Specialized Disclosure Report (Form SD)

Extreme Networks, Inc.

Conflict Minerals Report

For The Calendar Year Ended December 31, 2025

This Conflict Minerals Report (the "Report") for Extreme Networks, Inc. ("we" or "our") is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1") for the reporting period from January 1 to December 31, 2025. Rule 13p-1 requires the disclosure of certain information by companies that manufacture or contract to manufacture products that use minerals specified in Rule 13p-1 that are necessary to the functionality or production of these products. These minerals are columbite-tantalite (coltan), cassiterite, wolframite, gold, or their derivatives, which the Securities and Exchange Commission has limited to tantalum, tin, tungsten and gold (collectively, the "Minerals").

We have determined that certain Minerals are necessary to the functionality or production of our networking equipment. We generally manufacture our products through contract manufacturers. As a result, we do not have direct relationships with many of our suppliers. Due to the depth of the supply chain, we are far removed from the sources of ore from which these metals are produced and the smelters/refiners that process those ores. Consequently, we rely on our contract manufacturers, direct and indirect suppliers, and industry initiatives for source information on the Minerals in our products.

For the reporting period from January 1 to December 31, 2025, we conducted reasonable country of origin ("RCOI") activities followed by due diligence investigations to determine the source and chain of custody of the Minerals that are necessary to the functionality or production of our products.

We have reason to believe, based on our reasonable country of origin inquiry and due diligence, that certain smelters within our supply chain may source Minerals from the Democratic Republic of the Congo ("DRC") or from Conflict-Affected and High-Risk Areas ("CAHRAs"), as defined by the Responsible Minerals Initiative ("RMI"). Although Rule 13p-1 defines "Covered Countries" as the DRC and its adjoining countries, we consider CAHRAs more broadly as part of our responsible sourcing risk assessment, consistent with RMI guidance.

RMI's definition of CAHRAs includes countries identified as high risk under applicable conflict minerals frameworks, including the DRC and its adjoining countries, as well as other regions identified by regulatory bodies such as the European Commission pursuant to Article 14.2 of Regulation (EU) 2017/821.

A majority of identified Smelters were classified by RMI as Responsible Minerals Assurance Process ("RMAP") conformant. Where smelters are identified as RMAP non-conformant and source Minerals from the DRC or CAHRAs, we engage with the relevant suppliers to obtain remediation plans and timelines for transitioning away from such smelters, and we take additional steps, where appropriate, to mitigate associated risks within our supply chain. Because we are a downstream company and rely on supplier-provided information, we do not have direct relationships with smelters or refiners and, in many cases, cannot determine whether specific smelters reported by suppliers contributed to our products.

Company Overview

We are a provider of cloud networking solutions, software, and services. We design, develop, and manufacture wired, wireless, and software-defined wide area network ("SD-WAN") infrastructure equipment, software, and cloud-based network management solutions. Our cloud-based platform offers unified network management across wireless access points, switches, and SD-WAN, and leverages machine learning, artificial intelligence for information technology operations and analytics to help customers deliver secure connectivity at the edge, accelerate cloud deployments, and derive actionable insights to save time, lower costs, and streamline operations. We conduct our sales and marketing activities on a worldwide basis through distributors, resellers, and our field sales organization.

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Conflict Minerals Program

We are committed to the responsible sourcing and use of conflict-free minerals as components of any products linked to our business endeavors. We are a member of the Responsible Business Alliance ("RBA"). As a member of the RBA, we expect all suppliers to abide by the RBA Code of Conduct.

We have established a conflict minerals compliance program that is based on the framework established by the Organisation for Economic Cooperation and Development (the "OECD Framework") applicable to downstream companies. We have continued to expand our conflict minerals compliance program to improve alignment between the Company's due diligence activities and the current OECD Framework.

We engage a third-party service provider to collect data from our suppliers. We rely in good faith on the information suppliers provide and expect them to maintain responsible and ethical business practices consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Reasonable Country of Origin Inquiry

We conducted a RCOI survey of all of our suppliers. Of the 42 suppliers contacted by the Company, 41 suppliers provided valid responses to our questionnaires. Suppliers were asked to utilize the RMI Conflict Minerals Reporting Template ("CMRT") to report on their usage and sourcing of materials containing the Minerals, and all responding suppliers provided CMRTs. The RMI CMRT was developed by several of the world's leading consumer electronics companies and is generally regarded as the most common reporting tool for conflict minerals content and sourcing information. As a downstream company, we rely primarily on supplier-provided CMRTs and RMI data, and therefore our ability to determine the specific mine or location of origin of the necessary Minerals is limited.

These surveys listed a total of approximately 341 unique smelters and refiners ("Smelters") that may process the necessary Minerals contained in our products. Due to the use of company-wide surveys by some suppliers, the multiple tiers in our supply chain, and the fact that many suppliers provide company-level rather than product-level data, we cannot determine with certainty which reported Smelters actually provide the specific Minerals used in our products, and the resulting list of Smelters may be over-inclusive.

Based on the data obtained through our RCOI and due diligence:

We assess smelter status using information provided by the RMI and other publicly available sources and engage with suppliers, as appropriate, regarding higher-risk smelters. We are actively working on smelter outreach and removal where the smelter sources Minerals from the DRC or CAHRAs and is designated as RMAP non-conformant.

Certain additional information regarding smelters and refiners identified through our due diligence process is made available on our corporate website for transparency purposes. The contents of such website are not incorporated by reference into, and are not a part of, this Report.

Design of Due Diligence Measures

The following are the due diligence measures we performed as a result of our RCOI:

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In addition to direct queries to our suppliers, we utilize industry supply chain management tools and our third-party service provider to determine if there is any risk that the Minerals being used in our products are from DRC or CAHRAs and benefit armed groups in these areas. For example, we check the conflict-free status of smelters and refiners on the RMI's website.

Upon receiving information about all smelters within our supply chain, we assess their risk based on their RMI status and the origins of their minerals.

In addition to research regarding whether Minerals have been sourced from the DRC or CAHRA, we also conduct inquiries to determine whether refineries reported by suppliers have been sanctioned by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) ("Sanctioned Entities") as a source of Minerals. If we find such reports, we will continue to conduct due diligence to attempt to confirm whether or not the refineries in question were sanctioned at the time the suppliers acquired Minerals, and whether or not the refinery actually exists in our supply chain. If a supplier continues to use Sanctioned Entities in their supply chain, we will request that the suppliers provide us with schedules for eliminating those Sanctioned Entities from their supply chains.

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Steps To Be Taken To Mitigate Future Risk

We take the following steps to improve the program and further mitigate any risk that the necessary Minerals in our products could benefit armed groups in the DRC or CAHRA: