The California Transparency in Supply Chains Act (SB 657) (the “Act”) applies to retailers and manufacturers doing business in California, including Cavium. The Act requires these companies to disclose on their websites certain information related to efforts the companies take to eradicate slavery and human trafficking from their supply chain. Cavium is committed to acting in a socially responsible manner and upholding the values and ethics expressed in the Cavium Code of Conduct and Cavium Policy on Corporate Social and Environmental Responsibility.
Cavium considers its strategic suppliers which deliver high volume products and/or services critical to Cavium’s business as tier 1 suppliers. Prior to entry into a business relationship with a tier 1 supplier, the supplier must go through the Cavium supplier qualification process. One of the critical items verified during the supplier qualification process is a supplier’s corporate social and environmental responsibility, including their policy against slavery and human trafficking. Cavium does not use third party verifiers for the supplier qualification process. Thereafter, Cavium relies on the process described below to assess risk of slavery and human trafficking for its tier 1 suppliers.
On an annual basis Cavium requires each tier 1 supplier to sign the Cavium Supplier Labor Responsibility Agreement which includes, among other things, prohibitions on slavery and human trafficking. Cavium manages this process and does not use a third party. In addition, Cavium requires each tier 1 supplier to complete a supplier survey, which includes information regarding slavery and human trafficking. Cavium uses a third party vendor to assist with the survey process.
On a bi-annual basis Cavium schedules audits with its tier 1 suppliers. One of the items verified during this audit is compliance with the Cavium Supplier Labor Responsibility Agreement and Cavium’s Policy on Corporate Social and Environmental Responsibility. These audits are performed by Cavium and are generally announced ahead of time. Any non-conformances found in the audits are recorded and corrective and preventative plans are put in place with such nonconforming supplier.
Cavium employees are required to acknowledge the Cavium Code of Conduct on an annual basis. The Cavium Code of Conduct requires compliance with all laws where Cavium operates. Cavium has internal accountability standards and procedures for employees and contractors who violate the Cavium Code of Conduct, which may include termination of employment.
Cavium requires all employees to complete trainings on the Cavium Code of Conduct, which includes compliance with applicable laws. In addition, we have provided those involved in supply chain management with training on the Act. We are planning to expand our training on slavery and human trafficking for those involved in supply chain management.