UK Modern Slavery Act

Financial Year ending 31st December 2020

Kingston Technology Corporation and its sites worldwide (herein collectively referred to as "Kingston") is a US based company which develops memory products and gaming peripherals. Kingston has global manufacturing sites and a worldwide market presence. As such, we are not only obligated, but committed to supporting human rights around the world. We do not tolerate any form of modern slavery which includes forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons by any Kingston supplier or for any other purpose.

Kingston’s commitment to prohibit modern slavery is part of a larger effort of aligning Kingston’s standards to our core values: encourage business integrity and ethical conduct, and supply chain transparency and accountability. We are committed to social and environmental responsibility and to making a strong and positive contribution to the societies and people served by the company and its employees. We are dedicated to delivering products through a business and supply chain that respects human rights and the dignity of labor, adhering to laws that prohibit modern slavery in Kingston’s direct operations or supply chain.

Structure, business, and supply chain

Kingston is a leading manufacturer in DRAM and memory modules, and flash memory products such as SSDs, USBs, SD Cards and readers. Kingston generates revenues primarily from sales of products, OEM services, and contract manufacturing. Our efforts to combat modern slavery require us to be reliant on our strong relationships with our global suppliers that manufacture or provide services on our behalf.

Kingston works with many suppliers worldwide that support our business and operations, including hardware manufacturing and our extended workforce. As such, Kingston takes measures to ensure that our suppliers have established policies and practices to prevent modern slavery practices from developing in their supply chains.

Internal management, accountability, and programs

Kingston’s worldwide employees are dedicated to ensuring ethical practice, including labor and human rights, health and safety of employees and work practices, consideration of environmental impact, and supporting our global communities. Kingston’s top management, corporate executives, and employees work together to prevent any form of modern slavery and continue to explore improvements within our internal programs.

Kingston conducts annual CSR Risk Assessments to assess risk within our own processes and business transactions. The CSR Risk Assessment program is developed around Kingston’s Code of Conduct and RBA standards, as well as federal and local laws by country or region. Any CSR Risk Assessment findings will be addressed accordingly to ensure minimal risk in internal processes. Additionally, Kingston annually conducts CSR Risk Assessments to assess risk within our own processes and business transactions. The CSR Risk Assessment program is developed around Kingston’s Code of Conduct and RBA standards, as well as federal and local laws by country or region. Any CSR Risk Assessment findings will be addressed accordingly to ensure minimal risk in internal processes.

Kingston firmly believes that our responsibility to due diligence includes transparency. Our commitment to corporate social responsibility, including our efforts against modern slavery, can be found in our annual Global Reporting Initiative (GRI) Report. The GRI Report provides detailed information about Kingston as an organization through its financial and operational activities and is published on our website and accessible to the public. Transparently reporting through the GRI platform holds Kingston accountable and demonstrates Kingston’s commitment to prevent modern slavery.

Policies addressing ethical conduct and prevention of modern slavery

Kingston has a Code of Conduct that outlines expectations for Kingston employees and our suppliers alike. The Kingston Code of Conduct sets up policies intended to protect the health, safety and ethical treatment of workers, which prohibits any form of modern slavery. Kingston employees, contractors and suppliers are expected to abide by our Code of Conduct to maintain internal accountability standards and procedures for any parties failing to meet Kingston’s company standards regarding modern slavery. Kingston maintains accountability and grievance mechanisms which are available to both employees and external parties. Kingston will investigate any reports of human trafficking and slavery in its business or supply chain and take appropriate action to remedy any issues it identifies as a result. No such reports have been received during the last financial year.

For additional information, please refer to the Kingston Code of Conduct

Kingston’s commitments to mitigate Modern Slavery through due diligence and supplier management

One of the ways Kingston has exercised its due diligence has been through our continued membership with the Responsible Business Alliance (RBA). As a member of RBA, we are committed to progressively aligning our own policies and operations with the provisions of the RBA Code of Conduct and to support and encourage our suppliers and sub-contractors to do the same. RBA membership requires, among other things, that members take a firm stance against modern slavery.

RBA membership includes not only Kingston’s plausibility of being audited by other RBA participants, but the ability to request RBA Audits of our suppliers. RBA audits are conducted to assess suppliers’ policies and practices with regards to modern slavery risks and controls, and their management and oversight of their own suppliers. RBA Audits are completed by RBA-certified third-party entities.

In 2020, due to the COVID-19 pandemic, Kingston was not able to conduct in-person Supplier Audits as planned due to travel bans. As it is becoming safer and more accessible to conduct in-person audits, we have developed an audit plan for 2021 which incorporate on-site in-person audits, as well as document review and re-engagement of the supplier under Kingston’s Code of Conduct agreement. Kingston Supplier Audits aid in the improvement of our supply chain’s awareness and efforts to reduce risks of modern slavery. Supplier Audits are conducted by Kingston using RBA audit guidelines and follow the RBA’s structure for corrective action and follow-up. Follow-up audits are conducted to address any corrective action and to help to keep suppliers accountable and ensure continual improvement in their operations to help combat modern slavery.

Additionally to in-person supplier audits, Kingston asks our suppliers to complete self-assessment questionnaires (SAQ) about their working conditions and CSR program. SAQs allow us to identify labor-related red flags that may impact our decision to continue or alter a current relationship with a supplier.

In addition to the measures described above, we have established and maintained a Conflict Minerals Program as part of our commitment to help end modern slavery. Kingston is a member of the Responsible Minerals Initiative (RMI), which has a variety of programs addressing modern slavery and child labor. Being a member of the RMI allows Kingston to manage and maintain a supply chain that does not harvest precious minerals (currently tin, tungsten, tantalum, gold and cobalt) from mines that finance modern slavery and child labor.

Training

Kingston is continuing to develop and implement CSR training at each of its regional sites. This training includes Kingston’s Code of Conduct, which reinforces the expectation that our employees, extended workforce, and suppliers follow applicable laws and report concerns of illegal or unethical activity.

Top management, corporate executives, and employees who have direct responsibility for supply chain management at our major manufacturing facilities receive training on a regular basis on the elements of the UK Modern Slavery Act to help them identify warning signs for modern slavery within the supply chain. We are currently working to further refine this training program to be applied across our global sites.

Assessing and Reporting on Effectiveness

As previously mentioned, Kingston schedules RBA audits, as well as conducting our own audits of suppliers and their facilities. These audits include in-depth facility tours, meetings with management, on-site worker interviews, document reviews, and assessments of related areas such as dormitories, cafeterias, wastewater treatment facilities, and warehouses. The audit protocol is designed to assess suppliers’ performance in areas covered by our Code of Conduct, including modern slavery risk.

As mentioned above, both RBA and Kingston audit findings are closely followed up on to ensure effectiveness of corrective actions.

Kingston recognizes the limitations of audits. As such, in 2018, Kingston conducted a materiality assessment of Kingston employees worldwide to engage them and get a better understanding of where their knowledge and recognition of modern slavery lies. Kingston plans to implement a materiality assessment in 2021 to reflect a wider range of Kingston’s internal and external stakeholders and gather data to assess how we can continue to combat modern slavery and minimize it within Kingston’s supply chain.

Additionally, Kingston sends our Code of Conduct and acknowledgment letters to direct suppliers to certify that materials incorporated into Kingston products comply with the laws regarding modern slavery of the country or countries in which they are doing business.

Reporting Concerns or Raising Issues Related to Modern Slavery

Each of Kingston’s regional sites have an active whistle-blower policy which offers reporting options to employees and extended workers. . Reporting tools are made accessible in multiple languages as an option to report concerns anonymously, and is promoted through internal policies, communications, and trainings, and also extended to suppliers alike through our Kingston’s Code of Conduct. Our Code of Conduct also prohibits retaliation for raising concerns.

If any concerns about modern slavery are raised through our reporting channels, Kingston coordinates with appropriate stakeholders to investigate and address the issue. As previously noted, actions taken could potentially reduce or suspend business with the supplier, or, terminate business with the supplier altogether. Any internal reports may result in appropriate disciplinary actions or termination of employment.

Approvals

This UK Modern Slavery Statement was approved by the Vice President of Administration of Kingston Technology Corporation and is endorsed by the Members of Kingston Technology Europe Co LLP and Kingston Digital Europe Co LLP.

This statement is made pursuant to the requirements of the UK Modern Slavery Act and also serves to fulfill the requirements of The California Transparency in Supply Chains Act (SB 657) and Australia Modern Slavery Act.

Vice President of Administration
Lawrence Gonzales signature
Lawrence Gonzales
Dated: 06/8/2021

Previous annual statements

2020

2019

2018

2017

For information about how COVID-19 has affected our business operations, click here.