Sustainability in Our Business

Lumentum’s Code of Business Conduct defines our global standards for ethical, legal, and responsible business practices and applies to all board members, employees, agents, and contractors. The Code is available in all local languages where we operate. All new employees receive training and must formally acknowledge adherence as part of onboarding

We maintain compliance oversight across our operations and supply chain and expect suppliers to follow our Supplier Code of Conduct, which outlines standards on human rights, anti-corruption, and fair competition. All new suppliers receive the Supplier Code of Conduct during onboarding as part of our commitment to promoting ethical business practices across our value chain.

We provide multiple channels for reporting ethical or compliance concerns. All employees, contractors, and stakeholders are encouraged to report potential or actual violations of our Code of Business Conduct or applicable laws.

Maintaining high ethical standards is everyone’s responsibility. Early reporting helps prevent issues, supports accountability, and strengthens our culture of integrity. Reports can be submitted through our anonymous hotline, EthicsPoint platform, or by emailing LumentumLegal@Lumentum.com.

Lumentum is committed to upholding human rights and treating every worker with dignity and respect, as outlined in our Corporate Social Responsibility Policy, Code of Business Conduct, Supplier Code of Conduct and reinforced through our participation in the Responsible Labor Initiative (RLI).

We prohibit all forms of forced, bonded, or child labor across our operations and supply chain. Lumentum pays all recruitment-related fees and prohibits suppliers or labor agencies from charging workers any fees or deposits for employment. All workers must meet legal age and work-authorization requirements, and employment terms are clearly defined in written agreements.

We maintain zero tolerance for harassment, intimidation, or discrimination, and provide accessible reporting channels—including EthicsPoint, our anonymous hotline—for raising concerns.

Lumentum conducts regular third-party and internal audits to assess compliance with human-rights and labor standards, including those set out in the Responsible Business Alliance (RBA) Code of Conduct.

Our approach aligns with international human-rights conventions and meets disclosure obligations under the UK Modern Slavery Act, California Transparency in Supply Chains Act, and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211).

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.

As part of our commitment to responsible business practices, RBA Code of Conduct training is a core element of our global sustainability program. All employees complete full RBA Code training during onboarding, covering key human rights topics such as forced labor, child labor, and freedom of association. We provide annual refresher training to reinforce these principles and maintain awareness across our workforce.

Additional, targeted training is delivered to employees who engage directly with our supply chain, such as Global Commodity Managers, Supplier Quality Engineers, R&D engineers, and Buyers, on identifying and managing human rights risks. Key staff at our most critical suppliers, our Contract Manufacturers, also complete RBA Code and annual refresher training. We aim to achieve 100% completion annually for all targeted employees.

We regularly evaluate our operations and supply chain to ensure alignment with the Responsible Business Alliance (RBA) Code of Conduct and to drive continuous improvement in responsible business practices.

Our success depends on the strength and integrity of our global supply chain. We work with more than 900 direct suppliers and several core contract manufacturers, building agility, resiliency, and scale into every stage of our operations.

Lumentum is committed to acting ethically and in compliance with applicable laws and regulations wherever we operate. We hold our suppliers to the same standards, requiring formal acknowledgement of our Supplier Code of Conduct and/or Channel Partner/Distributor Code of Conduct during onboarding, with ongoing adherence to both the letter and spirit of these policies.

Supplier performance and alignment with our values are evaluated through our Responsible Business Alliance (RBA) assessments and audits, described in the section above.

Lumentum is committed to responsible sourcing and to ensuring that the materials in our products are obtained in a manner consistent with our values of human rights, integrity, and environmental responsibility.

We follow the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and adhere to Section 1502 of the U.S. 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 suppliers to source tin, tantalum, tungsten, and gold (3TG) only from smelters conformant with the Responsible Minerals Assurance Process (RMAP). Rather than prohibiting high-risk countries from our supply chain, we support responsible raw material sourcing from these regions through the use of RMAP conformant smelters. Affected suppliers of 3TG-containing parts or materials must submit Conflict Minerals Reporting Templates (CMRTs) on an annual basis, disclosing the smelters in their supply chains.

Lumentum has dedicated personnel to manage our conflict minerals program; however, we engage a third-party consulting firm for the smelter due diligence process.

Lumentum’s annual Specialized Disclosure Report (Form SD) with the Conflict Minerals Report are available on our Investor Relations page. For more information, contact ConflictMinerals@Lumentum.com.

Information security is critical to our business success and helps protect innovation, intellectual property, and the data that enable our global operations. Our Legal team oversees the privacy program, with support from Information Technology (IT), to ensure compliance with applicable global data privacy and protection requirements.

Information security is essential to maintaining the trust of our customers, employees, and partners. We continually work to strengthen our cybersecurity posture, implement effective controls, and align with leading industry standards and frameworks, while complying with relevant regulations. Our overall cybersecurity risk management practices are informed by the ISO 27001 standard and the National Institute of Standards and Technology (NIST) Cybersecurity Framework, providing a foundation for ongoing enhancement. Lumentum’s headquarters and Thailand site are ISO 27001-2022 certified, reflecting our commitment to continuously improving our information security management.