Operating with 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.
- Responsible Business Alliance
- Business Conduct and Ethics
- Human Rights
- Supply Chain Management
- Conflict Minerals
- Substance Restrictions
- Global Trade
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. Lumentum fully supports the vision and mission of the RBA, and the collaborative approach to improving working and environmental conditions across the supply chain. As part of our commitment, 100% of our manufacturing sites complete an annual RBA Self-Assessment Questionnaire (SAQ) and all have been rated as low risk. Since 2019, all of our active manufacturing sites completed internal or external social responsibility audits.
We require our next-tier suppliers to acknowledge, implement, and comply with all applicable labor, environmental, and health and safety laws and regulations, including those requirements in the RBA Code of Conduct. To verify this practice, we conduct due diligence on our supply chain, assessing risk from a country level as well as facility level. We require our top direct suppliers to complete assessments that evaluate facility risks on labor, environment, health and safety, and ethics. In addition, all contract manufacturers undergo third-party audits every two years to evaluate their conformance to the RBA Code of Conduct. Verification audits confirm resolutions of any adverse findings.
Business Conduct and Ethics
At Lumentum, we conduct our business affairs with uncompromising integrity. Integrity is at the heart of our reputation for providing the highest quality products and services along with ensuring a fair and equitable workplace.
Our Code of Business Conduct outlines the broad principles of legal and ethical business conduct embraced by Lumentum 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. We provide multiple mechanisms for reporting concerns, including anonymous reporting.
Code of Business Conduct (PDF, 333.73 KB)
|Percentage communicated to on anti-corruption policies and procedures|
|- Governance body members||100%||100%||100%|
|Percentage trained on anti-corruption policies and procedures|
|- Governance body members||*||100%||*|
|Total number of confirmed incidents of corruption||0||0||0|
|In FY20, Lumentum expanded its training to include contingent employees. This change in practice, and limitations to in-person classroom training due to COVID-19, have impacted our FY20 training coverage.
*Lumentum’s Board of Directors receives training, via the Code of Business Conduct, biennially. Beginning in FY21, training will occur on an annual basis.
Lumentum is committed to uphold the human rights of workers and to treat each of them with dignity and respect. We prohibit the use or support of any form of child labor, forced labor or human trafficking at Lumentum and our suppliers. This requirement is embodied 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, consistent with obligations under the UK Modern Slavery Act (MSA 2015) and the California Transparency in Supply Chains Act (SB 657).
Lumentum pays all fees associated with recruitment and ongoing employment, and prohibits suppliers, including subcontractors and labor or recruitment agencies, from charging workers any fees or deposits for employment. This applies to all types of workers, including migrant, temporary or subcontracted. 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 contract with clearly defined terms and conditions.
During new hire orientation, Lumentum policies, including the Code of Business Conduct, are reviewed and require signed acknowledgement from each worker. The Code clearly states any harassment, intimidation, or discrimination is not tolerated. As an equal opportunity employer, Lumentum is committed to providing a workplace free of harassment, discrimination, and retaliation, as well as disrespectful, abusive, or unprofessional conduct. If such cases should arise, employees are encouraged to communicate with Human Resources and file a grievance through our anonymous hotline, EthicsPoint.
Lumentum maintains a rigorous audit program. Third-party organizations and our internal team conduct regular audits of our global facilities. These audits are conducted to the Responsible Business Alliance (RBA) standard, or equivalent, which includes the requirement of freely chosen employment and no child labor. The scope of these audits include subcontracted labor and contingent workers.
Supply Chain Management
Lumentum is committed to conducting our business affairs with uncompromising integrity, protecting the environment, and preserving the welfare of our personnel, our business partners, and the public. This commitment means acting ethically and complying with all applicable laws and regulations of the countries in which Lumentum does business or where business is being conducted on behalf of Lumentum and its subsidiaries. In keeping with our commitment, we expect that all suppliers act and conduct business in a manner that complies both with the letter and spirit of our Supplier Code of Conduct.
In addition to our commitment to uphold the human rights of workers in our supply chain, suppliers must have EHS policies and processes in place to demonstrate a commitment to safe and environmentally responsible operations, services, and management. This includes procedures and systems to identify, prevent, manage, and track environmental and health and safety hazards, including maintenance of emergency response plans. Suppliers must have EHS audit programs to periodically assess their prevention plans and measures, facilities, and operations for compliance and effectiveness. Lumentum expects suppliers to maintain compliant EHS systems and provide a record of compliance with all applicable laws and regulations when conducting business.
In effort to build a more agile and resilient supply chain, we partner with our suppliers to identify and address potential areas of risk. Risks may include physical impacts of climate change, such as extreme weather events, to geopolitical or business risks that may threaten our supplier’s ability to conduct business. In addition to working closely with our suppliers, we have engaged third-party providers to assist in assessing the risk within our supply base. Supply Risk Solutions monitors event impacts within our supply chain, as well as provides best practices and suggestions for improvement of our suppliers’ business continuity plans. Rapid Ratings assesses the financial health of our supply base
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 (“conflict minerals”).
Affected suppliers are required to commit to being or becoming “conflict-free” (which means that such supplier does not source conflict minerals) and sourcing only from conflict-free smelters. Each affected supplier to Lumentum is 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 (3TG) that it purchases. Our Conflict Minerals program has been extended in 2020 to include cobalt. We follow the same process of supplier inquiry for cobalt sourcing as for conflict minerals (3TG) by using the cobalt reporting template.
Lumentum has a dedicated position to manage and review our conflict minerals program work. We engage a third-party to collect data from suppliers and review smelter information. More than 90% of surveyed suppliers respond to our annual reasonable country of origin inquiry with completed Conflict Minerals Reporting Templates (CMRT).
As a member of the Responsible Minerals Initiative (RMI) we require all our suppliers to source tin, tantalum, tungsten, and gold only from smelters conformant with the Responsible Minerals Assurance Process (RMAP) assessment protocols. 82% of smelters and refiners identified in our supply chain in 2019 were verified to be conflict-free through their completed RMAP or are actively undergoing RMAP assessment process. Based on our due diligence process an additional 16% of smelters can be reasonably considered as conflict-free, however, they did not undergo the RMAP assessment. 2% of smelters, which have been identified by a sole supplier, were identified as high risk and Lumentum engaged with the supplier to conduct the due diligence to determine if these smelters are actually used for parts shipped to Lumentum and to eliminate them from our supply chain.
For more information on Lumentum conflict minerals program contact ConflictMinerals@Lumentum.com.
Lumentum is committed to compliance with all applicable product environmental laws and regulations, inclusive of EU Directive 2011/65/EC (RoHS), Directive 2012/19/EC (WEEE) and Regulation 1907/2006/EC (REACH).
Lumentum currently fulfills, and will continue to fulfill, all our obligations under these regulatory schemes. We participate in technical working groups and stakeholder consultations for EU RoHS legislation reviews and RoHS exemptions evaluations to ensure we are up to date on the latest and future regulations to appropriately plan our product development.
We require all our suppliers to complete Lumentum’s Compliance Data Form with material composition and to disclose any regulated substances present in parts and materials purchased by Lumentum. Compliance with substance restrictions is required for component qualification, release to manufacturing, and is continuously reviewed against new substance requirements until product discontinuance.
Lumentum eliminated four phthalates (BBP, DBP, DEHP and DIBP) restricted by the RoHS amending Directive (EU) 2015/863 from all products. In FY2020 we reviewed 18,000 parts and surveyed over 600 suppliers to ensure all our products comply with Perfluorooctanoic acid (PFOA) restrictions of EU REACH regulation and the Stockholm Convention on Persistent Organic Pollutants. We continuously monitor technical progress and work closely with our suppliers to proactively reduce the use of hazardous substances in our products. We evaluate our products against declarable substances included in IEC 62747 standard. In FY 2020, 61% of our revenue was of products that contain IEC 62474 declarable substances, down from 68% in FY 2019, mainly due to lead in components covered by RoHS exemptions.
Please contact customer service for more information on Lumentum product compliance.
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.