CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT AND UK MODERN SLAVERY ACT DISCLOSURE
(Pursuant to California Civil Code § 1714.43 and Section 54 (Part 6) of the UK Modern Slavery Act 2015)
Molex Electronic Technologies, LLC ("Molex") is committed to conducting all business lawfully and with integrity. Molex’s commitment to ensuring that our business and supply chain are maintained in a lawful and socially responsible way includes, among other things, an expectation that neither human trafficking nor slavery/forced labor is taking place in any part of our business, and that our suppliers not use forced labor in any of its forms, including human trafficking and slavery, to produce the products they provide to Molex. Molex’s expectations are set out in its Code of Conduct, as well as a separate Molex Code of Conduct for Suppliers that extends to our global supply chain.
Verification
The Molex Code of Conduct for Suppliers sets responsible business requirements for our global supply chain. This code requires suppliers to provide safe and healthy working conditions, treat their workers with dignity and respect, and follow environmentally responsible practices. As to human trafficking and slavery, it states in part as follows:
7.1 FREELY CHOSEN EMPLOYMENT: Suppliers shall not use forced, bonded, indentured labor or involuntary or exploitative prison labor. Slavery or trafficking of persons shall not be used. This includes transporting, harboring, recruiting, or 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 within the facility or unreasonable restrictions on entering or exiting company-provided facilities. All work will be voluntary, and all workers will be free to leave upon reasonable notice.
That section of the Code of Conduct for Suppliers also addresses risks associated with the possible presence of labor brokers in the supply chain:
7.1 FREELY CHOSEN EMPLOYMENT: ... Suppliers shall take steps to ensure that Supplier agencies providing workers to the Supplier are aware of and compliant with the provisions of the Code and that they adhere to the laws of the sending and receiving countries, whichever is more stringent in protecting workers.
As a Responsible Business Alliance (RBA) member, Molex also adheres to the RBA Code of Conduct, which similarly prohibits the use of forced, bonded, or indentured labor, involuntary prison labor, or slavery or human trafficking.
Supplier Audits
Molex conducts audits of our key suppliers to evaluate compliance with company standards. The scope of these supplier audits includes our company standards for human trafficking and slavery in supply chains, as well as our broader social responsibility and sustainability policies. Suppliers are typically audited based in part on an assessment of the level of risk for coerced labor practices in the country where the supplier operates.
Preliminary supplier risk assessments are generally conducted through supplier self-assessment questionnaires. Each year, our suppliers receive a questionnaire, including questions targeted at human trafficking and slavery risk. Molex uses the questionnaire to help determine risk areas for its suppliers. Using a risk-based approach, announced audits are then scheduled and conducted by internal and external auditors using industry-accepted protocols to ensure that supplier performance is consistent with our policies and expectations. In the event an audit reveals supplier non-conformance with our standards, depending on the circumstances we either require suppliers to establish corrective action plans and report on the implementation of such plans, or we terminate the relationship.
Direct Supplier Certification
To promote and ensure compliance with our standards relating to human trafficking and slavery, we include clauses in our Code of Conduct for Suppliers and commercial agreements requiring direct supplier compliance with applicable laws and regulations. For example, the Code of Conduct for Suppliers states:
5. REQUIREMENTS: All Suppliers to Molex shall comply with all applicable legal requirements and, where appropriate, conform to additional requirements specified by Molex customers. If the requirements in this standard are more prescriptive (stricter) than local laws, then these requirements should be followed. Likewise, if local laws are more prescriptive (stricter) then they should be followed.
Molex expects its suppliers to communicate the Code to their employees and their own suppliers, and for their employees and suppliers to adhere to them.
Accountability Standards
Molex’s management sets the tone for our ethical culture and holds managers accountable for communicating ethics and compliance expectations. Molex’s Code of Conduct, which is available in more than 18 languages, seeks to promote honest and ethical conduct and support compliance with applicable laws and regulations. The Code of Conduct reflects our policies related to forced labor, human trafficking, wages and work hours, and nondiscrimination.
Non-compliance with Molex’s standards regarding human trafficking and slavery - whether by a supplier or an employee - can result in corrective action or termination depending on the circumstances. Internal or external auditors would work with suppliers, employees and possibly a third-party expert to resolve any instances of non-compliance. Molex’s employees are trained on and provided with several means to report compliance concerns, including on an anonymous basis, and such concerns are objectively investigated under the guidance and direction of our compliance or legal departments. Molex prohibits retaliation against anyone who, in good faith, raises a concern.
Training on Human Trafficking & Slavery
Molex requires its employees to comply with our global Code of Conduct and internal employment policies, which address prohibition of coerced labor. Employees are trained on the specific requirements of these policies. Molex also provides training to our employees who are directly responsible for procurement and supply chain management on the subject of human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products. Such employees receive training on company policies and procedures designed to ensure that Molex’s supply chain is free of any type of coerced labor, including guidance on reporting concerns. The training is periodically provided through a variety of means.
Click here to view the complete California Transparency in Supply Chains Act of 2010 (SB 657) or visit http://www.leginfo.ca.gov/pub/09-10/bill/sen/sb_0651-0700/sb_657_bill_20100930_chaptered.pdf
Click here to view the complete UK Modern Slavery Act 2015 or visit http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted
This statement is made and reflects the position of Molex as of February 15, 2017 and has been approved by:
Joseph Nelligan, Jr., CEO and Manager
Molex Electronic Technologies, LLC
Date: January 4, 2019