Operating with Integrity
Lumentum is committed to the highest standards of social, ethical, and environmental conduct and responsibility. This applies to our facilities, processes, and employees, as well as to the companies with which we do business.
To find out more about our initiatives, download our CSR Report (PDF, 8.66 MB)
Business Conduct and Ethics
At Lumentum, integrity is at the heart of our reputation for providing the highest-quality products and services and ensuring a fair and equitable workplace. Lumentum’s Code of Business Conduct outlines the broad principles of legal and ethical business conduct embraced by the company as part of our commitment to integrity. We expect all Directors, employees, agents, and contractors to act in a manner that complies both with the letter and the spirit of the Code. The Code is available in all local languages where we operate.
The global footprint of Lumentum and the breadth of our supply chain creates exposure to certain regulatory and compliance risks. Conducting business with uncompromising integrity means acting ethically and complying with applicable laws and regulations where we do business, and we expect all parties affiliated with Lumentum to do so as well. All of our direct and indirect suppliers receive communication on anti-corruption policies and procedures. Local laws and customs differ by country; thus, a global code of conduct is critically important. The Code provides a summary of beliefs and behaviors fundamental to our success, principal among which is to act in a manner that reflects honesty, fairness, and integrity.
To ensure understanding of and compliance with applicable legal requirements and our standard of conduct, we engage in consistent communication with and training of our stakeholders. During new-hire orientation, our Code of Business Conduct is reviewed, and a signed acknowledgment is required.
We provide multiple mechanisms for reporting concerns, including anonymous reporting. Maintaining the highest ethical standards is the responsibility of every member of the Lumentum community. Early identification of potential ethical or compliance related issues often will allow for their prevention or rapid resolution, minimizing adverse repercussions, and frequently providing opportunities for us to learn new ways to improve our business practices. Accordingly, the rapid identification and reporting of concerns is a key component of our commitment to integrity.
All stakeholders are encouraged to report suspected or actual violations of the Code, or of laws or government rules and regulations. To provide a description of a suspected violation, complaint, or concern, email LumentumLegal@Lumentum.com, visit our EthicsPoint site or access our Anonymous Reporting hotline found in our Code of Business Conduct.
At Lumentum, human rights are woven into every aspect of our business. Lumentum is committed to uphold the human rights of workers and to treat each of them with dignity and respect. Lumentum enforces several policies to protect the rights of its workers. These are embedded in our Corporate Social Responsibility Policy, Code of Business Conduct, Supplier Code of Conduct and through our commitment to the Responsible Labor Initiative (RLI). In addition, we ensure there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain.
Lumentum has implemented practices to ensure that forced labor does not exist in our operations or our supply chain. We pay all fees associated with recruitment and ongoing employment, and we prohibit suppliers, including subcontractors and labor or recruitment agencies, from charging workers, including migrant, temporary, or subcontracted workers, any fees, or deposits for employment.
All Lumentum sites require official government identity documents to verify age and right to work. Identity documents are used for verification purposes only and retained by the employee. Employment is at will, and each employee is provided an employment agreement with clearly defined terms and conditions. Suppliers are expected to follow these same requirements.
Lumentum is an equal opportunity employer and does not tolerate harassment, intimidation, or discrimination of any kind. If such cases should arise, employees are encouraged to communicate with their manager or Human Resources, or to file a grievance through EthicsPoint, our anonymous hotline. All reports of suspected violations, concerns, or complaints are directed to the General Counsel. The information is promptly evaluated, and the appropriate actions are taken, including investigation, in accordance with applicable laws, rules, and regulations.
Finally, Lumentum maintains a rigorous audit program. Third-party organizations and our internal CSR team conduct regular audits of our global facilities. Audits include the requirement of freely chosen employment and zero child labor. The scope of these audits includes subcontracted labor and contingent workers. Company-wide training on the RBA Code includes human rights such as forced labor, child labor, and freedom of association. We deliver specialized trainings to our supply chain staff and global talent acquisition teams addressing human rights risks.
We recognize the primary human rights risks that may exist in our supply chain. Lumentum works closely with suppliers on protecting workers’ rights and expressly prohibits any form of child labor, forced labor, or human trafficking.
We ensure transparency in our approach to removing modern slavery throughout our supply chain, consistent with obligations under the UK Modern Slavery Act (MSA 2015) and the California Transparency in Supply Chains Act (SB 657).
Supply Chain and Supplier Responsibility
Key to our success is our relationship with, and the performance of, our supply chain partners. We engage with over 700 direct suppliers and several core contract manufacturers. Strategically, we aim to design agility, resiliency, and scale into our global supply chain for all new and existing products.
Lumentum is committed to acting ethically and complying with all applicable laws and regulations of the countries where we do business. We have the same high expectations of our suppliers and require their signed acknowledgement of our Supplier Code of Conduct and/or Channel Partner/Distributor Code of Conduct upon onboarding; thereafter, suppliers are mandated to comply with both the letter and spirit of the Code.
We complete annual supplier responsibility risk assessments of our supply chain using RBA’s tools and approach. We evaluate our direct and indirect suppliers to the RBA Code of Conduct which covers five categories: labor and human rights, environment, health and safety, ethics and the management systems that support these topic areas.
The first level assessment includes an evaluation of our top 200 suppliers by spend and considers geographical locations, spend level, industry, and international indices from organizations such as UNICEF, World Resources Institute, International Labor Organization.
The second level assessment is based on a detailed Self-Assessment Questionnaire (SAQ) that evaluates suppliers’ compliance with the RBA Code at their corporate and manufacturing sites. This assessment covers all major suppliers and any supplier that was rated high risk in the first level assessment. We work with our suppliers on corrective actions for the areas identified as high risk.
We require key management staff of our Contract Manufacturers to complete RBA Code of Conduct training to ensure the Code requirements are understood and implemented within their facilities. All contract manufacturers undergo third-party audits covering the full RBA Code of Conduct biennially to evaluate conformance. We work with contract manufacturers on corrective actions until closure and require third-party verification audits to confirm resolutions of any adverse findings.
The CSR team also provides annual detailed training covering environmental compliance, RBA compliance, and specific CSR risks that are relevant to supply chain team members, such as forced labor, working hours and restricted chemicals. The training is provided to Global Commodity Managers, Buyers, Purchasing, and Supplier Quality Engineers.
Supply Chain Risk Management
For business risk, we partner with our suppliers to identify and address potential areas of risk. Risks may include physical impacts of climate change, geopolitical impacts, or risks that threaten our suppliers’ ability to conduct business. Additionally, third-party providers assist in assessing the risk within our supply base.
RapidRatings’ Financial Health Rating evaluates supply chain resiliency through predictive analytics. Dataminr, a service powered by AI, monitors real time physical risks and supply chain disruptions, including natural disasters, geopolitical events, COVID updates and logistics information. Lumentum has created a business continuity planning assessment to ensure proper business continuity practices exist within our key suppliers. Each of our critical suppliers is required to complete this assessment and provide up to date financial information on an annual basis, which allows us to understand and mitigate risks within our supply chain. By leveraging information from a variety of sources, we improve continuity within Lumentum’s supply chain.
Responsible Business Alliance
Lumentum is a proud member of the Responsible Business Alliance (RBA), the world’s largest industry coalition dedicated to corporate social responsibility in supply chains. The RBA Code of Conduct establishes industry guidelines for social, environmental, and ethical practices.
Lumentum fully supports the vision and mission of the RBA, its Code of Conduct, and the collaborative approach to improving working and environmental conditions across the supply chain. Our Corporate Social Responsibility Policy aligns with the RBA and its objectives. We conduct internal reviews and audits of our facilities to the RBA Code of Conduct to continuously improve our own operations.
We require the same high levels of commitment from our partners and suppliers through our Supplier Code of Conduct. We encourage and hold our first-tier suppliers accountable to attain high-level standards. Using RBA’s tools and approach, we actively monitor our supply chain, where applicable.
Together, we envision an electronics industry that is devoted to leading global sustainability and ethical practices for the well-being of its workers, businesses, and the environment.
Together, we envision an electronics industry that is devoted to leading global sustainability and ethical practices for the well-being of its workers, businesses, and the environment.
All active manufacturing sites have completed internal or external social responsibility audits. All employees, including on-site contingent workers, are trained on the RBA Code of Conduct. Annual refresher training sessions are also required for all employees and contingent workers, with a focus on different sections of the Code each year. For example, we’ve delivered trainings on how to recognize forced labor in the supply chain, human rights and climate change and greenhouse gas emissions. Each year we target 100% completion of employees and contingent workers.
100% OF OUR MANUFACTURING SITES COMPLETE AN ANNUAL RBA SELF-ASSESSMENT QUESTIONNAIRE, AND ALL HAVE BEEN RATED AS LOW RISK.
100% OF OUR CONTRACT MANUFACTURERS COMPLETED AUDITS TO VERIFY COMPLIANCE WITH THE RBA CODE OF CONDUCT.
Lumentum is committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity, and environmental responsibility. Lumentum complies 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.
As a member of the Responsible Minerals Initiative (RMI) we require all our suppliers to source tin, tantalum, tungsten and gold (3TG) only from smelters conformant with the Responsible Minerals Assurance Process (RMAP) assessment protocols. Affected suppliers are required to provide completed Conflict Minerals Reporting Templates (CMRT) detailing the tin, tantalum, tungsten, and gold (3TG) smelters in their supply chain. Lumentum pays additional attention to suppliers reporting high-risk smelters (i.e. a smelter that sources from the covered countries and is not currently RMAP conformant).
In 2020, we expanded our Conflict Minerals program to include cobalt sourcing in our supply chain, and in 2022, extended it to mica. We follow the same process of supplier inquiry for cobalt and mica sourcing as for conflict minerals (3TG) by using the cobalt reporting template and the extended minerals reporting template for mica.
Lumentum has a dedicated team to manage and review our conflict minerals program work. We engage a third party to collect data from suppliers and review smelter information.
Our annual Specialized Disclosure Report (Form SD), including the Lumentum Holdings Inc. Conflict Minerals Report, is publicly available at www.lumentum.com/investors. For more information on Lumentum conflict minerals program contact ConflictMinerals@Lumentum.com.
Data Privacy and Security
The security of our information systems is critical to our business success. Information security can impact both reputational and competitive aspects of our work. It helps us to capture our innovations through the protection of intellectual property and it enables our everyday work across all our teams. Our Privacy Program Committee oversees the protection of data, information, and assets and ensures compliance with all applicable global data privacy requirements.
Lumentum’s information technology (IT) system security is critical to Lumentum’s business success. We prioritize security and implement effective measures to protect against cyber threats, safeguard assets, comply with regulations and maintain the confidence of our customers.
Cybersecurity Governance and Risk Management
Lumentum’s chief information officer (CIO) updates the company’s cybersecurity with the objectives of all business units and other functional areas. In this way, we ensure that cybersecurity risks from both internal and external sources are identified and evaluated and that controls are designed and implemented to address relevant areas and achieve cybersecurity objectives. Cybersecurity metrics are established and tracked internally.
Our IT infrastructure and systems are configured to maintain the confidentiality, integrity and availability of information and transaction processing. Our cybersecurity risk management program is based on specifications set forth in the National Institute of Standards and Technology Framework for Improving Critical Infrastructure Cybersecurity (NIST cybersecurity framework) and International Standardization Organization and International Electrotechnical Commission (ISO/IEC 27001) standards.
Our IT team monitors security governance, security architecture and technical support, application security, and the security operations center. The team is encouraged to maintain an active role in relevant cybersecurity information sharing forums, special interest groups and professional associations to stay up to date on new and emerging cybersecurity risks that may impact Lumentum or our operating environment.
A third-party security auditor completes an annual security assessment that identifies internal and external cyber threats and vulnerabilities. Additional systems and processes for risk assessment and mitigation include monthly scans of all systems to identify threats and vulnerabilities and patch updates for all systems.
Our cybersecurity risk management program contains internal processes and external monitoring by third parties and law enforcement. If an incident is detected, the matter is immediately reviewed by the cybersecurity team. Upon review, the matter may be treated as a security incident and handled in accordance with our security incident response policy.
Lumentum sees security related issues as part of ongoing activities. Formal steps are taken to evaluate and address security risks. Lumentum’s Risk Management Program is tied to other cybersecurity measures.
Employee Training and Vendor Management
We believe all employees play a crucial role in ensuring the security of Lumentum’s technology systems. Upon hiring and annually thereafter, 100% of employees successfully complete IT security training courses covering cybersecurity practices that support the functioning of our cybersecurity risk management program. The training courses are designed to teach employees to identify and respond to social engineering attacks such as phishing and tailgating and to comply with Lumentum policies and practices.
All vendors and business partners with access to confidential information are required to sign and comply with security and privacy agreements. Critical external vendors complete a comprehensive security assessment when onboarding. Lumentum works with a third party to evaluate responses and ensure external vendors meet the expected criteria.
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 GlobalTrade@Lumentum.com.
Our legacy of innovation is evident in our product leadership positions and extensive intellectual property portfolio. Our patent portfolio is constantly evolving, with strengths in optical switching, coherent transmission, source lasers, 3D sensing, photonic integrated circuits, and ultrafast lasers. This is what sets us apart as trailblazers and leaders in the industries we serve. We value our innovators, acknowledge their contributions, and celebrate their patents in our company-wide meetings.
Kaizen is a Japanese term that loosely translates to continuous improvement. Many organizations use Kaizen methodology only in production, but Lumentum applies Kaizen at every stage of the life cycle of a product as well as in our business processes.
During the product design phase, we use Kaizen to bring the right people together and conduct rapid cycles of continuous improvement. In this way, we utilize the incredible talent and knowledge of our teams to make strong designs even stronger. This is accomplished by combining production knowledge with design knowledge and encouraging teams to collaborate to “fail fast, fail cheap and fail forward.”
Once a product design exists, we prepare for mass production by utilizing the Production Preparation Process (3P). This is an event-driven process for developing a new product concurrently with the operation or processes that will produce it, by the people who will interact with it.
After a product is released, we remain focused on continuous improvement. Kaizen events are used to improve existing processes across the entirety of the business. In all Kaizen projects, we strive to double the good and halve the bad, with a quality goal of zero defects and a safety goal of zero incidents.
Lumentum Ventures is a strategic initiative to harness internal innovation and disruptive technology to drive organic growth into new product categories and end markets, with a goal of ultimately building new businesses that accelerate revenue/margin expansion and customer diversification for the company.
Cross-functional teams with expertise in market research, competitive intelligence, R&D, and business development come together to analyze customer and industry pain points and conceptualize differentiated solutions that address critical market gaps.
By leveraging Lumentum’s world-class portfolio of photonic technologies, deep technical expertise, and broad ecosystem partnerships, coupled with an agile development process, these teams are taking ideas “out of the lab” to validate market traction and establish these nascent businesses for sustainable, long-term success.
Twice a year, the Luminary Program solicits, evaluates, selects, and corporately funds employee-conceived innovative concept investigation projects that address challenging topics in technology, products, and applications. The program offers employees the opportunity to develop, through company-sponsored exploratory projects, their innovative ideas that may not neatly fit into traditional product roadmaps, address our conventional markets, or meet our traditional corporate investment profile.
Projects selected for development often remain in the research and development phase for several years while we assess their merits and feasibility. Our appetite for risk is greatest at this stage, with “fail fast, fail cheap, fail forward” as a guiding principle.