Commitment to Supply Chain Diversity
Lam Research values a diverse and inclusive supply chain and is committed to selecting diverse suppliers who offer goods and services that meet our company’s standards, supplier selection criteria, and customer requirements. Our focus is to select partners that help us provide best-in-class products and services at the leading edge and throughout the technology lifecycle with the lowest total cost to our customers.
Supplier Code of Conduct
Lam is committed to conducting ethical supply chain management and business operations,and we require our suppliers to conduct their operations in a manner that complies with our Supplier Code of Conduct.
Lam Research Global California Transparency in Supply Chains Act of 2010 Compliance Statement
Lam Research Corporation is committed to compliance with applicable laws and regulations, including the prevention of slavery and human trafficking under the Lam Research Global California Transparency in Supply Chains Act of 2010 (SB 657) Compliance Statement, in its business operations. Lam Research contractually requires direct product suppliers to conduct their operations in a manner that complies with all applicable laws and regulations. Lam Research also requires direct product suppliers to comply with Lam Research’s Supplier Code of Conduct; the Principles And Standards Of Ethical Supply Management Conduct With Guidelines (“ISM Principles”), Institute for Supply Management, 2016; and the Responsible Business Alliance’s Code of Conduct, Responsible Business Alliance (“RBA Code”), effective January 1, 2018. To verify compliance with its global supply chain standards, Lam Research:
- Verification: In order to verify prospective direct product suppliers, we require all new direct materials suppliers, as part of the supplier screening process, to provide a completed written certification that addresses risks of human trafficking and slavery (described in paragraph 3 below). The verification is conducted by Lam Research’s Global Supply Chain Management Contracts and Compliance Manager.
- Auditing: We periodically audit major direct product supplier operations, including to address the risks of human trafficking and slavery in our supply chain. The audit is conducted by Lam Research employees, directly or in conjunction with third parties. During the last fiscal year, audits were announced, but we reserve the right to conduct unannounced audits.
- Certification: We request a written certification from major direct product suppliers that the materials incorporated into their products comply with applicable laws and regulations, including laws regarding slavery and human trafficking of the country or countries in which they are doing business.
- Internal Accountability: Lam direct product suppliers, employees, and contractors who fail to comply with Lam’s policies are subject to corrective action up to and including termination.
- Training: During the last fiscal year, we implemented required annual training of front-line employees and managers with direct responsibility for supply chain management and onsite audits on how to identify and mitigate risks of human trafficking and slavery.
Conflict Minerals Policy Statement
In order to address growing international concern over the violence and human rights abuses that are being fueled by mining operations controlled by armed militias in the Democratic Republic of Congo and neighboring countries (collectively, the “Covered Countries”), the United States has adopted legislation under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) pertaining to certain “conflict minerals”, including tin, tantalum, tungsten, and gold (and their derivatives). The Act, as implemented by the U.S. Securities and Exchange Commission’s final rules (the “Final Rules”), requires certain public companies whose products contain these “conflict minerals” to make annual disclosures and conduct reasonable due diligence on their supply chains to determine the sources of such conflict minerals.
Lam Research fully supports the intent of Section 1502 of the Act. Lam has a complex supply chain and relies heavily on its partnerships with suppliers to purchase certain products or components from around the world that may include conflict minerals. Like many other companies in the electronics industry, Lam does not directly purchase the conflict minerals contained in its products or have any direct relationship with the mines or smelters that process them. As a result, we have been working closely with our suppliers since late 2012 to determine the sources of any conflict minerals that are contained in our products. Lam takes corporate responsibility seriously, and it is our goal to use in our products only conflict minerals that are sourced responsibly, including any conflict minerals that may be sourced from the Covered Countries.
In support of this policy, Lam Research:
- Complies with its reporting obligations under Section 1502 of the Act, as implemented by the Final Rules;
- Exercises due diligence with suppliers consistent with the framework provided by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas;
- Communicates Lam’s expectations for conflict free materials sourcing to suppliers;
Partners with suppliers to provide due diligence information that will assist in responsible sourcing decisions and supply chain transparency;
- Continues to monitor and work with customers, suppliers, and industry groups to collaborate on industry-wide solutions that enable companies to make easier transitions towards sourcing conflict minerals that are “DRC conflict free” (as defined in the Final Rules) in the future
Lam’s Form SD filing and relevant Conflict Minerals Reports (if any) can be found at here.