Partner Responsibility, Ethics and Labor
Partner Responsibility, Ethics and Labor

Lumentum partner responsibility: integrity

Lumentum is committed to the highest standards of social, ethical, and environmental conduct and responsibility. This commitment applies to our facilities, processes, and employees as well as to the companies with whom we do business. To implement this commitment in our supply chain, we have adopted the standards within the Responsible Business Alliance's (RBA) Code of Conduct.

The RBA Code of Conduct is an industry-leading set of guidelines governing social, environmental, and ethical responsibilities in the electronics-industry supply chain. To ensure excellence throughout the Lumentum supply chain, we expect all our business partners, and specifically, each manufacturing location supplying materials to us, to demonstrate conformance to the voluntary standards outlined in the Code of Conduct, in addition to compliance with local labor, health, environmental and safety regulations.

Ethics and labor at Lumentum

Lumentum conducts business ethically and with the highest regard for employees throughout our supply chain and is committed to maintaining compliance with ethics and labor regulations worldwide. We use numerous internal and external tracking systems globally to ensure legal and regulatory compliance with changing ethics and labor issues.

Conflict minerals statement

Lumentum and its subsidiaries (“Lumentum”) are committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity and environmental responsibility.

Lumentum is committed to complying with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as well as the applicable requirements of Section 1502 of the Dodd-Frank Act, which aims to prevent the use of minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC) or in adjoining countries (“conflict minerals”).

Affected suppliers to Lumentum will be required to commit to being or becoming “conflict-free” (which means that such supplier does not source conflict minerals) and sourcing, where possible, only from conflict-free smelters.  Each affected supplier to Lumentum will be required to provide completed CMRT declarations evidencing such supplier’s commitment to becoming conflict-free and documenting countries of origin for the tin, tantalum, tungsten, and gold that it purchases. 

For more information on Lumentum conflict minerals program contact

Global trade policy

It is the policy of Lumentum, headquartered in the United States, to conduct business in compliance with all relevant export laws and regulations of the United States as well as with those of all other countries in which Lumentum and its subsidiaries operate.  Lumentum's products and technology may be subject to the Export Administration Regulations (EAR) or the International Traffic in Arms Regulations (ITAR). Lumentum complies fully with these laws and regulations as well as with those of the Office of Foreign Assets Control (OFAC).  For more information on Lumentum's Export Compliance policy and practices contact the Lumentum Legal Department.

Disclosure for the UK Modern Slavery Act and California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act (SB 657) and the UK Modern Slavery Act (MSA 2015) both address issues of slavery, servitude, forced or compulsory labor, and human trafficking. These acts were designed to address the role of business, like Lumentum, in preventing modern slavery from occurring in their supply chains. Lumentum is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chain, consistent with its disclosure obligations under SB 657 and MSA 2015.

Lumentum supports human rights globally both in our own facilities and in our supply chain. We strictly prohibit slavery or human trafficking of any kind and are committed to reducing the risk within our supply chain. Lumentum is a member of the Responsible Business Alliance (RBA), and we subscribe to the RBA Code of Conduct, supporting principles in human rights and labor, specifically the elimination of all forms of forced and compulsory labor. In addition, Lumentum has a Corporate Social Responsibility Policy that includes support of the principles established under the United Nations Universal Declaration of Human Rights and the International Labour Organization Declaration on Fundamental Principles and Rights at Work.

Lumentum expects the same high standards from all its contractors, suppliers and other business partners, as part of its contracting processes, Lumentum includes specific prohibition against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children.

1. Verification: The steps we have taken to evaluate and address forced labor risks are through compliance to the RBA Code of Conduct. The RBA Code of Conduct, section A1 “Freely Chosen Employment”, states that “Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons shall not be used.”

  • Risk Assessments of Suppliers: Evaluation of labor and human rights risks through RBA tools such as a risk assessment platform and RBA Self- Assessment Questionnaire (SAQ)
  • Performance Monitoring via Supplier Scorecards: Social Responsibility metrics are integrated alongside other metrics
  • Third Party Audits: Lumentum’s Contract Manufacturers are required to undergo third-party audits to evaluate their conformance to the RBA Code of Conduct.

2. Supplier Audits: Lumentum’s Contract Manufacturers are required to undergo third-party audits to evaluate their conformance to the RBA Code of Conduct. The third-party audits are required every 2 years, with verification audits confirming closure of identified findings in between. Onsite subcontractors and service providers are included in the scope of our internal audits.
3. Certification: Suppliers are required to sign Lumentum’s Supplier Code of Conduct, unless Lumentum accepts the Supplier’s own Code of Conduct, committing to compliance with labor laws, regulations and prohibition of forced or slave labor.

4. Internal Accountability: Lumentum’s Code of Business Conduct outlines the broad principles of legal and ethical business conduct embraced by Lumentum as part of our commitment to integrity. Lumentum expects that all directors, employees, agents and contractors will act in a manner that complies both with the letter and the spirit of the Code. We provide multiple mechanisms for reporting concerns, including anonymous reporting. As part of evaluating our own compliance, we conduct internal RBA audits on an annual basis.

5. Training: Lumentum employees are required to complete training on Lumentum’s Code of Business Conduct on an annual basis. In addition, during a supplier conference there is training to suppliers and supply chain staff on compliance to the RBA Code and risks in the supply chain, including modern day slavery. There has also been specialized training delivered to Supplier Quality Engineers on risks and red flags to be aware of during their supplier visits.

Our commitment to the RBA Code of Conduct is a cornerstone of our efforts to safeguard our operations and supply chain against any forms for forced, bonded or slave labor.

Disclosure for the UK Modern Slavery Act and California Transparency in Supply Chains Act (PDF, 150.58 KB)