Our suppliers are integral to Lam’s ability to continue helping our customers innovate for the future.
At Lam, propelling technology forward goes hand in hand with cultivating a responsible supply chain that supports our business, as well as our values and social and environmental ambitions. We aspire to hold ourselves and our suppliers accountable for conducting business responsibly and ethically. This is integral to our overall business strategy—making Lam’s value chain more competitive and resilient.
Focus areas
Collaborating
to advance
climate action
Achieving our net zero goal requires collaboration across our value chain, especially with our suppliers on our Scope 3 emissions, which are outside of our direct control.
Upholding
human rights
We strive to support and protect human rights throughout our global operations, including within our supply chain.
Ethically sourcing
raw materials
We exercise due diligence with our suppliers to promote the responsible and ethical sourcing of raw materials, including conflict minerals, and materials.
Our comprehensive approach
Our supply chain spans more than two dozen countries.
It’s a complex network that requires strong oversight and governance to manage. Our approach is to engage closely with suppliers throughout the supplier lifecycle, from pre-selection to onboarding and beyond. We aspire to cultivate strong supplier relationships built on shared values, transparency, and mutual trust.
Responsible supply chain management
Supply chain management
Strategic pillars
- Transparency
- Responsibility
- Training
- Risk assessments
- Governance
Focus areas
- Collaborating to advance climate action
- Upholding human rights
- Ethically sourcing materials
Supply chain governance and management
Our global supply chain executive leadership oversees responsible supply chain governance, while a dedicated program management team implements our efforts with support from a global, cross-functional team. We are a member of the RBA, a relationship that underpins our responsible supply chain program.
For Lam, effective supply chain management allows us to:
- Lay the foundation for a productive supplier relationship. We communicate our expectations, collect data to inform our strategy, and foster collaboration and build momentum toward our respective goals.
- Build capacity for progress. We mature our methodology and enhance data accuracy; identify potential emissions-reduction opportunities and human rights risks; and provide resources, training, and coaching opportunities.
- Act on opportunities to drive measurable improvements. We reduce value chain emissions, hold suppliers accountable, and measure our impact and adjust our strategy as needed.
Our supplier engagement approach
Lam engages with suppliers throughout our relationship. We use country-level risk data to inform our overall supplier engagement and assessment strategy.
Pre-contract
Before contracting with a supplier, Lam conducts due diligence using a risk‑based approach.
Onboarding
We require newly contracted suppliers to:
- Acknowledge and agree to adhere to the principles set forth in our GSCC, which is based on the RBA’s COC, the UN Guiding Principles on Business and Human Rights, the UN Global Compact, and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.
- Complete a screening and onboarding process to assess and mitigate human rights and business ethics risks.
- Complete sanctions, trade, and other list-based screening.
Expectations of top suppliers1
- Set science-based targets (SBTs) in line with Science Based Targets initiative methodology.
- Respond to our annual environmental survey, providing emissions and environmental data.
- Respond to our annual Conflict Minerals Reporting Template (CMRT) survey request.
- Complete Corporate self-assessment questionnaires (SAQs) and Responsible Labor SAQs,2 and provide Validated Assessment Program (VAP) audit reports.
Ongoing validation
We assess suppliers’ ongoing compliance with our GSCC and the RBA COC, as well as their progress toward goals, using:
- RBA’s online toolkit, including training modules, Corporate SAQs, Facility Risk SAQs, Responsible Labor SAQs, VAP, and country risk profiles to support human rights risk monitoring; SAQs cover labor, ethics, health and safety, environmental stewardship, and management systems
- The Responsible Mineral Initiative’s (RMI’s) CMRT, Extended Minerals Reporting Template, and Reasonable Country of Origin Inquiry data for supplier conflict mineral monitoring
- Incorporation of human rights risk identification as part of our Quality Management System (QMS) audits
- Lam supplier scorecards, which monitor supplier performance across many metrics
The multi-faceted monitoring process may include requests for action plans to improve policies and practices, and closure audits to ensure that suppliers have implemented those improvements.
Ongoing engagement
- Continued risk-based due diligence
- Webinars, events, and training opportunities
- Access to Lam resources regarding our net zero roadmap and other global impact initiatives, as well as subject matter experts
- Energy audits for select suppliers
We’re an active member of the Responsible Business Alliance (RBA), and support its vision and mission. Beginning with supplier pre-selection and onboarding, we require that every supplier adheres to our Global Supplier Code of Conduct, the RBA Code of Conduct, and all applicable laws and regulations. We also encourage them to become RBA members.
Global Supplier Code of Conduct
Lam Research
Our proven delivery performance is achieved with ethical supplier management and business operations. Every Lam direct material supplier is contractually obligated to comply with our Global Supplier Code of Conduct, which is communicated through the MyLam® portal, and is subject to regular internal reviews by our Supply Chain Management team. In addition, the Global Supplier Code of Conduct is translated into several languages and posted on our website.
Ethics helpline
Open and honest communication is one of our Core Values and is our standard practice. We encourage our employees, suppliers, and other non-Lam employees to help us proactively recognize Ethics and Compliance related issues by asking questions, expressing concerns, making disclosures, or filing reports through channels including the EthicsPoint Helpline.
Collaborating to advance climate action
Lam strives to reduce our company’s value chain emissions, including in our global supply chain.
We aim to achieve net zero emissions by 2050. Driven by this goal, we are collaborating closely with our suppliers to reduce Lam’s Scope 3 (and, therefore, our suppliers’ Scope 1) emissions. By 2025, we aim to support 46.5% of our suppliers (measured by emissions) in establishing science-based targets (SBTs).
Through our supplier engagement platform, we survey our top 100 suppliers1 on categories including their GHG emissions, CDP scores, environmental goals, ISO 14001 certification, and RBA membership status. This data has enabled us to create a baseline for our suppliers’ performance in these areas.
Upholding human rights
Lam strives to protect and respect human rights within our supply chain and operations.
Every individual deserves safe working conditions and to be treated with dignity and respect. We strive to support and protect human rights throughout our global operations, including within our supply chain. This work aligns with our Core Values, our Global Supplier Code of Conduct (GSCC), and our Human Rights Policy, and it supports our commitments to our customers.
Lam’s global Human Rights Policy applies to all employees. Our GSCC reflects the policy’s principles, and we expect our suppliers, as well as our business and community partners, to adhere to them. We also expect our suppliers and their sites to comply with laws that include, but are not limited to, the U.K. Modern Slavery Act of 2015 and the California Transparency in Supply Chains Act of 2010.
Our human rights management process is informed by the RBA, making use of suppliers’ SAQs and their participation in the VAP audits to drive continuous improvement. In addition to helping us check compliance with our GSCC and the RBA COC, SAQs and review of VAPs ensure our suppliers are mitigating potential human rights risks. The management process also helps us meet our customers’ expectations for supply chain human rights. Our Global Employment Practices Statement declares our support of workers’ rights to freedom of association and collective bargaining, to the extent permitted under local laws. We also align with the RBA’s Responsible Labor Initiative, which is focused on ensuring that the rights of workers vulnerable to forced labor in global supply chains are consistently respected and promoted. We ask our top suppliers to complete human rights training through the RBA platform and have launched internal training for certain Lam employees in global supply chain management.
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 Global Supplier Code of Conduct; and the Responsible Business Alliance’s Code of Conduct, Responsible Business Alliance (“RBA Code”), effective January 1, 2021. To verify compliance with its global supply chain standards, Lam Research:
Verification: In order to verify prospective direct product suppliers, we require 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 three below). The verification is conducted by Lam Research’s Global Supply Chain Management Contracts and Compliance Manager.
Auditing: We periodically audit top direct product supplier operations to address the risks of human trafficking and slavery in our supply chain. The audit is conducted by our Internal Audit Team, 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 top direct product suppliers that the materials incorporated into their products comply with all 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 suppliers, employees, and contractors who fail to comply with Lam’s policies are subject to corrective action including termination.
Training: We require annual training for front-line employees and managers with direct responsibility for supply chain management. Participants learn how to conduct onsite audits, and identify and mitigate risks of human trafficking and slavery.
Raw material due diligence
Raw minerals are the building blocks of semiconductor technology.
Our aspiration to uphold global human rights extends to our strategy for responsibly and ethically sourcing raw materials. This strategy includes our membership in the RBA’s Responsible Mineral Initiative (RMI), a multi-stakeholder organization that helps address human rights issues in the mining of conflict minerals and other minerals of concern. We leverage RMI’s Conflict Minerals Reporting Template to collect data from our suppliers, and we then include that data in our annual filings to the U.S. Securities and Exchange Commission.
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 the Congo (DRC) 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 can be found on our SEC Filings page.
Caution regarding forward-looking statements
Statements made on our Company webpage that are not of historical fact are forward-looking statements and are subject to the safe harbor provisions created by the Private Securities Litigation Reform Act of 1995. Such forward-looking statements relate to, but are not limited to: our goal to be net zero by 2050, our ESG strategy and related goals, our renewable electricity goals, our continued commitment to business integrity, the strength and effectiveness of our ethics and compliance framework, our environmental footprint, sustainability in our industry, our social impacts, and the sustainability of our products and operations. Some factors that may affect these forward-looking statements include: trade regulations and tariffs, export controls, trade disputes, and other geopolitical tensions may inhibit our ability to sell our products; business, political and/or regulatory conditions in the consumer electronics industry, the semiconductor industry and the overall economy may deteriorate or change; the actions of our customers and competitors may be inconsistent with our expectations; supply chain cost increases and other inflationary pressures have impacted and may continue to impact our profitability; supply chain disruptions or manufacturing capacity constraints may limit our ability to manufacture and sell our products; and natural and human-caused disasters, disease outbreaks, war, terrorism, political or governmental unrest or instability, or other events beyond our control may impact our operations and revenue in affected areas; as well as the other risks and uncertainties that are described in the documents filed or furnished by us with the Securities and Exchange Commission, including specifically the Risk Factors described in our most recent annual report on Form 10-K and our quarterly report on Form 10-Q. These uncertainties and changes could materially affect the forward-looking statements and cause actual results to vary from expectations in a material way. The Company undertakes no obligation to update any forward-looking statements.
Additionally, while we leverage various frameworks and other standards in our disclosures, such standards are ultimately only used to inform our disclosures and we cannot guarantee (and no language of “alignment” or similar should be understood to mean) complete adherence to such standards or any particular stakeholders’ interpretation of same. Our disclosures based on standards may change due to revisions in framework requirements, availability or quality of information, changes in our business or applicable governmental policies, or other factors, which may be within or outside of our control. Similarly, some of the information in this Report is reliant on third-party information or methodologies. Any inaccuracies or changes in such information or methodologies, whether within or outside of our control, could cause results and performance to differ from what is reported. In addition, various aspects of this report are based on processes and procedures that we believe apply appropriate levels of support to address issues in scope and, while these statements may use words such as “ensure”, “prevent”, or similar language, such terms should not be considered to mean (as there can be no guarantee) that such efforts will be successful in all situations.
Separately, certain information included in this Report may be used for compliance with various legal obligations; however, this Report is necessarily broader than certain legal requirements, and any such use shall not be deemed to incorporate portions of this Report that are not responsive to such obligations or references to same. It is not intended, and we hereby disclaim, any legal relations, rights or obligations to any third-party in connection with these disclosures. Moreover, by providing this information, neither we nor any of our affiliates are conceding any specific item is required or applicable under any legal obligation, nor are we conceding any particular interpretation of such legal requirements. Moreover, in certain circumstances, information included in this Report may differ from information included in regulatory reporting due to differences in methodologies for the calculation of certain metrics or other factors, which may be within or outside of our control.
- Top suppliers are defined as the top 100 direct suppliers, which account for approximately 91% of direct spend and 90% of direct supplier emissions, with some variability year-over-year. Direct suppliers are defined as those who provide parts, assemblies, and services to produce parts used to manufacture and support Lam’s products. Indirect suppliers are all other goods and services used in Lam’s daily operations that are not parts, assemblies, or services directly tied to producing parts used to manufacture or support Lam’s products.
- Pertains only to our top 36 direct suppliers, who account for approximately 85% of spend.