CommScope Holding (COMM) SDConflict minerals disclosure

Exhibit 1.01

Conflict Minerals Report of CommScope Holding Company, Inc.

For the Calendar Year Ended December 31, 2020

Pursuant to Rule 13p-1 Under The Securities Exchange Act of 1934

CommScope Holding Company, Inc. presents this Conflict Minerals Report for the reporting period of January 1, 2020 to

December 31, 2020 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission. Unless otherwise specified or unless the context otherwise requires, references to “CommScope,” “we,” “us” or “our” refer to CommScope Holding Company, Inc. and its consolidated subsidiaries.

Overview of our Conflict Minerals Program

CommScope is a leading global provider of infrastructure solutions for communication networks. In 2014, our leaders defined a sustainability philosophy on corporate responsibility that embraces our core company values. In keeping with our values and supporting our efforts to respect people and our planet, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner and source raw materials only from reputable organizations pursuant to our Conflict Minerals Policy (the “Policy”) and following the Organisation for Economic Co-operation and Development (“OECD”) due diligence framework, third edition. The Policy is available on our website at https://www.commscope.com/Docs/Corporate-Responsibility/Supplier-Responsibility/CommScope_Conflict_Minerals_Policy.pdf.

CommScope Products

Conflict minerals in the form of tin, tantalum, tungsten and gold were necessary to the functionality or production of certain products we manufactured or contracted to have manufactured during 2020 within our operating segments as follows:

Reasonable Country of Origin Inquiry

We conducted a reasonable country of origin inquiry (“RCOI”) and due diligence on the source and chain of custody using the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”) to determine whether any of the necessary conflict minerals in our 2020 products originated in the Democratic Republic of the Congo (“DRC”) and the adjoining countries (the “Covered Countries”), or were conflict minerals from recycled or scrap sources. The term “conflict minerals” comes from Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and is defined as columbite-tantalite, also known as coltan (from which tantalum is derived); cassiterite (tin); gold; wolframite (tungsten); or their derivatives; or any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the DRC or any of the Covered Countries. To make the RCOI determination, we engaged our suppliers to identify the smelters and refiners (“facilities”) of necessary conflict minerals that may have been contained in our products and reviewed available information on the sourcing of conflict minerals by facilities, including information about the facilities provided by RMI regarding processors of conflict minerals.

Our RCOI included:

We have communicated to suppliers that we expect all materials supplied to CommScope to be free of conflict minerals from facilities that directly or indirectly support the illegal armed groups in the DRC region. However, continuing to source from conformant facilities from the Covered Countries is acceptable.

RCOI Conflict Minerals Status

We have determined with respect to our products containing necessary conflict minerals that we know or have reason to believe that some of the necessary conflict minerals originated or may have originated in the Covered Countries.

Conflict Minerals Due Diligence Measures

Our conflict minerals due diligence process is based on the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition 2016), a recognized due diligence framework. We conducted due diligence measures on the source and chain of custody of our conflict minerals to determine whether these conflict minerals originated in the DRC or any of the Covered Countries and financed or benefited non-state armed groups in any of these countries.

Design of our Due Diligence Measures

The design of our due diligence measures is specific to our downstream position in the minerals supply chain and the OECD recommendations for downstream actors that have no direct relationships to facilities. As a member of RMI, we evaluate all facilities reported by suppliers against the RMI Smelter Database and the RMI RCOI Data to determine facility validity and country of origin.

The design of our due diligence process includes the following steps:

As a downstream supplier, we do not assess the due diligence practices of facilities. We assess supplier responses against internally established criteria for completeness, consistency and risk. We contact suppliers that provided incomplete, inaccurate or untraceable information to correct and/or obtain additional information. Unresponsive suppliers are identified and forwarded to the Procurement team for further review. Each unresponsive supplier is indicated in a report provided to the Conflict Minerals Corporate Management Team for supplier review to determine if alternative sourcing will be pursued. We encourage in scope suppliers to urge facilities in their supply chain to join the Responsible Minerals Assurance Process (“RMAP”). We evaluate all facilities reported by suppliers against the RMI Smelter Database and the RMI RCOI Data to determine facility validity and country of origin.

We support the industry initiative that conducts audits of facilities’ due diligence activities and we encourage our suppliers to source from facilities that participate in the RMAP. As a downstream supplier, we do not have a direct relationship with conflict minerals facilities and do not perform or direct audits of these entities within our supply chain. As a member of RMI, we utilized information made available by RMI concerning independent third-party audits of facilities and country of origin.

Future Goals to Mitigate Risk

We are committed to continuously improving our RCOI and due diligence process and intend to take the following steps in 2021:

Due Diligence Results

We had a response rate of 97% to our supplier RCOI and due diligence performed for facilities indicated by suppliers as having sources in the Covered Countries is as follows:

Based on the RMI RCOI Data as of January 29, 2021, 47 smelters or refiners were identified as sourcing from the Covered Countries. All were listed on the RMI Conflict-Free Smelter list.

Two suppliers indicated a gold smelter located in Uganda. According to the RMI Smelter database, the smelter RMAP Audit status is “Outreach Required.” Detailed sourcing information is not available at this time. CommScope and RMI continue to urge this smelter to participate in the program.

Overall, of the 331 unique smelters identified by our suppliers and verified against RMI known facilities, 237 are listed as “Conformant” by RMI and 22 are “Active” based on the RMI Smelter database as of March 3, 2021.

Table 1: Countries of Origin and Facilities Used to Process Conflict Minerals in CommScope Products

The following list represents the facilities provided by suppliers, verified against RMI known facilities.

Countries of origin for these facilities are believed to include: Angola, Argentina, Armenia, Australia, Austria, Azerbaijan, Bahamas, Bangladesh, Belarus, Belgium, Benin, Bolivia, Botswana, Brazil, Brunei, Bulgaria, Burkina Faso, Burundi, Cameroon, Canada, Cayman Islands, Chile, China, Colombia, Costa Rica, Cote d'Ivoire, Croatia, Cuba, Cyprus, Czechia, Democratic Republic of the Congo, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Fiji, Finland, France, French Guiana, Gabon, Gambia, Georgia, Germany, Ghana, Greece, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Iran, Ireland, Israel, Italy, Ivory Coast, Japan, Jordan, Kazakhstan, Kazakhstan , Kenya, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Libya, Liechtenstein, Lithuania, Luxembourg, Macau, Madagascar, Malaysia, Mali, Malta, Mauritania, Mauritius, Mexico, Monaco, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Caledonia, New Zealand, Nicaragua, Niger, Nigeria, Norway, Pakistan, Panama, Papua New Guinea, Paraguay, Peru, Philippines, Poland, Portugal, Puerto Rico, Qatar, Republic of Korea, Romania, Russia, Russian Federation, Rwanda, San Marino, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Slovenia, Solomon Islands, Somaliland, South Africa, South Korea, Spain, St Vincent and Grenadines, Sudan, Suriname, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Uganda, Ukraine, United Arab Emirates, United Kingdom, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Yemen, Zambia, Zimbabwe.

Efforts to Determine the Conflict Minerals’ Mine or Location of Origin

Through our participation in the RMI and requiring our suppliers to complete the CMRT we have determined that seeking information about conflict mineral facilities in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the conflict minerals in our supply chain.