Responsible Supply Chain | ESG | Lam Research

Responsible Supply Chain

We leverage our global reach to promote ESG progress beyond Lam’s operations.

At Lam, propelling technology forward goes hand in hand with cultivating a responsible supply chain that reflects our Core Values. We hold ourselves and our suppliers accountable for conducting business responsibly and ethically with regard to human rights, environmental impact, supplier diversity, and mineral sourcing. This work is integral to our overall business strategy—making Lam’s entire value chain more competitive and resilient.

Focus areas

to advance
climate action

To achieve net zero emissions, we are engaging our suppliers to accelerate climate progress.

human rights

We believe in the protection and respect of global human rights and are committed to upholding high standards of conduct within our supply chain and operations.

Ethically sourcing
raw materials

We exercise due diligence with our suppliers to promote the responsible and ethical sourcing of raw materials, including conflict minerals such as cobalt and mica.

Fostering supply
chain diversity

By building strong relationships with small and diverse suppliers, we provide best-in-class products and services to our customers while benefiting local communities.

Our comprehensive approach

Our supply chain spans six continents and 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 each step of 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.

Embedding ESG across our supply chain

We manage and monitor ESG performance throughout our supply chain with a strategic framework built on five pillars:





Risk Assessment
and Audit

Supply chain governance and management

Our Supply Chain ESG team leads our supplier compliance and risk assessment efforts while driving continuous supply chain improvement. We also maintain a cross-functional Supply Chain Committee comprised of representatives from several of Lam’s teams:

• Direct and Indirect Supply Chain
• Environmental, Health, & Safety
• Ethics & Compliance
• Environmental, Social, and Governance
• Logistics

The Supply Chain Committee meets regularly to identify opportunities for responsible supply chain initiatives. The committee also develops plans for these initiatives and provides input on their implementation.

Evaluating suppliers and ensuring compliance


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 and complete an annual self-assessment questionnaire (SAQ) through RBA’s platform. We use a risk-based approach to conduct due diligence assessments on our highest-risk suppliers—a process that may involve audit reports, inspections, and corrective actions as needed.

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 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 through asking questions, expressing concerns, making disclosures or filing reports through channels including the EthicsPoint Helpline.

Collaborating to advance climate action

Lam is dedicated to reducing our company’s value chain emissions, including in our global supply chain.

Our long-term goal is 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 top suppliers (measured by emissions) in establishing science-based targets (SBTs).

Through our supplier engagement platform, we survey our top 100 suppliers (by spend) 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, with many suppliers acknowledging Lam’s Climate Pledge.

Upholding human rights

Lam is committed to upholding human rights within our supply chain and operations.

We are committed to protecting and supporting human rights—both in our supply chain and in our operations around the world. Not only is this a compliance issue; it also aligns with our Core Values such as honesty, integrity, mutual respect, and mutual trust. We expect our suppliers and sites to comply with laws including—but not limited to—the U.K. Modern Slavery Act of 2015 and the California Transparency in Supply Chains Act of 2010.

Lam’s Human Rights Policy applies to all employees and outlines our expectations to uphold internationally recognized human rights. We expect our suppliers, as well as our business and community partners, to adopt similar practices. The policy aligns with the RBA’s Code of Conduct and builds on standards outlined in our GSCC.

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 all suppliers to complete human rights training through the RBA platform and have launched internal training for all Lam employees in global supply chain management.

In 2022, we continued to make progress in human rights due diligence. We created our first human rights policy and began working to enhance our risk assessment process for direct suppliers to address risks relating to labor (e.g., forced labor, human trafficking, child labor, discrimination, etc.). As we continue to lay the foundation for our human rights program in 2023, we started a human rights gap assessment to identify potential human rights risks and gaps that focused on our own employees, women, children, migrant workers, and indirect workers. This assessment included both site risk and corporate risk assessments which were conducted by a third party.

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; 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 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 three 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 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 major 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 product suppliers, employees, and contractors who fail to comply with Lam’s policies are subject to corrective action including termination.

Training: During the last fiscal year, we implemented required 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.

Ethically sourcing raw materials

Raw minerals are the building blocks of semiconductor technology, and we are dedicated to sourcing them responsibly.

Our commitment to upholding 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 working to help address human rights issues in the mining of tin, tantalum, tungsten, gold, and other minerals of concern.

Since 2012, we have used the Conflict Minerals Reporting Template developed by RMI to assess our suppliers. In 2022, we expanded our due diligence efforts to include cobalt and mica, as recommended by RMI.

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 (if any) can be found here.

Fostering supply chain diversity

Fostering a diverse and inclusive supply chain allows us to provide best-in-class products and services to our customers.

We encourage opportunities to work with diverse suppliers that offer goods and services that meet our company’s standards, supplier selection criteria, and customer requirements. These diverse businesses drive economic growth and stability in local communities and help Lam enhance performance by building a more competitive and flexible supply base.

During our supplier onboarding process, we implement measures to identify diverse suppliers, including minority-, women-, LGBTQIA+-, and veteran-owned businesses, as well as businesses owned by people with disabilities. We also include diverse qualifications in our Supplier Scorecard and track and report spending with diverse direct material suppliers on a periodic basis. This data supports our cross-functional approach to continuously enhancing Lam’s supplier diversity.

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, our inclusion and diversity initiatives, and the sustainability of our products and operations. Some factors that may affect these forward-looking statements include: trade regulations, 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 are expected to continue to impact our profitability; supply chain disruptions have limited and are expected to limit our ability to meet demand for our products; the severity, magnitude, and duration of the COVID-19 pandemic (and the related governmental, public health, business, and community responses to it), and its impacts on our business, results of operations, and financial condition, are evolving and are highly uncertain and unpredictable; and widespread outbreaks of illness 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.