FORM SD
Specialized Disclosure Report

QUANTUM CORPORATION
(Exact name of registrant as specified in its charter)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Quantum Corporation has evaluated its current products and determined that certain products we manufacture or contract to manufacture contain tin, tungsten, tantalum and/or gold (“3TG”). Based on the outcome of our due diligence procedures, we have filed a Conflict Minerals Report.

Reasonable Country of Origin Inquiry (RCOI)

Following our initial determination that our hardware products contain components that contain 3TG minerals, Quantum conducted an RCOI to determine which components contain 3TG minerals and whether such 3TG minerals originated in the Covered Countries. Our RCOI was based on a survey of our direct suppliers of parts, components and assemblies containing conflict minerals. We requested that the EICC GeSI conflict minerals reporting template be completed. Over 75% of our suppliers responded. Based on those responses, Quantum determined that 3TG minerals present in certain of its products may have originated in the Covered Countries and were not from scrap or recycled sources. Therefore, in accordance with Rule 13p-1, Quantum proceeded to engage in due diligence regarding the sources and chain of custody of its 3TG minerals.

We have identified over 200 direct suppliers whose components may contain 3TG minerals. We rely on these suppliers to provide us with information about the source of conflict minerals contained in the components supplied to us based on the EICC GeSI conflict minerals reporting template. Our direct suppliers are similarly reliant upon information provided by their suppliers. Many of the largest suppliers are also SEC registrants and subject to Rule 13p-1.

Conflict Minerals Disclosure

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.02 hereto and is publicly available Company’s website at http://www.quantum.com, where the document may be found by clicking “About Us” from the home page, selecting “Investor Relations” and then clicking on “Corporate Documents.”

Item 1.02 Exhibit

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2 – Exhibits

Item 2.01 Exhibits

Exhibit 1.01 -- Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

Exhibit 1.01

Quantum Corporation

Conflict Minerals Report

Introduction

This is the conflict minerals report for Quantum Corporation (“Quantum”, “we” or “us”) for the calendar year 2014 in accordance with Rule 13p-1 under the Securities Exchange Act (“Rule 13p-1”).

Quantum is a leading expert in scale-out storage, archive and data protection, providing solutions for capturing, sharing, transforming and preserving digital assets over the entire data lifecycle. Our customers, ranging from small businesses to major enterprises, have trusted us to address their most demanding content workflow challenges. We provide solutions for storing and protecting information in physical, virtual and cloud environments that are designed to help customers Be Certain™ they have an end-to-end storage foundation to maximize the value of their data by making it accessible whenever and wherever needed, offering indefinite retention and reducing total cost and complexity. Quantum’s primary hardware products include Scalar® automated tape libraries and DXi® deduplication disk system. A more complete description of our products is included in our Annual Report on Form 10-K filed with the Securities and Exchange Commission.

Quantum hardware products require components that contain 3TG minerals. Accordingly, pursuant to Rule 13p-1, we conducted a reasonable country of origin inquiry (“RCOI”). Based on those responses, Quantum determined that 3TG minerals present in certain of its products may have originated in the Covered Countries and were not from scrap or recycled sources. Therefore, in accordance with Rule 13p-1, Quantum proceeded to engage in due diligence regarding the sources and chain of custody of its 3TG minerals as further described in this report.

Company Management Systems

Policy for Conflict Minerals

We have established and committed to a company statement that explains the importance of the conflict minerals issue and our responsibility for addressing conflict minerals in our supply chain. A copy of our Policy for Conflict Minerals can be viewed on our company’s website at http://www.quantum.com, where the document may be found under “Legal” on the home page, selecting “Ethics & Compliance” and then clicking on our Environmental Report under “Environmental Responsibility.”

Internal Management

Our internal Conflict Minerals team is led by the Environmental Responsibility Manager who implements our Conflict Minerals Sourcing Policy. The Product Management team supports supplier contact. Regular reviews of these efforts are communicated to senior management.

Control systems

As we do not have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our industry, and take advantage of third party industry resources including the Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative’s (EICC-GeSI) Conflict Free Sourcing Initiative (CFSI) efforts.

Controls include, but are not limited to, our Code of Conduct (The High Road) which outlines expected behaviors for all Quantum employees, our Supplier Code of Conduct, our Conflict Minerals Policy and our Environmental Requirements Specification. These documents detail supplier requirements and obligate participation in Conflict Minerals Reporting.

Grievance Mechanism

We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Quantum’s policies, including reports to our ethics committee and our third party hotline. Information about these mechanisms are available in our Code of Conduct which is posted on the investor relations section of our website.

Maintain records

We have adopted a policy to retain relevant documentation.

Identification and Assessment of Risks in Our Supply Chain

We participate in the following industry-wide initiatives to disclose upstream actors in the supply chain: The Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative’s (EICC-GeSI) and the Conflict Free Sourcing Initiative (CFSI). As part of our risk assessment plan and to ensure suppliers understand our expectations, we provide feedback on supplier reporting that may be incomplete or inaccurate.

Quantum requests our suppliers to complete the EICC GeSI conflict minerals reporting template. We have determined that this process represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

Risk is assessed by reviewing information contained in the declaration tab of our suppliers CMRT and by comparing the data contained in the suppliers Smelter List against the CFSI Smelter and Refiner list.

Due Diligence

We designed our due diligence framework to conform with the internationally recognized due diligence framework provided by The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas , and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, “OECD Guidance”), specifically as it relates to our position in the minerals supply chain as a “downstream” purchaser. Below we describe our due diligence processes with respect to Steps 3 and 4 of the OECD Guidance. OECD steps 1, 2 and 5, are described in the Form SD and elsewhere in this report.

Design and Implement a Strategy to Respond to identified Risks

Quantum has a risk management plan, through which the conflict minerals program is implemented, managed and monitored. Updates to this risk assessment are provided regularly to senior management.

Quantum suppliers provided the EICC GeSI conflict minerals reporting template with varying results. A third party evaluation service was used to identify and evaluate smelter data against the data provided by the Conflict-Free Smelter Program. Many data inconsistencies were identified during this process, and verification efforts with the relevant suppliers are ongoing to resolve the data inconsistencies. We also continue to follow up with suppliers that have not yet responded to our requests for 3TG information. We are advising suppliers that failure to adequately respond to our request for 3TG information may result in loss of approved vendor status.

As described in our conflict minerals policy, we engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the Covered Countries and encourage them to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.

Many of our suppliers were unable to represent to us that 3TG from the entities they listed had actually been included in components they supplied to Quantum. In addition, many processing facilities were not validated as in fact being smelters or refiners. We have therefore elected to present only the smelter and refiner names identified by the CFSI in this report. (Table 1). Of those smelters that have been identified, 49% have been found to be CFSI compliant, Active or Progressing. Quantum will continue to encourage suppliers to utilize only compliant smelters.

Participate and support third party audit programs

We do not have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of the due diligence practices of these entities within our supply chain. However, we support audits through our participation in various industry initiatives. Quantum compares supplier smelter data with CFSI smelter lists and considers smelters and refiners identified by the CFSI as Compliant to be Conflict-Free.

Annual Reporting on Supply Chain Due Diligence

This report will be posted at http://www.quantum.com, where the document may be found under “Legal” on the home page, selecting “Ethics & Compliance” and then clicking on our Environmental Report under “Environmental Responsibility.”

Future Due Diligence Measures

During calendar 2015, we expect to continue to receive and evaluate supplier 3TG information and we intend to continue to enhance our supplier communication and training information to improve data accuracy and ongoing supplier updates of sourcing information. We also continue to follow up with suppliers that have not yet responded to our requests for 3TG information. We are advising suppliers that failure to adequately respond to our request for 3TG information may result in loss of approved vendor status. If a supplier is not on our approved vendor list, we will not obtain or accept parts from that supplier.

Audit

An independent private sector audit of our Conflict Minerals Report was not required for 2014.

Table 1. Smelters recognized by the CFSI reported in Quantum products.