UK Modern Slavery Act Introduction

This Statement sets out Rochester Electronics’ actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chain. This statement relates to actions and activities during the financial year January 1, 2020 to December 31, 2020.

The organization recognizes that it has a responsibility to take a robust approach to slavery and human trafficking.

The organization is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

We aim to be a positive social presence in every community where we work. We promote basic human rights by following applicable local labor laws and we do not allow child or forced labor by our company, vendors of suppliers. We also follow all applicable wage and hour laws, including minimum wage, overtime and maximum hour rules.

Organizational Structure and Supply Chains

This statement covers the activities of Rochester Electronics:

Rochester Electronics is the largest continuing source manufacturer of semiconductors in the world. With product licensing from leading manufacturers such as Analog Devices, Altera, Cypress, Fairchild, Freescale, Infineon, Intel, NXP, Renesas and Texas Instruments, Rochester continues to manufacture and distribute mature products. For industrial, transportation and hi-reliability markets, this extension of product life is critical for long term production and maintenance. With over 100,000 products and 15 billion units in stock, no other company compares to our selection, capabilities or solutions.

The organization currently operates in the following countries:

  • St. Neots, Cambridgeshire

The following is the process by which the company assesses whether activities or countries are high risk in relation to slavery or human trafficking:

  • The Group confirms that prior to any supplier being included on our supply chain they have policies and procedures that are congruent with our intention to combat slavery and human trafficking.
  • If suppliers do not have their own Modern Slavery policy, we will make our policy available and obtain assurances of the supplier’s commitment to follow prior to supply commencing.
  • If, after supply commences, we believe there is an actual breach or risk of breach, we will investigate this following our Complaints & Serious Untoward Incident Policy.

Responsibility

Responsibility for the Rochester Electronics, LLC. anti-slavery initiatives are as follows:

Policies

In addition to the Modern Slavery policy, there are several other Group policies that are used to support the intention of combating slavery and human trafficking and identifying risk. The organization operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing Policy:

Rochester Electronics encourages its employees to report improper activities in the workplace and will protect employees from retaliation for making any such report in good faith. Employees have the right to report, without suffering retaliation, any activity by Rochester Electronics or a Rochester Electronics employee that the employee reasonably believes violates any state or federal law. An employee who suspects a problem with legal compliance is required to report the situation(s) to the Human Resources Manager. Employees may also report information regarding possible unlawful activity to an appropriate government or law enforcement agency. Any employee who believes he/she has been retaliated against for whistleblowing may file a complaint with Human Resources.

Code of Conduct:

Employee conduct should be directed primarily by good sense and adherence to the Company’s basic tenets: integrity, respect for the individual, cooperation, and building a winning team. No set of policies can anticipate every instance when proper conduct might become an issue, so the Company relies on you to use your best judgment before acting in any given situation. The Company expects you to maintain the highest standards of ethical conduct in every business relationship --with colleagues, customers, vendors and even our competitors.

Risk Assessments:

An initial risk assessment is completed with a new supplier; confirming adherence to policy intent and new employees/temporary worker recruitment and vetting process. Scheduled audits are completed to identify risks. At any time where a breach or potential breach is identified, either internally or in the supply chain, it is reviewed and corrective action is taken.

Due Diligence:

Rochester Electronics, LLC. undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Rochester Electronics, LLC. due diligence and reviews include assessing the supply chain broadly to assess productor geographical risks of modern slavery and human trafficking in areas which may include but not limited to;

  • Evaluating the modern slavery and human trafficking risks of each new supplier;
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • Conducting supplier audits or assessments with a focus on slavery and human trafficking where general risks are identified;
  • Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans to include specific amendments to be made and adhered to;
  • Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking;
  • Utilizing the use of available databases, to check suppliers for labor standards, compliance in general, and modern slavery and human trafficking; and
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the suspension or termination of the business relationship and reporting to the authorities as appropriate.

Training:

This policy will be communicated to all employees and distributed during new hire orientation. Employees are required to acknowledge this policy yearly.