Responsible Business, Ethical Operations, and Climate Stewardship

This Code of Conduct establishes the standards for our global operations and supply chain, reflecting our commitment to:

• Ethical and lawful conduct
• Respect for human rights
• Safe and dignified working conditions
• Environmental stewardship
• Responsible mineral sourcing
• Life-cycle climate accountability
• Transparent governance

These principles apply to all employees, officers, directors, contractors, and suppliers worldwide. We expect all business partners to uphold equivalent standards.

This Code of Conduct reflects commercially reasonable and our good-faith efforts and operational objectives. While we strive to implement and uphold these principles across our global operations and supply chain, many aspects of compliance depend on information and actions provided by third parties. Accordingly, this Code represents our best efforts and does not constitute a guarantee of outcomes or create contractual rights for third parties unless expressly agreed in writing elsewhere.

Labor and human rights

We respect internationally recognized human rights and uphold the dignity of every worker.

1. Freely Chosen Employment
   1. No forced, bonded, trafficked, or involuntary labor.
   2. No withholding of identity documents.
   3. Freedom of movement and voluntary employment.
2. Child and Young Labor
   1. No child labor.
   2. Young workers may not perform hazardous work.
3. Working Hours
   1. Compliance with applicable laws.
   2. Overtime must be voluntary and legally compensated.
   3. At least one day off per 7-day period.
4. Wages and Benefits
   1. Compensation meeting or exceeding legal standards.
   2. Timely payment and clear wage statements.
   3. No unlawful deductions.
5. Humane Treatment
   1. Zero tolerance for harassment, abuse, intimidation, or coercion.
   2. Fair and transparent disciplinary policies.
6. Non-Discrimination: Equal employment opportunity regardless of race, religion, gender, nationality, disability, age, or other protected status.
7. Freedom of Association: Workers may lawfully organize and bargain collectively without retaliation.

Health and safety

We maintain safe and healthy workplaces.

1. Occupational Safety
   1. Hazard identification and mitigation.
   2. Preventive maintenance and safety controls.
   3. Provision of appropriate PPE as needed.
2. Emergency Preparedness
   1. Documented emergency response procedures.
   2. Training and drills.
3. Incident Management
   1. Systems to track, investigate, and remediate workplace injuries and illnesses.
   2. Root-cause corrective action processes.
4. Industrial Hygiene and Ergonomics: Control of chemical, physical, and ergonomic risks.
5. Facilities: Safe and sanitary facilities where housing or food services are provided.

Ethical business conduct

We operate with integrity.

1. Anti-Corruption: Zero tolerance for bribery, corruption, or improper payments.
2. Accurate Records: Truthful financial reporting and documentation.
3. Intellectual Property Protection: Respect for company, customer, and third-party IP.
4. Fair Competition: No anti-competitive practices.
5. Data Protection: Protection of confidential and personal information in compliance with applicable laws.

Responsible sourcing of minerals

We are committed to responsible mineral sourcing that does not contribute to armed conflict, human rights abuses, or environmental harm.

1. International Framework Alignment
   We use best efforts to align with:
   • OECD Due Diligence Guidance
   • U.S. Dodd-Frank Section 1502
   • EU Conflict Minerals Regulation
   • Responsible Business Alliance standards
2. Covered Minerals
   At minimum, this policy applies to the following materials commonly used in semiconductors, capacitors, solder, connectors, and electronic components:
   • Tantalum
   • Tin
   • Tungsten
   • Gold
3. Due Diligence Process
   We implement a risk-based process consistent with OECD’s five-step framework:
   • Public responsible minerals policy.
   • Assigned internal accountability.
   • Supplier contractual requirements.
   • Annual supplier surveys.
   • Supplier engagement and corrective action plans.
   • Escalation where risks are not addressed.
   • Transparent reporting consistent with applicable regulations.
4. Zero Tolerance
   We prohibit sourcing that directly or indirectly supports:
   • Armed groups
   • Forced labor
   • Child labor
   • Severe human rights abuses

Where credible risk is identified, we will take responsible and appropriate action.

Environmental responsibility

We are committed to minimizing environmental impact across our operations and products.

1. Compliance: Maintain environmental permits and comply with global environmental regulations (including RoHS, REACH where applicable).
2. Pollution Prevention: Reduce waste, emissions, and resource consumption and promote energy efficiency and responsible material use.
3. Hazardous Materials Management: Proper identification, handling, storage, and disposal.

Climate impact and product life-cycle responsibility

We recognize that hardware manufacturing carries significant climate impact. We commit to measuring and reducing product life-cycle emissions using recognized methodologies. Climate impact measurements and life-cycle assessments involve modeling assumptions, third-party data, and evolving methodologies.

1. Life Cycle Assessment (LCA)
   We conduct assessments that may include:
   1. Raw material extraction
   2. Component manufacturing
   3. Assembly and testing
   4. Packaging
   5. Transportation
   6. Product use phase
   7. Maintenance
   8. End-of-life treatment
2. Product Carbon Footprint (PCF)
   Where possible, we:
   1. Quantify cradle-to-gate or cradle-to-grave emissions.
   2. Use supplier-specific primary data where available.
   3. We assess embodied carbon, manufacturing emissions, and end-of-life impact
3. Supplier Climate Integration (Scope 3)
   We engage with suppliers to:
   • Encourage renewable energy use.
   • Improve manufacturing efficiency.
   • Align with science-based targets where feasible.
4. Design for Climate Performance
   We integrate climate considerations into product engineering:
   • Optimize performance per watt.
   • Reduce idle and peak power draw.
   • Increase product longevity and modularity.
   • Improve recyclability and disassembly.
   • Reduce material intensity and packaging volume.
5. Climate Targets and Continuous Improvement
   We commit to:
   • Improving year-over-year carbon intensity.
   • Increasing renewable energy usage.
   • Enhancing logistics efficiency.
   • Reducing packaging and material waste.
6. Documentation and Verification
   
   • Maintain documented methodologies.
   • Record emissions factors and data sources.
   • Conduct third-party verification where appropriate.
   • Avoid unsubstantiated environmental claims.

Management systems and governance

Responsible business conduct requires structured oversight.

Leadership Accountability
Executive oversight of compliance, climate, and responsible sourcing.

Risk Assessment
Periodic evaluation of operational, supply chain, and climate risks.

Supplier Responsibility
Suppliers must adhere to equivalent standards. Failure to comply may result in corrective action or termination.

Training and Communication
Regular training for employees and suppliers.

Grievance Mechanisms
Confidential reporting channels available. No retaliation for good-faith reporting.

Continuous Improvement
Annual review of policy effectiveness and evolving regulatory expectations.

Reporting and enforcement

Violations of this Code may result in disciplinary action, termination of employment, or discontinuation of business relationships. Reports may be made confidentially through designated compliance channels.

Closing statement

Responsible business practices are fundamental to long-term competitiveness, innovation, and trust. Ethical conduct, responsible sourcing, environmental stewardship, and climate accountability are not optional — they are core operating principles. We are committed to continuous improvement and measurable progress.