Supply Chain Management

01Labor

Participating companies must uphold the human rights of all workers and treat them with dignity. This obligation covers everyone employed by the company or its suppliers, including temporary staff, migrant workers, students, contract workers, direct employees, and any other employment arrangements.

Labor and Working Condition Standards

Prohibition of Forced Labor

• Any form of forced labor is strictly prohibited, including confinement such as debt bondage, custodial labor, involuntary or exploitative prison labor, slavery, or human trafficking. This also covers the transportation, harboring, recruitment, transfer, or receipt of individuals through threats, coercion, force, abduction, or fraud for labor or services. Companies must not impose unreasonable restrictions on workers’ entry to or exit from company facilities, including dormitories or housing, nor restrict their freedom of movement within such facilities.
• As part of the employment process, all workers must be provided with a written employment contract in their native language or a language they understand, outlining the terms and conditions of their employment.
• Foreign migrant workers must receive their employment contract before leaving their country of origin. Upon arrival in the destination country, the contract must not be amended or replaced, except where necessary to comply with local laws and only if such changes provide terms that are equal to or more favorable for the worker.
• All work must be voluntary. Workers should be able to resign or terminate their employment anytime without penalty, as long as they provide reasonable notice. This right must be explicitly included in the employment contract.
• Participating companies must keep records for all workers upon their separation from employment.
• Employers, recruitment agencies, and their subcontractors shall not retain, destroy, conceal, or confiscate any identity or immigration documents, including government-issued identification, passports, or work permits.
• Notwithstanding the above, employers may retain such documents only when required to comply with local legal obligations. In these circumstances, workers shall not be denied timely access to their documents.
• Workers shall not be required to pay recruitment fees or any other employment-related charges to employers, recruitment agencies, or their subcontractors. If it is determined that a worker has paid such fees, the full amount shall be reimbursed to the worker.

Child Labor and Young Workers

• Child labor is strictly prohibited at all stages of manufacturing. For the purposes of this policy, a “child” is defined as any person under the age of 15, the age at which compulsory education is completed, or the minimum employment age specified by national law—whichever is highest. Workers under 18, referred to as "young workers," must not be employed in work that may jeopardize their health and/or safety, including night shifts or overtime.
• Participating companies are required to properly manage student workers by keeping accurate records, performing due diligence on partner educational institutions, and protecting the rights of student workers, all in line with relevant laws.
• Participating companies must establish appropriate mechanisms in place to verify the age of workers. The use of legitimate workplace learning programs is supported, provided they comply with all relevant laws.
• Participating companies must provide all student workers with appropriate support and training. In the absence of applicable local laws, the wage rates for student workers, interns, and apprentices must be at least equivalent to those of other entry-level workers performing similar or comparable work. Any cases of child labor must be addressed with appropriate support and corrective measures.

Working Hours

• Working hours must not exceed the limits established by applicable local laws, and companies must also work proactively to reduce excessive working hours.
• Weekly working hours, including overtime, must not exceed 60 hours, except in cases of emergency or extraordinary circumstances.
• All overtime work must be voluntary, and workers must be given at least one day of rest every seven-day period.

Wages and Benefits

• Compensation provided to workers must comply with all applicable laws related to wages, including those governing minimum wages, overtime pay, and legally mandated benefits.
• Participating companies must ensure payment of a living wage that allows employees and their families to sustain an adequate standard of living.
• All workers shall receive equal pay for work of equal value and equivalent qualifications.
• Workers must be compensated for overtime hours at a rate higher than their regular hourly wage.
• Deductions from wages as a form of disciplinary or punitive action are not permitted.
• Workers must be provided with timely and comprehensible wage statements that contain sufficient information to verify accurate compensation for all work performed during each pay period.
• The use of temporary, dispatched, and outsourced workers must adhere strictly to the limits permitted by applicable local laws and regulations.

Non-Discrimination/Non-Harassment/Humane Treatment

• Participating companies are required to ensure their workplaces are free from harassment and illegal discrimination.
• Any form of abusive or inhumane treatment is strictly prohibited, including violence against workers, gender-based violence, sexual harassment, sexual abuse, corporal punishment, psychological or physical coercion, bullying, public humiliation, or verbal abuse. Workers must not face or be at risk of experiencing such behavior.
• Companies shall not engage in discrimination or harassment in recruitment or employment practices—including wages, promotion, compensation, and access to training opportunities—based on race, color, age, sex, sexual orientation, gender identity or expression, ethnicity or nationality, disability, pregnancy, religion, political affiliation, union membership, military service, protected genetic information, or marital status.
• Clear disciplinary policies and procedures addressing these requirements must be established and communicated to all workers.
• Workers must be provided with reasonable accommodations for religious practices and disabilities.
• Furthermore, workers and potential workers must not be required to undergo medical or physical examinations—including pregnancy tests—that could be used discriminatorily. This requirement is established in consideration of the ILO Convention No. 111.

Freedom of Association and Collective Bargaining

• Open communication between employees and management is the most effective way to resolve workplace environment and employment-related issues.
• Workers and their representatives have the right to freely communicate and express their views and concerns regarding working conditions and management practices to management, without fear of discrimination, retaliation, intimidation, or harassment.
• In accordance with these principles, participating companies must respect all workers’ rights to form and join labor unions of their choice, engage in collective bargaining, and participate in peaceful assembly. They must also respect workers' right to refrain from these activities.
• Where applicable laws limit freedom of association and the right to collective bargaining, workers should be allowed to choose and participate in lawful alternative forms of worker representation. All rights related to freedom of association and collective bargaining must comply with local legal requirements.

02Health and Safety

Participating companies acknowledge the significance of not only reducing work-related injuries and illnesses but also recognizing that a safe and hygienic working environment enhances the quality of products and services, manufacturing consistency, worker retention, and morale. They further understand that worker input and training are vital for identifying and resolving workplace health and safety concerns.

Health and Safety Principles

Occupational Health and Safety

• Companies are required to identify and assess potential occupational health and safety hazards, including exposure to chemicals, electrical and other energy sources, fire, vehicles, and falling objects, and to mitigate these risks utilizing the hierarchy of controls.
• Where such measures are inadequate to manage hazards, workers must be provided with appropriate, well-maintained personal protective equipment (PPE) and training materials specific to the risks.
• Appropriate measures must be taken to protect pregnant workers and workers with childcare responsibilities. These measures may include reasonable job adjustments, such as ensuring that pregnant or nursing workers are not assigned to work environments that could pose a danger to themselves or their children.

Emergency Preparedness

• Potential emergency situations and events should be identified and evaluated, with their impact reduced by implementing emergency preparedness and response procedures. This includes incident reporting, employee notification, evacuation protocols, and worker training.
• Emergency preparedness measures must include appropriate fire detection and suppression equipment, clearly marked and unobstructed exits, facilities equipped with sufficient emergency exits, contact information for emergency response personnel, and comprehensive recovery plans.
• These measures and procedures shall prioritize the minimization of harm to life, the environment, and property.

Occupational Injury and Illness

• Procedures and systems must be established to prevent, manage, track, and report occupational injuries and illnesses. These measures shall include encouraging worker reporting, classifying and recording cases of occupational injury and illness, providing necessary medical treatment, investigating incidents, implementing corrective actions to eliminate root causes, and establishing provisions that support workers’ return to work.
• Participating companies must allow workers to remove themselves from imminent danger without fear of retaliation and must permit them to stay away from the hazardous situation until it is resolved.

Industrial Hygiene

• The exposure of workers to chemical, biological, and physical agents must be identified, evaluated, and managed according to the hierarchy of controls.
• Where hazards cannot be sufficiently controlled, workers must be provided with appropriate, well-maintained personal protective equipment (PPE) at no cost, and they are required to use it.
• Participating companies must ensure a safe and hygienic working environment for their workers, which they must maintain through ongoing and systematic monitoring of worker health and workplace conditions.
• Participating companies must conduct occupational health monitoring to regularly assess whether workers' health is being adversely impacted by workplace exposure.
• The occupational health protection program must be continuous and include training materials related to the risks of exposure to hazardous conditions within the workplace.

Physically Demanding Work

Hazards related to physically demanding or ergonomically strenuous tasks—such as manual material handling, lifting heavy objects, repetitive lifting, prolonged standing, and force-intensive assembly work—must be identified, assessed, and controlled.

Machine Safeguarding

Production machinery and other equipment must be assessed for safety hazards. Where machinery poses a risk of worker injury, physical safeguards—such as guards, interlocks, and barriers—must be installed and properly maintained.

Sanitation, Food, and Housing

• Workers must be provided with clean restroom facilities, access to potable water, and sanitary facilities for the preparation, storage, and consumption of food.
• Worker dormitories provided by participating companies or labor agencies must be maintained in a clean and safe condition. They must have appropriate emergency exits, hot water for bathing and showering, adequate lighting, proper ventilation and climate control, secure individual storage for personal belongings and valuables, and a personal living space of reasonable size that allows free and safe movement.

Health and Safety Communication

• Participating companies must provide occupational health and safety information and training to workers in their native language or a language they understand. This training must cover all potential workplace hazards they might encounter, including machinery, electrical hazards, chemicals, fire, and physical dangers.
• Health and safety information must be clearly posted within the facility or displayed in locations where workers can easily see and access it.
• Health-related information and training should include, where applicable, risks specific to relevant characteristics such as gender or age. Training must be provided to all workers prior to the start of work duties and thereafter on a regular basis.
• Workers are encouraged to raise health and safety concerns without fear of retaliation.

03Environment

Participating companies acknowledge that environmental responsibility is essential to producing world-class products. They are obligated to identify their environmental impacts and actively work to minimize adverse effects on local communities, the environment, and natural resources, all while ensuring public health and safety.

Environmental Standards

Environmental Permits and Reporting

All necessary environmental permits (e.g., emissions monitoring), approvals, and registrations are to be obtained, maintained, kept current, and operated in accordance with all relevant operational and reporting requirements.

Pollution Prevention and Resource Conservation

• Emissions and releases of pollutants, as well as the generation of waste, shall be minimized or eliminated at the source, or through the implementation of measures such as the installation of pollution prevention equipment, improvements to production, maintenance, and equipment-related processes, and other appropriate means.
• The utilization of natural resources—including water, fossil fuels, minerals, and products derived from primary forests—shall be minimized through practices such as process modifications in production, maintenance, and facilities, substitution of materials, reuse, conservation, recycling, and other applicable measures.

Hazardous Substances

• Hazardous chemicals, wastes, and other substances that can threaten human health or the environment must be identified, labeled, and managed to ensure their safe handling, transport, storage, use, recycling or reuse, and disposal.
• Hazardous waste data must be recorded and monitored.

Solid Waste

Participating companies must implement a systematic approach to identify, manage, and reduce solid waste (excluding hazardous waste), and to ensure its responsible disposal or recycling. Waste-related data must be recorded and monitored.

Air Emissions

• Volatile organic compounds, aerosols, corrosive substances, particulates, ozone-depleting substances, and combustion byproducts generated from operations must undergo appropriate characterization, routine monitoring, control, and treatment prior to release into the atmosphere.
• Ozone-depleting substances must be effectively managed in accordance with the Montreal Protocol and all applicable regulations.
• Participating companies are required to conduct regular monitoring of the performance of their air emissions management systems.

Material Restrictions

Participating companies must comply with all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in products and manufacturing processes, including requirements related to recycling and waste labeling.

Water Management

• Participating companies must document, characterize, and monitor water sources, water usage, and water discharges. They must also implement water management practices that identify conservation opportunities and control contamination pathways.
• All wastewater must be characterized, monitored, controlled, and treated as required before discharge or disposal.
• Participating companies must regularly monitor the performance of wastewater treatment and containment systems to ensure optimal operation and compliance with regulations.

Energy Consumption and Greenhouse Gas Emissions

• Participating companies must establish and report company-wide greenhouse gas (GHG) reduction targets.
• Energy consumption and GHG emissions across all Scope 1 and Scope 2 categories, as well as all material Scope 3 categories, must be recorded and monitored.
• Participating companies must pursue methods to enhance energy efficiency and to minimize energy consumption and GHG emissions.

Conservation of Biodiversity and Ecosystems

Participating companies must recognize the impacts of their operations on ecosystems and biodiversity, and implement appropriate measures to prevent, reduce, or otherwise mitigate those impacts.

04Ethics

To fulfill social responsibilities and achieve market success, participating companies and their subcontractors must uphold high standards of ethical conduct, including, but not limited to, the following:

Standards of Ethical Conduct

Business Integrity

• All business interactions must uphold the highest standards of integrity.
• Participating companies are required to adhere strictly to a zero tolerance policy concerning all forms of bribery, corruption, extortion, and embezzlement.

No Improper Advantage

• No promises, offers, permits, provides, or accepts bribes or other improper or inappropriate benefits. These prohibitions include accepting, directly or indirectly through a third party, to obtain or maintain transactions or to gain other improper benefits.
• Participating companies must establish procedures for monitoring, record keeping, and implementation to ensure compliance with applicable anti-corruption laws.

Disclosure of Information

• All business transactions must be conducted transparently and accurately documented in the accounting books and records of the participating companies. Information regarding the participating companies' labor practices, health and safety activities, environmental activities, business operations, organizational structure, financial condition, and performance must be disclosed in accordance with applicable regulations and general industry practices.
• Falsification of records or misrepresentation of conditions or practices within the supply chain is strictly prohibited.

Intellectual Property

Intellectual property rights must be protected and respected. Transfers of technology and know-how must be conducted in a manner that protects intellectual property rights, and information belonging to customers and suppliers must be safeguarded.

Fair Business, Advertising and Competition

Companies must maintain standards of fair business practices, advertising, and competition.

Protection of Identity and Non-Retaliation

• Programs must be maintained to ensure the confidentiality, anonymity, and protection of suppliers and employees who report concerns, except where prohibited by law.
• Participating companies should establish communication processes that enable employees to raise concerns without fearing retaliation.

Responsible Sourcing of Minerals

• Participating companies must implement policies and conduct due diligence to reasonably ensure that the tantalum, tin, tungsten, gold, and cobalt in their products are sourced according to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equally recognized due diligence framework.
• They are also required to disclose the methods and results of these investigations when requested by the customer.

Privacy

• Participating companies must ensure that reasonable measures to safeguard the personal information of all parties with whom they engage in business activities, including suppliers, customers, consumers, and employees.
• Participating companies must adhere to relevant laws and regulations concerning data protection and information security when collecting, storing, processing, transferring, or sharing personal information.

05Management Systems

Management System Standards

Company Commitment

Participating companies shall establish policies on human rights, health and safety, the environment, and ethics—approved by executive management—that affirm the company’s commitment to due diligence and continuous improvement, and shall document and communicate these policies in languages understood by their workers.

Management Accountability and Responsibility

Participating companies shall designate senior management and responsible company personnel accountable for the effective implementation of the management system and associated programs. Senior management shall conduct periodic reviews of the management system to evaluate its status and performance.

Legal and Customer Requirements

Supporting companies must establish or implement processes to identify, monitor, and recognize applicable legal and customer requirements, including those outlined in this code of conduct.

Risk Assessment and Risk Management

• Participating companies must establish or implement processes for the identification of risks associated with legal compliance, environmental health and safety, labor practices, and ethical conduct. This includes risks that could have significant impacts on human rights and the environment.
• To manage identified risks and ensure regulatory compliance, participating companies must assess the relative significance of each risk and implement appropriate procedural and physical controls.
• Areas that require environmental, health, and safety risk assessments include production operations, warehouses and storage facilities, plant and facility support equipment, laboratories and testing areas, sanitation facilities (such as restrooms), kitchens, and worker housing or dormitories.

Improvement Objectives

Participating companies must establish documented performance objectives, targets, and implementation plans to enhance social, environmental, and health and safety outcomes. They should also regularly evaluate their performance to confirm these objectives are achieved.

Training

Participating companies must establish training programs for both managers and workers to support the effective execution of corporate policies, procedures, and improvement objectives, and to ensure compliance with applicable legal requirements.

Communication

Participating companies must establish processes that effectively communicate clear and accurate information about corporate policies, programs, expectations, and performance to workers, suppliers, and customers.

Worker/Stakeholder Engagement and Access To Remedy

• Participating companies must establish processes for ongoing, two-way communication with workers, their representatives, and other relevant or necessary stakeholders.
• These processes must be designed to obtain feedback on the practices and conditions outlined in this Code and to encourage continuous improvement.
• Workers must be provided with a secure environment in which they can raise grievances and give feedback without fear of retaliation or reprisal.

Audits and Assessments

Participating companies must conduct periodic self-assessments to ensure compliance with legal requirements, the provisions of this Code, and customer contractual requirements related to social and environmental responsibility.

Corrective Action Process

Participating companies must establish processes to ensure the prompt remediation of non-conformities identified through internal or external assessments, inspections, investigations, or audits.

Documentation and Records

Participating companies are required to establish and maintain comprehensive documentation and records to demonstrate compliance with all regulatory requirements, adhere to internal standards, and ensure the safeguarding of privacy through appropriate confidentiality measures.

Supplier Responsibility

Participating companies must establish processes to ensure that the requirements of this Code are communicated to suppliers and that supplier adherence to the Code is effectively monitored.