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Kingston Supplier Code of Conduct

Kingston Technology Company, Inc. and its sites worldwide (hereinafter collectively referred to as “Kingston”) are committed to adopting a code of Corporate Social Responsibility. This Code is established in order to ensure that working conditions in our organization are safe and that business operations are environmentally responsible. Kingston believes that by adopting and incorporating this Code into our business operations we can promote and maintain integrity in all areas of our business. In keeping with the policies set forth by this Corporate Social Responsibility Code, Kingston expects its supplier to comply with this Code, which sets forth standards concerning protection of the environment, relationship with society, ethical practices, data privacy, product quality and safety, health and safety of its employees and management system. These standards are one of many factors that Kingston uses in selecting its suppliers.

Suppliers should have a system in place to ensure compliance with the standards outlined in this Code, as well as all applicable laws and regulations. If there are violations of this Code, it may cause Kingston to terminate its business with such supplier. Suppliers should cooperate with Kingston’s assessment of performance against this Code in due course.

A. LABOR

The labor standards are:

  1. Freely Chosen Employment

    Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not be used. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment agreement in the applicable language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to employees’ identity or immigration documents, such as government-issued identification, passports or work permits, unless the holding of work permits is required by law. Workers shall not be required to pay employer’s or agents’ recruitment fees or other aggregate fees. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker.

  2. Young Workers

    Child labor will not be used at any stage of manufacturing. The term “child” refers to any person employed under the age of 15, under the age for completing compulsory education or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Suppliers shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Suppliers shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.

  3. Working Hours

    Working hours are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or exempt situations. Workers shall be allowed at least one day off every seven days

  4. Wages and Benefits

    Compensation paid to workers should comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Any disciplinary wage deductions are to conform to local law. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

  5. Humane Treatment

    There should be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse of workers or threats of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.

  6. Non-Discrimination

    Suppliers should be committed to a workforce free of harassment and unlawful discrimination. Suppliers shall not engage in discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards and access to training. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

  7. Freedom of Association

    In conformance with local law, participants shall respect the rights of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

B. HEALTH and SAFETY

The health and safety standards are:

  1. Occupational Safety

    Worker potential for exposure to safety hazards (e.g., chemical, electrical and other energy sources, fire, vehicles, and fall hazards) are to be identified and assessed, and controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment and educational materials about risks to them associated with these hazards. Reasonable steps must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments, as well as include reasonable accommodations for nursing mothers.

  2. Emergency Preparedness

    Potential emergency situations and events are to be identified and assessed and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, worker notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, clear and unobstructed egress adequate exit facilities, and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the environment and property.

  3. Occupational Injury and Illness

    Procedures and systems are to be in place to manage, track, and report occupational injury and illness, including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.

  4. Industrial Hygiene

    Worker exposure to chemical, biological and physical agents is to be identified, evaluated and controlled according to the hierarchy of controls. Potential hazards are to be eliminated or controlled through proper design, engineering and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment. Protective programs shall include educational materials about the risks associated with these hazards.

  5. Physically Demanding Work

    Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks are to be identified, evaluated, and controlled.

  6. Machine Safeguarding

    Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers will be provided and properly maintained for machinery used by workers.

  7. Sanitation, Food, and Housing

    Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Supplier or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

  8. Health and Safety Communication

    Suppliers shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical hazards.. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise safety concerns.

C. ENVIRONMENTAL

Suppliers must comply with all applicable environmental laws, regulations and standards and recognize the adverse effects on the environment when conducting business. The minimum standards to protect the environment are outlined as follows:

  1. Environmental Permits and Reporting

    All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained and kept current and their operational and reporting requirements are to be followed.

  2. Pollution Prevention and Resource Reduction

    Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding pollution control equipment; modifying production, maintenance and facility processes; or by other means. The use of natural resources, including water, fossil fuels, minerals and virgin forest products, is to be conserved or by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means.

  3. Hazardous Substances

    Chemicals and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal.

  4. Solid Waste

    Supplier shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).

  5. Air Emissions

    Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge. Participant shall conduct routine monitoring of the performance of its air emission control systems..

  6. Materials Restrictions

    Suppliers are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal. Kingston has established a Hazardous Substances Management Program through which all requirements and regulations are defined. Suppliers shall follow it.

  7. Water Management

    Suppliers shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination. All wastewater is to be characterized, monitored, controlled, and treated as required prior to discharge or disposal. Participant shall conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

  8. Energy Consumption and Greenhouse Gas Emissions

    Energy consumption and greenhouse gas emissions are to be tracked and documented, at the facility and/or corporate level. Suppliers are to look for cost-effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

D. ETHICS

To meet social responsibilities in business transactions, Suppliers will uphold the highest standards of ethics including:

  1. Business Integrity

    The highest standards of integrity are to be upheld in all business interactions. Suppliers shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement. All business dealings should be transparently performed and accurately reflected on Supplier’s business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

  2. No Improper Advantage

    Bribes or other means of obtaining an improper advantage are not to be promised, offered, authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

  3. Disclosure of Information

    Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

  4. Intellectual Property

    Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights; and customer information is to be safeguarded.

  5. Fair Business, Advertising and Competition

    Standards of fair business, advertising, and competition are to be upheld. Appropriate means to safeguard customer information must be available.

  6. Protection of Identity and Non-Retaliation

    Programs that ensure the confidentiality, anonymity and protection of employee whistleblowers are to be maintained, unless prohibited by law. Suppliers should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

    Supplier employees may submit confidential reports of potential ethical violations, concerns and complaints between employees from suppliers and Kingston through the following methods:

    Location USA, CA
    Hotline 1(888)435-5453
    Email [email protected]
    Address 17600 Newhope Street, Fountain Valley, CA 92708
  7. Responsible Sourcing of Minerals

    To support industry-wide efforts to identify, reduce and draw nearer to eliminating the use of conflict minerals, suppliers shall warrant that all materials supplied to Kingston do not contain conflict minerals from Congo and its neighboring countries or any conflict regions areas that directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses. Conflict minerals include, but are not limited to, rare metals such as tinstone, wolframite, coltan, gold and their derivatives, especially gold (Au), tantalum (Ta), tin (Sn), tungsten (W) and cobalt (Co), from conflict regions. Consequently, the mining, refining, shaping and any other manufacturing or processing procedure of conflict minerals shall not take place in conflict regions. Suppliers shall exercise due diligence on the source and chain of custody of these minerals, reinforce its supply chain management, establish relevant policies and/or procedures to effectively detect and track sources of raw materials, ensure the legality of sources of raw materials and preclude use of conflict minerals. Kingston may audit the supplier’s due diligence measures regarding the sources of the supplier’s materials. Upon Kingston’s request, supplier shall truthfully answer investigative questionnaires along with other relevant information, and guarantee the truthfulness, correctness, and completeness of answers to such questionnaires and information it provides Kingston. Kingston may provide its customers and other organizations it partners with, with aforementioned completed investigative questionnaires and information.

  8. Privacy

    Suppliers are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

F. MANAGEMENT SYSTEM

Suppliers should adopt or establish a management system whose scope is related to the content of this Code. The management system is designed to ensure: (a) compliance with applicable laws, regulations, and customer requirements related to Supplier’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code.

The management system contains the following elements:

  1. Company Commitment

    A corporate social and environmental responsibility policy statement affirming the Supplier’s commitment to compliance and continual improvement endorsed by executive management and posted in the facility in the local language.

  2. Management Accountability and Responsibility

    The supplier clearly identifies senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.

  3. Legal and Customer Requirements.

    A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code

  4. Risk Assessment and Risk Management

    A system to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Supplier’s operations. The relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks should be determined.

  5. Improvement Objectives

    Written performance objectives, targets and implementation plans to improve the Supplier’s social and environmental performance, including a periodic assessment of the Supplier’s performance in achieving those objectives.

  6. Training

    Training for managers and workers on company programs, policies, procedures, and improvement objectives and to meet applicable legal and regulatory requirements.

  7. Communication

    A process for communicating clear and accurate information about Supplier’s policies, practices, expectations and performance to workers, suppliers and customers.

  8. Worker Feedback, Participation and Grievance

    Ongoing processes, including an effective grievance mechanism, to assess employees’ understanding of and obtain feedback on or violations against practices and conditions covered by this Code and to foster continuous improvement.

  9. Audits and Assessments

    Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of this Code and customer contractual requirements related to social and environmental responsibility.

  10. Corrective Action Process

    A process for timely correction of deficiencies, identified by internal or external assessments, inspections, investigations and reviews should be managed.

  11. Documentation and Records

    Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

  12. Supplier Responsibility

    A process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.

Such management system should also be open to inspections, including on-site inspections of supplier facilities by Kingston representatives or full access to validated third party audits encompassing aforementioned management systems. Supplier should maintain documentation necessary to demonstrate compliance with this Code and should provide Kingston with access to that documentation upon Kingston’s request.

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