Modern Slavery
Statement

Modern Slavery Statement
For financial year ending 31 March 2020

As a company whose mission is to create transformational technology as a force for good,Arm welcomes the requirements of Section 54 of the UK Modern Slavery Act 2015.
The transparency that the Act seeks to encourage is in line with the way we operate at
Arm as reflected by our Code of Conduct and our company culture.

About Arm
Arm technology is at the heart of a computing and connectivity revolution that istransforming people’s lives and how businesses operate. We design energy-efficient
processors and related technologies to deliver the intelligence in applications ranging fromthe sensor to the smartphone to the supercomputer. This technology, combined with ourInternet of Things (IoT) software and device management platform, enables customers
to derive real business value from their connected devices. Together with our 1,000+technology partners, we are at the forefront of designing, securing, and managing all areas ofcomputing from the chip to the cloud. We are headquartered in Cambridge UK and are partof the SoftBank GroupCorp (SBG).
This statement covers Arm Limited and Arm Inc., and their group companies.

1Our Values and Policies
At Arm, Corporate Responsibility is underpinned by:
Our Code of Conduct“Arm’s global reputation relies not only on delivering leading technology but also onupholding a culture of responsibility supported by our actions as an ethical company.
A high standard of ethics and good governance are essential to supporting a successful,growing business and maintaining the trust of our partners and employees.”– Simon Segars, CEO
The Arm Code of Conduct supports how we manage our business in a responsible
way consistent with our Core Beliefs1 . It translates legal and regulatory requirements
into the behaviors that we expect of all Arm employees, directors and agents and guides
us to make ethical decisions that promote trust. Everyone at Arm is required to 		demonstrate on annual basis that they have read and understand the Code of Conduct;and completed the mandatory Code of Conduct training.
Our Supplier Code of Conduct
Arm’s Supplier Code of Conduct (Supplier Code) describes our corporate responsibility
requirements from suppliers that provide products or services to Arm and its subsidiaries.
Arm requires suppliers and their employees to commit to this Code as a condition ofdoing business.
Our Supplier Diversity Project
Arm is creating a Supplier Diversity program where US suppliers to Arm will be required
to define their federally prescribed diversity category. Arm will then analyze and review
the supplier results to determine the level of Arm’s supplier diversity spend. As theprogram matures Arm expects to set annual supplier diversity spending goals.
Our Sustainability Strategy
Arm has signed the Universal Declaration of Human Rights and our Human Rights Policy
is incorporated in our Code of Conduct.
Arm participates in the UN Global Compact (UNGC), which asks companies to embrace,
support and enact within their sphere of influence a set of core values in the areas ofhuman rights, labour standards, the environment and anti-corruption.
We are also a member of UNGC LEAD. LEAD is a group of 33 multinationals that havebeen chosen out of the 13,698 UNGC members because of their history of engagementwith the UN and commitment to corporate responsibility. We are represented on boththe Global Compact LEAD and UK network’s advisory board, keeping us in touch withour peers and informing us on how we can contribute to sustainability in our immediateoperations, our ecosystem and beyond. As a LEAD company, we submit an annualCommunication on Progress against the 21 advanced criteria that support the ten Global
Compact principles. The advanced criteria include sections on human rights, eliminationof forced and compulsory labour, abolition of child labour and the elimination of 		discrimination. For details of our reporting on these areas, please see theCorporate Responsibility Report Supplement.
2Arm has been a supporter of the UK Living Wage Campaign since 2015. The Living
Wage is a voluntary higher rate of base pay (based on the cost of living) which we, as anaccredited Living Wage Employer, have committed to paying all our direct employees
as a minimum.

Our Supply Base: Assessing and Managing Risk
As an IP company, we do not have an extensive tiered supply base for the provision of raw
materials coming into the business. We do, however, purchase a wide range of goods andservices from approximately 2,800 diverse suppliers who operate globally, regionally,and locally. Our suppliers provide products and services to Arm’s IP and IoT software anddevice management businesses and the enterprise functions. This product and service
portfolio includes Engineering Technology, Cloud Services, Enterprise IT infrastructureand services; and Corporate Services, including people and employee services, property andfacilities management, consulting, finance, accounting and tax, legal, and marketing services.
Our suppliers help our people to innovate and operate successfully. We attach great
importance to the supply side of our value chain.
In 2014, we added requirements relating to responsible labour practices into our standard
supplier Terms of Business. These referred to the requirement that suppliers respect andpromote the rights set out in the International Labour Organisation’s International (ILO)
Labour Standards and the provisions of the United Nations’ Universal Declaration of HumanRights in relation to both its personnel and its suppliers. In 2018, we strengthened theserequirements by reference to the UK Modern Slavery Act 2015 specifically, i.e. suppliers
are required to conduct proper checks on any agency person and Arm reserves the right torequire the supplier to remove from performance of the work any of the supplier’s officers,
employees, agents or subcontractors whom Arm believes to be engaging in any Modern
Slavery Practice, and take such action as Arm considers necessary to ensure Arm and thesupplier fully comply with all applicable laws relating to modern slavery.
In addition, the Company manages its risk in this area through a comprehensive third-party
risk assessment process (Assessment) where one of the three most significant goals is tomeasure risk as relates to Anti-Slavery and Human Trafficking. The Assessment, conductedby the Company with assistance from a large international accounting firm, ensures thatArm’s compliance objectives in this space are aligned to its business goals. The Assessment,
which is necessarily iterative in nature, is part of Arm’s overall compliance plan and its
repeated conduct is part of the entity’s long-term plan to adjust to the continuously
changing external landscape and associated changes in company strategy.
Since 2015, we have been operating against our Supplier Code (or an acceptable equivalent).
As part of our standard new supplier onboarding process, suppliers are required to confirm
that they comply with our Supplier Code, which sets out our key expectations of ourSuppliers. In relation to Employment Standards, these are:Child labour
We are opposed to the use of any form of child labour or practices that inhibit the developmentof children. Suppliers must comply with all child labour laws and should not employ anyone
under the age of 15, or where it is higher, the mandatory school leaving age in the local country.

3Forced or involuntary labour
Suppliers must not participate in human trafficking; use forced, involuntary, or slave labour;or purchase materials or services from companies using forced, involuntary, or slave labour.
They must be able to certify that materials included in their products comply with the slavery
and human trafficking laws of the country or countries in which they do business.
Compensation and working hours
Suppliers must comply with the applicable wage and hour labour laws and regulations 		
governing employee compensation and working hours. Suppliers should conduct operations inways that limit overtime to a level that ensures a humane and productive work environment.
Diversity and equality

Suppliers should aim to provide equality of opportunity and treatment regardless ofrace, colour, gender, religion, nationality, sexual orientation, age, or disability.
Suppliers are expected to support equal pay for work of equal value. Suppliers must
oppose discrimination or intimidation towards employees including all forms or threats ofphysical and psychological abuse.
For more information on our Supplier Code of Conduct, please go to suppliers.
Further, we expect our suppliers to:• implement or maintain, as applicable, a management system that facilitates 		
compliance with the Supplier Code and with the law, and identifies and mitigates
related operational risks while facilitating continuous improvement.
• have a process to communicate the Supplier Code requirements to next-tiersuppliers and to monitor their compliance to the Supplier Code and all applicablelaws and regulations.
• assist us in enforcing the Supplier Code by communicating its principles to theirsupervisors, employees, and suppliers.
The Supplier Code includes the details of a whistle-blower hotline for confidential reportingof violations of the Supplier Code. Non-compliance within our supply base will be reviewed
on a case-by-case basis by our Procurement and/or Legal Compliance team, with action to betaken as appropriate.

Next Steps
As we grow, we continue our focus on maturing our centre-led procurement organisation,processes, controls, performance, risk management and general practices. Central to theaforementioned growth is continuous evolution in our supplier performance and relationshipmanagement capabilities, which enable us to be vigilant and actively consider steps that we cantake to mitigate key risks such as modern slavery and human trafficking.
We continue to work with suppliers to ensure our approach to supplier management andmonitoring of suppliers against Arm’s Code of Conduct evolves and is effective.
We continue our procurement digitalisation journey, recently implementing an e-procurement
solution, SAP Ariba. This software gives greater visibility of the supply base and spend that may be
at risk for modern slavery issues in an evolving landscape.

4We look to create a Supplier Diversity program which will monitor and measure Arm’s US supplier
diversity spending. Setting supplier diversity spending goals is emerging as one of the tenants ofour program.
In the next financial year, we will be rolling out live training and workshops on supply basecompliance issues, including modern slavery and human trafficking, to relevant stakeholders.
We will also conduct a refresh of our Supplier Code. This will provide us with the opportunity toformally add in our expectation, as a UK Living Wage Employer, that our suppliers meet national
level salary standards as a minimum and best practice standard as a preference.
The Arm Board of Directors approved this statement on 23- September 2020.
Please direct any questions on this statement to Carolyn Herzog, General Counsel andChief Compliance Officer at legalethics@arm.comSimon Segars, Chief Executive Officer5