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Lenovo Anti-Slavery and Human Trafficking Statement
August 2022
This statement confirms the steps Lenovo has taken during Fiscal Year (FY) 2021/22 to meetthe requirements of Section 3 of the California Transparency in Supply Chains Act of2010, the United Kingdom (UK) Modern Slavery Act (MSA) 2015, Chapter 30, Part 6,
Provision 54 and the Australia Modern Slavery Act 2018. This statement is prepared inaccordance with the UN Guiding Principles on Business and Human Rights. In thisdocument, Lenovo confirms the steps taken to identify, prevent, mitigate and account for therisk of slavery and human trafficking in its business and its supply chain and actions that
may be taken to remediate any known adverse impacts. This statement covers the activities
of Lenovo and Motorola Mobility.
For the purposes of Part 2 of the Australian Modern Slavery Act 2018, this Statement ismade on behalf of Lenovo (Australia & New Zealand) PTY Limited (ABN 70 112 394 411),
Lenovo Global Technology (Australia & New Zealand) PTY LTD (ABN 90 614 012 985),
and Motorola Mobility Australia PTY. LTD. (ABN 86 139 208 361).
For the purposes of Chapter 30, Part 6, Provision 54 of the U.K. Modern Slavery Act 2015,
this statement is made on behalf of Lenovo Global Technology UK Limited (10219781),
Lenovo Technology (United Kingdom) Limited (04912819), Motorola Mobility UK Ltd.
(06969556), TTPCom Limited (03475732), TTP Communications Limited (03962172),
Motorola Mobility Holdings UK Limited (10696969), Lenovo Connect (United Kingdom)
Co. Limited (10626988), and Channel Solutions and Services Ltd. (11786337).
In the process of developing this statement we consulted the relevant companies we own orcontrol listed above.
Organization and Structure
Lenovo is a global technology company with 75,000 employees worldwide, operating in 180
markets around the world. Lenovo has adopted a new business group structure effective forthe year ending March 31, 2022. Lenovo has formed the Solutions and Services Group (SSG)
in addition to the existing Intelligent Devices Group (IDG) and Infrastructure Solutions
Group (ISG), previously named Data Center Group (DCG).

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Lenovo’s business groups are supported by corporate level functions, including global
supply chain and environmental, social, and governance (ESG) teams. Further information
about Lenovo, its management, investor relations, and corporate ESG commitments can befound at https://www.lenovo.com.
Corporate Policies
Lenovo is committed to ethical corporate citizenship and promoting strong ESG
performance in its activities. Lenovo demonstrates these commitments through transparent
and responsible actions driven by its values. These values respect and are informed by thoseof its stakeholders, including the communities with which we interact. Lenovo expects all
its employees, as well as contractors and consultants who perform work on Lenovo’s behalf,
to report immediately any suspected violations of laws, regulations, the Lenovo Code of
Conduct, or Lenovo policies. Lenovo strives to attain the highest level of ethical integrity
and to this end conducts worldwide internal audits that independently validate controls andinvestigate abuses. Its activities are guided by the corporate policies and programs noted
below.
Code of Conduct
Lenovo’s Code of Conduct includes requirements for its employees to act in an ethicalmanner, including expectations for reporting unlawful or inappropriate conduct, respecting
and protecting intellectual property and treating each other with dignity and respect.
Focus on Employee Welfare
Providing a safe and healthy working environment is core to Lenovo’s operating principles.
Lenovo equips employees with products and equipment that are safe for use. Lenovo also
focuses on implementing and improving processes and controls for preventing work-related
accidents, injuries and illnesses. Lenovo’s Corporate Policy #3 - Responsibility for
Employee Health and Safety focuses on creating and maintaining a workplace that provides
for the health and safety of all employees and reinforces the importance it places on this at
every location in which Lenovo does business. Lenovo’s Corporate Policy #17 - Workplace
Violence emphasizes that all employees, contractors, and guests are expected to refrain fromviolence, harassment, intimidation, or coercion.
Commitment to Diversity and Non-Discrimination
Lenovo’s Code of Conduct and the Corporate Policy #2 - Commitment to Diversity andNondiscrimination provide for a work environment free of discrimination and harassment
based on race, color, gender, religion, age, nationality, social or ethnic origin, sexual
orientation, gender identity or expression, marital status, pregnancy, disability or veteranstatus.

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Sustainability Policy
Lenovo’s Sustainability Policy states its commitment to ethical corporate citizenship andpromoting ESG topics in all of its activities. Every organization must support this policy, andeach manager, employee and any contractor performing work on behalf of Lenovo bears a
personal responsibility to abide by the following principles:
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Provide a safe, healthy, and enriching working environment for its employees
Be a fair and responsible member of the communities in which Lenovo operates
Work with its supply chain to ensure that Lenovo's values and expectations are upheld
Extend the benefits of Lenovo experience, products, and successes to the communities
in which Lenovo operates and contributes to their development
As employees and as a company, be ethical and responsible citizens

Human Rights Policy
Lenovo’s Corporate Policy #22 - Human Rights states its support for universal human rights,
including those identified in the United Nations Declaration on Human Rights, and commits
to extending these rights to its employees and others directly or indirectly employed in its
supply chain. This policy applies to Lenovo’s worldwide operations and those of its supply
chain. Every Lenovo organization must support this policy including the following
commitments:
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Conduct business in accordance with the United Nations Declaration of Human Rights
and the principles of the United Nations Global Compact, and extend thoserequirements to all suppliers doing business with Lenovo
Perform due diligence across the value chain to identify risks and avoid complicity inhuman rights violations
Provide access to grievance mechanisms, investigate allegations, and escalate known
cases of human rights abuse to senior leadership
Integrate training and accountability for respecting human rights across the businessand the supply chain
Engage internal and external stakeholders to address common challenges and advancehuman rights practices through continuous improvement
Operate legally and ethically in each country where Lenovo does businessAll corporate strategies, practices, and guidelines, as well as supplier requirements, must
support this commitment to human rights. Concerns about possible human rights violations
must be reported to Lenovo management, who shall take prompt corrective action.
Supplier Code of Conduct
Lenovo expects its suppliers to meet the highest standards of responsible sourcing. Lenovo’s
standard contractual terms and conditions for production suppliers require compliance with
Lenovo’s Supplier Code of Conduct. Conformance to Lenovo’s Supplier Code of Conduct3

is assessed as part of the procurement evaluation and decision-making process. The key
elements of the Lenovo Supplier Code of Conduct are as follows:
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Procurement Values and Ethical Dealings
Conflicts of Interest and Business Integrity
Human Rights
Supply Chain Working Conditions
Climate Change
Environmental Aspects
Responsible Sourcing of Raw Materials
Non-Discrimination and Non-Retaliation
Supplier Diversity
ESG Reports, Assessments and Product Certifications
Supply Chain Due Diligence
Supplier Grievance and Concern Notification

International Standards and Certifications
Lenovo supports the work of many independent, non-governmental internationalorganizations which bring together experts to share knowledge and develop voluntary,consensus-based, market relevant international standards that support innovation andprovide solutions to global challenges.
Lenovo maintains third-party certification for its internal manufacturing operations to thefollowing standards and encourages its production suppliers to maintain certifications tothese standards.
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ISO 9001 Certification for Quality Management Systems
ISO 14001 Certification for Environmental Management Systems
ISO 45001 Certification for Occupational Health & Safety

Responsible Business Alliance (RBA)
Lenovo believes in the benefits of having an industry standard supply chain code of conduct
and therefore implements the RBA Code of Conduct internally within Lenovo global
manufacturing locations and externally across its supply chain. Lenovo has been a member
since 2006 and supports RBA’s efforts to ensure that working conditions in the electronics
industry supply chain are safe, workers are treated with respect and dignity, and that business
operations are environmentally responsible, do not fund conflict and are conducted ethically.
Identification of Risk
Lenovo's procurement activities include both direct (supporting product production) andindirect (serving internal operations) procurement. With regards to Lenovo’s risk for humantrafficking and slavery, the risk is largely in the external supply chain for direct procurement.
This risk exists because many suppliers have access to large, lower-skilled labor pools that4are vulnerable to exploitation. The risk also exists in other tiers of the supply chain, fromcomponent manufacturers, smelters, and refiners to the miners of raw materials.
Lenovo’s indirect procurement activities serve its internal operations and have a smaller riskin that they represent a small fraction of its overall procurement spend, involve supplierswith higher skilled employees, and have significantly fewer supporting tiers.
With respect to Lenovo internal manufacturing locations, it has direct control over the
management and labor force of these operations and believes them to be of very low risk forhuman trafficking and slavery abuses. Lenovo’s line management conducts self-audits, andLenovo Corporate Internal Audit conducts independent audits. Additionally, its
manufacturing sites receive RBA independent third-party audits with RBA-approved
auditors and are very visible to Lenovo’s global management team.
Supply Chain Due Diligence
Responsible sourcing is embedded into Lenovo’s supply chain management businessprocesses. Its Supplier Sustainability Scorecard includes metrics on suppliers’ adherence to
its Conflict Minerals expectations. This scorecard is used by Lenovo executives in business
reviews with suppliers and provides a key input into business decisions.
Lenovo actively participates in Responsible Minerals Initiative’s (RMI) programs. RMI’s
tools and guidance documents help Lenovo address responsible sourcing risks for minerals.
Lenovo supports China smelters engagement through the China SET (Smelter EngagementTeam) within the RMI and by serving as the SPOC (Single Point of Contact) for both 3TG
and Cobalt smelters or refiners in Asia. Lenovo continued to drive its suppliers to discontinue
the use of non-conformant smelters. Lenovo also directly engaged with smelters and refiners
to undergo Responsible Minerals Assurance Process (RMAP) audits.
Lenovo directly validates supplier compliance with the RBA Code of Conduct, which
includes conflict minerals. This includes formal annual supplier Self-Assessments andbiennial supplier audits of compliance to the RBA Code of Conduct with independent RBA
approved third party auditors and reporting with RBA tools. Corrective Action Plans arereceived for all audits.
Additional Actions
In order to further enhance our programs in this area, Lenovo took the following additional
actions:
Real-time reporting of working hours and days off for many suppliersContinued efforts to encourage more suppliers to achieve RBA Silver, Gold, Platinum,or Factory of Choice status
Reduced average number of suppliers’ RBA Priority findings down from 0.5 to 0.1
findings per RBA VAP audit
Implemented EcoVadis assessment tools to assess suppliers
Improved cobalt due diligence processes
5Prevention and Mitigation of Risk
Lenovo implements multiple measures designed to minimize the risk of slavery and humantrafficking and drive social responsibility within its business and its supply chain.
Responsible Partners
Lenovo generally does business with large international and national suppliers who havetheir own corporate ESG programs. Specifically:• 76% of its procurement spend is with formal RBA Members• 96% of its procurement spend is with ISO 9001, ISO 14001, and OHSAS 18001 or ISO
45001 certified companies who also issue public Corporate ESG Reports
RBA Code of Conduct Implementation and Verification
Lenovo encourages its suppliers to comply with the RBA Code of Conduct and to ensurethat supplier working conditions are socially, environmentally, and ethically responsible.
The labor section of the RBA Code of Conduct specifically addresses forced labor, childlabor and human trafficking concerns.
RBA membership requirements call for an annual risk assessment on at least 80% of Tier 1
direct manufacturing suppliers by spend and annual audits on 25% of those identified as highrisk. Lenovo’s implementation exceeds this requirement. Lenovo directly validates
compliance for approximately 95% of its procurement spend with self-assessments andaudits, which includes many critical Tier 2 and Tier 3 suppliers who are also Tier 1 suppliers.
Lenovo requires these suppliers to:
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Comply with Lenovo’s Supplier Code of Conduct
Conduct a risk assessment using the RBA Self-Assessment Questionnaire (SAQ)
annually and report the results in the RBA online tool
Perform assessments at a supplier corporate level and key site level
Conduct biennial, independent, third-party RBA audits with RBA-approved auditors
Document audit reports and corrective action plans
Confirm closure of action plans
Require upstream suppliers to comply with the RBA Code of Conduct

This validation and audit results reporting process forms the basis for Lenovo’s evaluationof the effectiveness of its programs.
Supplier Penalties & Credits
Supplier ESG performance is included in Lenovo’s quarterly supplier report cards. Its top
100 suppliers, covering over 95% of its procurement spend, are scored against 29 key
indicators across the RBA Code of Conduct elements and performance, environmental
impact goals and reductions, conflict minerals efforts, and ESG reporting. Supplier ESG

6performance is used as an overall multiplier against the aggregate cost, quality, delivery,
technology, and service scores and can significantly influence a supplier’s overall rating.
Supplier Relationship Management
Lenovo also has a Supplier Advisory Council (LSAC) where senior executives from Lenovo
and its top 42 suppliers (constituting about 80% of its procurement spend) meet semiannually.
Accounting for Risk
To verify whether adverse human rights impacts are being prevented, or resolved if theyoccur, Lenovo is tracking the effectiveness of its programs and reports on them internallyand externally. Key reporting on the supply chain includes the following examples.
Internal Reporting & Metrics
ESG performance is measured and reported to senior procurement management as follows:•

RBA Monthly Reporting:– Number of suppliers in the validation program– Percent on-time self-assessments; numbers of late self-assessments and those due
within 3 months– Percent on-time audits, number of late audits and number due within 6 months– Number of late corrective action reports– Number of open action items– Number of suppliers with late working hours / time off quarterly validation reports– Newsletter of current and upcoming events, programs, and issues– Full supporting detail on each issue and individual supplier status– Working hours and time off is also reported by outsourced manufacturing suppliers
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RBA Quarterly Reporting– Overall YTD audit scores and yearly trends– By segment YTD audit scores (labor, environmental, OH&S, ethics, andmanagement systems)– Average number of Priority Findings and average number of Major Findings– Full supporting detail of each audit finding

External Reporting
Further details are available publicly within Lenovo’s ESG Report along with otherinformation on its Sustainability Resources pages.

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Training and Capability Building
Lenovo conducts several education and communication activities throughout the year for
Global Supply Chain employees and suppliers, which may include:
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Monthly newsletters
Annual ESG training
Annual training on Supplier Report Card penalties and credits
Annual training on Supplier Code of Conduct
Annual Environmental Impact training
Annual Responsible Sourcing of Raw Materials training

External Capability Training
As noted above, a substantial portion of Lenovo’s suppliers are large international andnational suppliers with existing and substantial ESG programs, so the need for capability
building is lessening. Furthermore, the RBA has a readily available comprehensive Learning
Academy with modules on all their programs, guidance and tools. In addition to this Lenovo
provides:• Ad-hoc education as necessary• Semi-annual communications letters on the RBA, environmental impact, conflictminerals, Supplier Code of Conduct expectations and program efforts
Effectiveness
Lenovo has been a member of RBA since 2006. In support of this program, all Lenovo
owned facilities as well as 95% of our suppliers by spend are required to undergo biennial
RBA audits. In 2021 RBA introduced version 7.0 of their Code of Conduct. Lenovo has
adopted these new standards and requires our suppliers to comply with the latest version of
the RBA Code of Conduct. During audits conducted by independent auditors to the RBA
Code of Conduct, no instances of forced labor were found at any Lenovo production facility
nor at any of the audited supplier facilities.
Lenovo’s average score for RBA Validated Assessment Program (VAP) audits conducted
over the period of FY 2020/21 and FY 2021/22 was 170.8 vs the industry average of 128.0
during this same time period. During FY2020/21 and FY2021/22, three audited Lenovo
facilities were awarded platinum status, one was awarded gold, all others were awarded
silver status, and all Lenovo owned facilities achieved Factory of Choice status.
In addition, Lenovo implemented mandatory education on forced labor prevention with its
325 sourcing managers of the global business groups. Lenovo is an active member of several
RBA workgroups.

8Remediation of Adverse Impacts
In the event of supplier non-conformance to ESG requirements, several actions may takeplace, including:
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Immediate discontinuation of business for serious violations
Track all audit findings to closure and require supporting evidence whenever possible
Penalize the supplier in the quarterly supplier report card score with the ESG multiplier
Senior Procurement management engagement with the supplier
Executive Lenovo management engagement with the supplier

Ultimately poor ESG performance results in lower business volume and eventual
discontinuation of business. It is Lenovo’s experience that good ESG performance often
comes hand-in-hand with good cost, quality, delivery and other performance attainment
measures and therefore is a good business performance indicator. Suppliers with strong ESG
performance coupled with strong performance overall are rewarded with increased businessvolume and continuation of the business relationship.
This disclosure summarizes the efforts Lenovo has taken in its own business, as well as its
suppliers, to eradicate slavery and human trafficking from its supply chain and promote
human rights and employee welfare globally. This document has been reviewed by its Boardof Directors and will be published externally.

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Director Signature
Approved by Lenovo Board of Directors

Director Name: Yang Yuanqing

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