same goal: to empower Accuray's customers to deliver the most precise and accurate treatments while still minimizing dose to healthy tissue, helping to reduce the risk of side effects that may impact patients' quality of life. Each of these systems serves patient populations treated by the same medical specialty, radiation oncology, with advanced capabilities. The CyberKnife platform is also used by neurosurgeons specializing in radiosurgery to treat patients with tumors in the brain and spine, and neurologic and/or endocrine disorders. Accuray is headquartered in the United States and also has primary offices in Switzerland, China, Hong Kong and Japan and conducts its business worldwide.

Description of the Products Covered by this Report

This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of such product; (ii) that were manufactured, or contracted to be manufactured, by Accuray; and (iii) for which the manufacture was completed during calendar year 2025. These products, which are referred to in this Report collectively as the "Covered Products," are the CyberKnife and TomoTherapy Systems, including the Radixact System.

Supply Chain Overview

All of Accuray's products are complex and require the integration of a number of components from several sources. Such components are manufactured by Accuray or contract manufacturers or are otherwise purchased by Accuray from third parties. As such, Accuray is many steps removed from the mining of Conflict Minerals; Accuray does not purchase raw or unrefined Conflict Minerals, and does no purchasing in the Covered Countries. Accuray's supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Conflict Minerals. In this regard, Accuray does not purchase Conflict Minerals directly from mines, smelters or refiners. As explained further below, Accuray must therefore rely on its suppliers to provide information regarding the origin of the Conflict Minerals in the Covered Products.

Reasonable Country-of-Origin Inquiry

Accuray has conducted a good faith RCOI regarding the Conflict Minerals that were necessary to the functionality or production of the Covered Products (the "Necessary Conflict Minerals"). This RCOI was reasonably designed to determine whether any of the Necessary Conflict Minerals originated in the Covered Countries or came from recycled or scrap sources. The RCOI comprised of the conduct described under the caption "Description of Due Diligence Measures - OECD Step 2 -Identify and Assess Risk in the Supply Chain" below. As a result of the RCOI, Accuray knows or has reason to believe that a portion of its Necessary Conflict Minerals originated or may have originated in the Covered Countries and knows or has reason to believe that those Necessary Conflict Minerals may not be from recycled or scrap sources. In response, Accuray also performed due diligence on the source and chain of custody of the Necessary Conflict Minerals to seek to determine whether the Covered Products were "DRC conflict free" (as defined in the Rule). Suppliers define the scope of their representations to Accuray at their own discretion and, as a result, the information provided to Accuray may be provided at a company level, division level, product category level or at a product level. Therefore, as a downstream procurer of components that may or may not contain Conflict Minerals, Accuray's RCOI efforts and due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody on Conflict Minerals.

Due Diligence Performed

Design of Due Diligence

Accuray designed its due diligence measures to be in conformity with, in all material respects, the internationally recognized due diligence framework in The Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the "OECD Framework"), consistent with Accuray's position as a downstream purchaser. The scope of Accuray's due diligence remained on Conflict Minerals - namely tin, tantalum, tungsten and gold (together, the "3TG"). Accuray integrated the five-step OECD Framework into its due diligence measures as described below.

Accuray's due diligence process required us to rely on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot be fully owned by Accuray. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, risk gaps can be mitigated. This aligns with industry standards and market expectations for downstream companies' due diligence.

Description of Due Diligence Measures

Accuray's due diligence measures performed with respect to Covered Products included the following:

1.	OECD Step 1 - Establish Strong Company Management Systems

Conflict Minerals policy statement. Accuray has actively engaged with its customers and suppliers for several years with respect to the use of Conflict Minerals. Accuray has also adopted a policy statement regarding Conflict Minerals that outlines its commitment to prevent the use of Conflict Minerals that, directly or indirectly, finance or benefit armed groups in the Covered Countries. This statement is available on Accuray's website at www.accuray.com/conflict-minerals-policy-statement, and suppliers are expected to follow this policy and provide Accuray with conflict-free parts and products.

Conflict Minerals team. Accuray's Conflict Minerals team, consisting of a cross-functional team of individuals from Accuray's engineering and sourcing teams as well as the legal team, collectively reviewed Accuray's Conflict Mineral supply chain. The executive team at Accuray had oversight responsibility for the work done by the Conflict Minerals team and that team reported to the executive team as needed. Further, the Conflict Minerals team members have knowledge of the Rule, Conflict Minerals and in properly reviewing and validating supplier responses. In addition, Accuray engaged a third-party service provider, Assent Compliance ("Assent") to, among other things: assist the Conflict Minerals team with management of supplier engagement; collect, process and store data from supplier responses through its online platform; review and validate supplier responses; assist with evaluating supply chain information regarding Conflict Minerals; identify potential risks; and develop and implement additional due diligence steps with regards to Conflict Minerals. As discussed in more detail below, the Conflict Minerals team worked collaboratively with Assent in connection with its due diligence efforts, including having a structured meeting cadence with Assent to review responses from Accuray's suppliers deemed to be in-scope.

System of controls and transparency. Accuray has developed and implemented a Supplier Code of Conduct, which describes the minimum standards of ethical and responsible conduct for Accuray's suppliers. Suppliers are strongly encouraged to comply with this code of conduct and are expected to meet internationally-accepted principles such as the United Nations Guiding Principles on Business and Human Rights. Accuray also endeavors to require all suppliers to accept the Supplier Code of Conduct through a contractual provision in its supply agreements. Accuray may periodically evaluate a supplier's compliance with the code to determine whether to continue the business relationship with such supplier. Failure to follow any of the provisions of such code can result in termination or non-renewal of any and all agreements with Accuray. In addition, Accuray used a supplier database maintained by Assent for collecting and retaining supplier responses and other information necessary to support Conflict Minerals inquiry and reporting in an effort to enhance its due diligence processes and improve the accuracy and completeness of supplier data. The Conflict Minerals team regularly reviewed the responses in the database with Assent throughout the due diligence process, including via the recurrent meetings.

Strengthen engagement with suppliers. Accuray continues to place a strong emphasis on supplier education and training. To help suppliers understand Accuray's expectations and its due diligence and disclosure obligations under the Rule, and to facilitate supplier responsiveness, Accuray leveraged Assent's online resources and all in-scope suppliers were provided access to Assent's library of Conflict Minerals training and support resources. In the event any responses were deemed invalid, Assent provided suppliers with guidance on correcting validation errors, including by providing direct feedback on their submission, directing them to appropriate training courses and having a direct dialogue with suppliers through Assent's Supplier Experience team. Furthermore, to mitigate against invalid responses, Accuray's suppliers are able to leverage Assent's team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete the request. Suppliers are provided guidance in their native language, if needed. Assent's automated feedback process also notifies suppliers of risks associated with their Template submission and serves to educate suppliers of certain conflict minerals' risks. Accuray believes that the combination of the Supplier Code of Conduct, its Conflict Minerals policy statement, and direct engagement with suppliers for conflict minerals training and requests constitute an effective supplier engagement program with respect to Conflict Minerals.

Establish a company grievance mechanism. Accuray maintains a whistleblower hotline that is available to report, confidentially and anonymously, violations of Accuray's policies or other illegal or unethical behavior, online at www.accuray.ethicspoint.com or by phone at (800) 499-8895. Concerned parties who wish to report information regarding Accuray's sourcing and use of Conflict Minerals in its products can do so through this existing hotline.

2.	OECD Step 2 - Identify and Assess Risk in the Supply Chain

To identify risks in Accuray's supply chain, Accuray relied on suppliers to provide information on the origin of the Conflict Minerals contained in supplier products or components that are included in the Covered Products. Accuray conducted a comprehensive analysis of component suppliers of the Covered Products according to the bill of materials and compiled a list of in-scope suppliers based on the probability of any 3TG in their product. Accuray considered all such suppliers contacted to be "in scope" for purposes of its assessment.

Accuray provided the list of all such suppliers to Assent for upload to the Assent Compliance Manager ("ACM") and requested that each supplier complete a Conflict Minerals Reporting Template ("Template") as developed by Responsible Minerals Initiative ("RMI") and return the completed Template to Assent via their ACM. Accuray also periodically reviewed the supplier list to ensure that irrelevant or "out of scope" suppliers were removed from the survey process based on the most current information available. The Assent ACM is a software-as-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications, and allows suppliers to upload completed Templates directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Framework process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier's declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

The Template is a recognized standard method for companies such as Accuray to use in the collection of representations, statements and data from Accuray's suppliers related to the presence, use, source and chain of custody of the Conflict Minerals. Suppliers are asked if the Covered Product(s) they supply to Accuray contain Conflict Minerals in order to determine whether the Necessary Conflict Minerals in supplier products or components were or were not "DRC conflict free" (as defined in the Rule). The Template requested suppliers to include the country of origin of any Conflict Minerals and the facilities used to process these minerals. Suppliers were asked to confirm whether the particular products they supply to Accuray contained any 3TGs and identify materials down to the smelter and mine. Risks associated with supplier responses are identified automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent staff and members of the Conflict Minerals team.

The collection process included an introductory notification from Assent to all in-scope suppliers describing the compliance requirements and requesting completion of the Template. Assent requested that all in-scope suppliers complete the Template and made available training and educational resources to guide suppliers on best practices and the use of the Template. Assent monitored and tracked all communications for reporting and transparency purposes. All in-scope suppliers that were unresponsive to the initial request were contacted via e-mail or phone call several times over the course of the diligence period to encourage them to submit a valid Template. The Conflict Minerals team also directly contacted suppliers that were unresponsive to Assent's communications during the diligence process and requested these suppliers complete the Template and submit it to Assent. Assent subjected all submitted Templates to an automated data validation to identify inaccurate submissions and contradictory answers. This data validation is based on questions within the declaration tab of the Template, which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the suppliers. The results of this data validation contribute to the program's health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement. All submitted Templates are accepted and classified as valid or invalid and in-scope suppliers that submitted invalid Templates were contacted regarding such Template and encouraged to resubmit an amended Template. The Conflict Minerals team monitored the status of the outreach and supplier responses through information made available via Assent.

Assent analyzed the responses provided by the in-scope suppliers, contacted the in-scope suppliers for additional information, and gathered other pertinent data, in order to identify and assess risks. These risk assessments are reviewed with members of the Conflict Minerals team. Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed 3TG mineral processing facilities on their Template declarations. In addition, Assent compared these facilities listed to the list of smelters and refiners consolidated by the RMI to ensure that the facilities meet the recognized definition of a 3TG processing facility that was operational during the 2025 calendar year. Assent also compared the identified smelters and facilities against lists published by the Responsible Minerals Assurance Process ("RMAP"), developed by the RMI, of smelters and refiners that have been certified as conflict-free (i.e., conformant with RMAP assessment protocols) or that are "active" in the RMAP process (i.e., they have agreed to participate in the RMAP but the audit process has not yet been completed). Accuray does not have a direct relationship with smelters/refiners, and does not perform direct audits of these entities within their supply chain. Smelters that are conformant to RMAP audit standards are considered to have their sourcing validated as "conflict free or responsibly sourced." In cases where the smelter's due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to in-scope suppliers reporting those facilities. Smelters are then assessed for the potential for sourcing risk.

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined by the OECD Framework. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

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Geographic proximity to the DRC and covered countries;

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Known mineral source country of origin;

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RMAP audit status;

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Credible evidence of unethical or conflict sourcing;

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Peer assessments conducted by credible third-party sources; and

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Sanction risks.

Risk mitigation activities were initiated whenever a supplier's Template reported facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing that supplier to take their own independent risk mitigation actions. Examples include the submission of a product-specific Template to better identify the connection to products that they supply to Accuray. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

In addition, in-scope suppliers were evaluated by Assent on the strength of their Conflict Minerals programs based on criteria including:

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Whether the supplier has a policy in place that includes DRC conflict-free sourcing;

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Whether the supplier has implemented due diligence measures for conflict-free sourcing;

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Whether the supplier verifies due diligence information received from its suppliers against the Company's expectations; and

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Whether the supplier's verification process includes corrective action management.

Suppliers who Assent determines do not meet or exceed these criteria are expected to receive educational material from Assent on how to improve their Conflict Minerals programs.

3.	OECD Step 3 - Design and Implement a Strategy to Respond to Risk

Together with Assent, Accuray is continuing its development of a process for assessing and responding to risks identified in its supply chain. Accuray currently determines on a case-by-case basis the appropriate risk mitigation strategy for any supply chain risks identified in the course of its due diligence efforts. Potential outcomes under this risk mitigation strategy include continuing to work with the supplier while risks are addressed, suspending the relationship on a temporary basis while risk mitigation is pursued or discontinuing the relationship with the supplier where risk mitigation efforts have failed. Additional factors are taken into consideration in determining the appropriate risk mitigation strategy for certain suppliers, including supplier size and capabilities, whether alternatives are available and Accuray's dependence on the supplier.

In addition to the above, Assent provides feedback on supplier submissions directly to such suppliers and educational resources are provided to assist such suppliers in corrective action methods or to improve their internal programs. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.

The results of the program and risk assessment are shared with the Conflict Minerals team to ensure transparency within Accuray.

4.	OECD Step 4 - Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices

As Accuray has no direct relationship with smelters or refiners in its supply chain, it did not perform or direct audits of these entities within its supply chain. Instead, Accuray relies on data collected and published by RMAP. RMAP performs an independent third-party audit program that evaluates smelter and refiner procurement activities and determines whether the smelter or refiner demonstrated that it has systems and controls in place to ensure that all materials it processed originated from conflict-free sources.

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities' sourcing practices on behalf of its compliance partners.

5.	OECD Step 5 - Report on Supply Chain Due Diligence

As required under the Rule, Accuray has filed its Form SD, which contains this Report as an exhibit, with the SEC for the Reporting Period. Accuray expects to report annually, as required by the Rule, and has posted this Report on its website.

Accuray has also considered impacts from the EU Conflict Minerals Regulation when disclosing details with regards to due diligence efforts. The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public report.

Due Diligence Outcome

As a result of its due diligence measures described above, Accuray received responses from 148 out of 182 (81.32%) in-scope suppliers that were contacted, with 100% of the suppliers who responded providing a Template. The Conflicts Mineral team continues to follow up with 34 in-scope suppliers from whom we have not yet received relevant information. Among the suppliers who responded:

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23 suppliers provided a completed Template incorporating responses from 100% of suppliers in their supply chain, including the names and locations of smelters and refiners that process Conflict Minerals used in components provided by such supplier, with 5 of such suppliers providing Templates that identified materials down to the location of mine.

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Of those suppliers that provided a Template, 55 indicated that the products supplied to Accuray did not contain any 3TG, 64 indicated that the products supplied to Accuray were "DRC conflict undeterminable," 21 indicated that the products supplied to Accuray were "non-DRC 3TGs" and 8 indicated that the products supplied to Accuray were "DRC conflict free."

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Of those suppliers that provided a Template, 8 provided inconsistent or incomplete information or provided information that suggest issues continue to remain with comprehension of the topic or how to accurately complete the Template.

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22 or 43% of tungsten smelters and refiners identified are verified "conflict-free" for tungsten.

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33 or 44% of tin smelters and refiners identified are verified "conflict-free" for tin.

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22 or 63% of tantalum smelters and refiners identified are verified "conflict-free" for tantalum.

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94 or 52% of gold smelters and refiners identified are verified "conflict-free" for gold.

Given that not all smelters identified by our suppliers were certified as "conflict free" by an independent third-party audit program, and that a number of supplier responses regarding the sources of raw materials for the Covered Products were determined to be uncertain or unknown (including because certain suppliers were only able to provide responses at the company-level rather than information specific to Accuray products), Accuray was unable to precisely determine whether or not all supplier parts in its supply chain for the Covered Products contain Necessary Conflict Minerals from the Covered Countries or, in the alternative, utilized Conflict Minerals in their manufacture that either financed or benefited, directly or indirectly, armed groups in the Covered Countries. As such, Accuray's due diligence in 2025 found that Accuray products containing or utilizing Conflict Minerals are "DRC conflict undeterminable" (as defined in the Rule).

The statements above are based on the RCOI process and due diligence performed in good faith by Accuray. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect this Report. These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers or third-party service providers, errors or omissions by smelters, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversights or errors in conflict-free smelter audits, Covered Countries' sourced materials being declared secondary materials, companies not continuing in business in 2025 or 2026, certification programs that are not equally advanced for all industry segments and metals, and smuggling of the Conflict Minerals to countries beyond the Covered Countries.

Identified Smelters and Refiners

As a result of Accuray's RCOI and due diligence, Accuray has compiled a list on Schedule 1 of the smelter and refiner facilities that met the recognized definition of a 3TG processing facility and were operational during the 2025 calendar year identified by its suppliers in completed Templates provided by such suppliers. Out of the 148 suppliers that provided smelter lists, 9 provided the smelters at the product level (i.e., they provided information for the particular types of products and components they supplied to Accuray), 135 provided smelters at the company level (i.e., they provided information regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components used in the Covered Products), and 4 were "user defined." As a result, some of the smelters and refiners reported to Accuray and identified on Schedule 1 may not actually have been used to process the Necessary Conflict Minerals in the Covered Products. In addition, Accuray has taken measures to validate the sources of origin against validated audit programs intended to verify the material types and mine sources of origin for these smelters and refiners.

Identified Countries of Origin of Necessary Conflict Minerals

Accuray does not have sufficient information to reliably determine the countries of origin of all of the Necessary Conflict Minerals in the Covered Products given that certain suppliers provided inconsistent or incomplete responses or provided information at the company level. However, based on information provided by Accuray's in-scope suppliers in completed Templates, Accuray believes that the countries of origin may include the countries listed in Schedule 2. As discussed above, because some suppliers provided information at the company level, the countries of origin of the Necessary Conflict Minerals in the Covered Products may not actually include certain of the countries in Schedule 2.

Efforts to Determine Mine or Location of Origin

Accuray's efforts to determine the mines or locations of origin of the Necessary Conflict Minerals with the greatest possible specificity included the use of the RCOI and due diligence measures described above.

Future Due Diligence and Risk Mitigation

Accuray intends to take the following steps, among others, to continue to improve the due diligence conducted and to further mitigate the risk that the Necessary Conflict Minerals in Accuray's products benefit armed groups in the Covered Countries:

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Improve the effectiveness of the due diligence procedures described above through better scoping of suppliers for in-scope suppliers and earlier engagement with suppliers to provide additional time for valid submissions.

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Encourage suppliers to implement responsible sourcing by using Conflict Minerals only from RMAP audited smelters or refiners or to encourage their smelters and refiners to obtain a conflict-free designation from a third-party program.

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Include in purchase order terms and conditions the need to follow our Supplier Code of Conduct.

Inherent Limitations on Due Diligence Measures

Accuray's supply chain with respect to the Covered Products is complex, and its procurement and manufacturing process is significantly removed from the sourcing, mining, smelting and refining of Conflict Minerals. As a result, Accuray does not have direct contractual relationships with smelters, refiners or mines, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. Moreover, Accuray believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and, therefore, has taken steps to identify the applicable smelters and refiners of Necessary Conflict Minerals in Accuray's supply chain by using the Template. However, tracing these minerals to their sources is a challenge that requires Accuray to rely on its direct suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Necessary Conflict Minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. In addition, because of the Accuray's relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited.