Supply Chain Responsibility at Lam
Lam Research collaborates closely with suppliers to meet emerging customer needs and develop more stringent social and environmental requirements, including screening and auditing requirements for human trafficking, child and forced labor, human rights, and workplace safety. Lam is committed to responsible supply chain management practices and addressing these important topics.
Sourcing the specialized components needed for our process equipment and services requires our supply chain to have a global presence. Lam is committed to complying with applicable laws and regulations and contractually requires our direct material suppliers to conduct their business in a manner that complies with applicable laws and regulations. We hold our suppliers to the same Core Values to which we hold ourselves, and partner with them to promote responsible and ethical operations throughout our supply chain. Our supply chain is also held to Lam Research’s Supplier Code of Conduct; it incorporates by reference and requires supplier adherence to the Responsible Business Alliance (RBA) Code of Conduct, which is reviewed regularly and updated with feedback from external stakeholders by the RBA. We work closely with our suppliers to address a wide range of issues through responsible supply chain management, including human rights, supplier diversity, environmental impact, cybersecurity and mineral sourcing.
To ensure we are aware of best practices and contributing to the collective effort to address human rights and conflict minerals, Lam Research participates in the Silicon Valley Conflict Minerals & Human Trafficking Forum.
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. This code is implemented and subject to regular internal review by our Supply Chain Management team. It is communicated to our top direct suppliers through our supplier portal, where it is accessible at any time.
We are committed to an environment where open and honest communications are the expectation. We encourage all individuals throughout our value chain to help us proactively address Ethics and Compliance related issues by asking questions, expressing concerns, making disclosures or filing reports through the Ethics Helpline or other channels. Our grievance platform is accessible on EthicsPoint.
RESPONSIBLE BUSINESS ALLIANCE
Lam Research is an active member of the Responsible Business Alliance (RBA), Responsible Mineral Initiative (RMI), and Responsible Labor Initiative (RLI) and fully supports the vision and goals of the RBA, RMI, and RLI.
Vision: A global electronics industry that creates sustainable value for workers, the environment and business.
Mission: Members, suppliers and stakeholders collaborate to improve working and environmental conditions through leading standards and practices.
Lam Research is committed to complying with the RBA Code of Conduct, progressively implementing the RBA approach and tools in the spirit of the industry’s common goals; and is also committed to progressively applying the RBA Code of Conduct to suppliers and to encouraging and supporting suppliers to do the same.
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.
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.