January 1, 2024
SILICON LABS SUPPLIER CODE OF CONDUCTSilicon Labs is committed to the highest standard of product quality and business integrity in its
dealing with Suppliers and ensuring that working conditions in our supply chain are safe, thatworkers are treated with respect and dignity, and that manufacturing processes are environmentallyand socially responsible.
To ensure our relationships with Suppliers meet and support these expectations, Silicon Labs has
adopted the Responsible Business Alliance (RBA) Code of Conduct as documented below. Silicon Labs
requires its Suppliers to acknowledge and support this Supplier Code of Conduct or another industrystandard code of conduct substantially similar in all material aspects and to conform to its standards
and provisions as documented in detail below.
Fundamental to adopting the Code is the understanding that a business, in all of its activities, must
operate in full compliance with the laws, rules and regulations of the countries in which it operates.
The Code encourages Suppliers to go beyond legal compliance, drawing upon internationally recognized
standards, in order to advance social and environmental responsibility and business ethics.
The Code is made up of five sections. Sections A, B, and C outline standards for Labor, Health and
Safety, and the Environment, respectively. Section D adds standards relating to business ethics;
Section E outlines the elements of an acceptable system to manage conformity to this Code.
For purposes of this Code of Conduct, “Supplier” means any company, corporation or other entitythat sells, or seeks to sell direct material goods or services to Silicon Labs, including any of its
subsidiaries. “Supplier” includes all of an entity’s employees, agents and other representatives. SiliconLabs will consider a Supplier’s compliance with another industry-standard code of conduct aseffective compliance with the RBA Code of Conduct as long as such code of conduct is substantiallysimilar in all material aspects.
The current version of the RBA Code of Conduct is v8.0. Future revisions of the RBA Code of Conduct
will be deemed incorporated into the Silicon Labs Supplier Code of Conduct.

A.

LABOR

Suppliers are committed to uphold the human rights of workers, and to treat them with dignity andrespect as understood by the international community. This applies to all workers including temporary,migrant, student, contract, direct employees, and any other type of worker. The recognized standards,
as set out in the References, were used in preparing the Code and may be useful sources of additional
information.
The labor standards are:1)

Prohibition of Forced Labor

Forced labor in any form, including but not limited to, bonded (including debt bondage) or indentured labor,
involuntary or exploitative prison labor, slavery or trafficking of persons is not permitted. This includes
transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion,1

abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of
movement in the facility in addition to unreasonable restrictions on entering or exiting company- provided
facilities including, if applicable, workers’ dormitories or living quarters. As part of the hiring process, allworkers must be provided with a written employment agreement in their native language, or in a language
the worker can understand, that contains a description of terms and conditions of employment. Foreign
migrant workers must receive the employment agreement prior to the worker departing from his or her
country of origin and there shall be no substitution or hange(s) allowed in the employment agreement upon
arrival in the receiving country unless these changes are made to meet local law and provide equal or better
terms. All work shall be voluntary, and workers shall be free to leave work at any time or terminate theiremployment without penalty if reasonable notice is given, which shall be clearly stated in workers’
contracts. Suppliers shall maintain documentation on all leaving workers. Employers, agents, and subagents’ may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, suchas government-issued identification, passports, or work permits. Notwithstanding the foregoing, employers
can only hold documentation if necessary to comply with the local law. In this case, at no time shall workers
be denied access to their documents. Workers shall not be required to pay employers’ agents or sub-agents’recruitment fees or other related fees for their employment. If any such fees are found to have been paid
byworkers, such fees shall be repaid to the worker.

2)Young Workers

Child labor shall not be used in any stage of manufacturing. The term “child” refers to any person under theage of 15, or under the age for completing compulsory education, or under the minimum age for
employment in the country, whichever is greatest. Workers under the age of 18 (Young Workers) shall not
perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Suppliers
shall ensure proper management of student workers through proper maintenance of student records,
rigorous due diligence of educational partners, and protection of students’ rights in accordance withapplicable laws and regulations. Suppliers shall implement an appropriate mechanism to verify the age ofworkers. The use of legitimate workplace learning programs, which comply with all laws and regulations, issupported. Suppliers shall provide appropriate support and training toall student workers. In the absence of
local law, the wage rate for student workers, interns, and apprentices shall be at least the same wage rate asother entry-level workers performing equal or similar tasks. If child labor is identified, assistance/remediation
shall be provided.

3)

Working Hours

Working hours shall not exceed the maximum set by local law. Further, a workweek shall not be more than
60 hours per week, including overtime, except in emergency or unusual situations. All overtime shall bevoluntary. Workers shall be allowed at least one day off every seven days.

4)

Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating tominimum wages, overtime hours and legally mandated benefits. All workers shall receive equal pay for
equal work and qualification. Workers shall be compensated for overtime at pay rates greater than regularhourly rates. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period,
2

workers shall be provided with a timely and understandable wage statement that includes sufficient
information to verify accurate compensation for work performed. All use of temporary, dispatch andoutsourced labor shall be within the limits of the local law.

5)

Non-Discrimination/Non-Harassment/Humane Treatment

Suppliers shall commit to a workplace free of harassment and unlawful discrimination. There shall be noharsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse,
corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; noris there to be the threat of any such treatment. Companies shall not engage in discrimination or harassment
based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity or national
origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status,
protected genetic information or marital status in hiring and employment practices such as wages,
promotions, rewards, and access to training. Disciplinary policies and procedures in support of theserequirements shall be clearly defined and communicated to workers. Workers shall be provided withreasonable accommodation for religious practices and disability. In addition, workers or potential workers
should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could
be used in a discriminatory way. This was drafted in consideration of ILO Discrimination (Employment andOccupation) Convention (No.111).

6)

Freedom of Association and Collective Bargaining

Open communication and direct engagement between workers and management are the most effective
ways to resolve workplace and compensation issues. Workers and/or their representatives shall be able toopenly communicate and share ideas and concerns with management regarding working conditions andmanagement practices without fear of discrimination, reprisal, intimidation, or harassment. In alignment
with these principles, suppliers shall respect the right of all workers to form and join trade unions of theirown choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the right ofworkers to refrain from such activities. Where the right of freedom of association and collective bargaining
is restricted by applicable laws and regulations, workers shall be allowed to elect and join alternate lawful
forms of worker representations.

3

B.

HEALTH AND SAFETY

Suppliers recognize that in addition to minimizing the incidence of work-related injuries and illnesses, a safeand healthy working environment enhances the quality of products and services, consistency of production
and worker retention and morale. Suppliers also recognize that ongoing worker input and education are
essential to identifying and solving health and safety issues in the workplace.
The health and safety standards are as follows:1)

Occupational Health and Safety

Worker potential for exposure to health and safety hazards (chemical, electrical and other energy sources,
fire, vehicles, and fall hazards, etc.) shall be identified and assessed, mitigated using the Hierarchy ofControls. Where hazards cannot be adequately controlled by these means, workers shall be provided withappropriate, well-maintained, personal protective equipment, and educational materials about risks to themassociated with these hazards. Gender-responsive measures shall be taken, such as not having pregnant
women and nursing mothers in working conditions, which could be hazardous to them or their child and toprovide reasonable accommodations for nursing mothers.

2)

Emergency Preparedness

Potential emergency situations and events shall be identified and assessed, and their impact minimized by
implementing emergency plans and response procedures including emergency reporting, employee
notification and evacuation procedures, worker training, and drills. Emergency drills shall be executed at least
annually or as required by local law, whichever is more stringent. Emergency plans shall also include
appropriate fire detection and suppression equipment, clear and unobstructed egress, adequate exit
facilities, contact information for emergency responders, and recovery plans. Such plans and procedures shallfocus on minimizing harm to life, the environment, and property.

3)

Occupational Injury and Illness

Procedures and systems shall be in place to prevent, manage, track and report occupational injuries andillnesses, including provisions to encourage worker reporting, classify and record injury and illness cases,
provide necessary medical treatment, investigate cases and implement corrective actions to eliminate theircauses, and facilitate the return of workers to work. Suppliers shall allow workers to remove themselves fromimminent harm, and not return until the situation is mitigated, without fear of retaliation.

4)

Industrial Hygiene

Worker exposure to chemical, biological, and physical agents shall be identified, evaluated, and controlledaccording to the Hierarchy of Controls. When hazards cannot be adequately controlled, workers shall be
provided with and use appropriate, well-maintained, personal protective equipment free of charge. Suppliers
shall provide workers with safe and healthy working environments, which shall be maintained throughongoing, systematic monitoring of workers’ health and working environments. Suppliers shall provide
occupational health monitoring to routinely evaluate if workers’ health is being harmed from occupational4

exposures. Protective occupational health programs shall be ongoing and include educational materials about
the risks associated with exposure to workplace hazards.

5)

Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavyor repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks shall be identified,evaluated, and controlled.

6)

Machine Safeguarding

Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks, andbarriers shall be provided and properly maintained where machinery presents an injury hazard to workers.

7)

Sanitation, Food, and Housing

Workers shall be provided with ready access to clean toilet facilities, potable water and sanitary foodpreparation, storage, and eating facilities. Worker dormitories provided by the Supplier or a labor agent shallbe maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing
and showering, adequate lighting, and adequate conditioned ventilation, individually secured
accommodations for storing personal and valuable items, and reasonable personal space along withreasonable entry and exit privileges.

8)

Health and Safety Communication

Suppliers shall provide workers with appropriate workplace health and safety information and training in thelanguage of the worker or in a language the worker can understand for all identified workplace hazards thatworkers are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physicalhazards. Health and safety related information shall be clearly posted in the facility or placed in a location
identifiable and accessible by workers. Health information and training shall include content on specific risks
to relevant demographics, such as gender and age, if applicable. Training shall be provided to all workers
prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise any health andsafety concerns without retaliation.

C.

ENVIRONMENT

Across all business functions, Suppliers recognize that environmental responsibility is integral to producing
world-class products. Suppliers shall identify the environmental impacts and minimize adverse effects on thecommunity, environment, and natural resources, while safeguarding the health and safety of the public.
The environmental standards are as follows:1)

Environmental Permits and Reporting5All required environmental permits (e.g. discharge monitoring), approvals, and registrations shall beobtained, maintained, and kept current and their operational and reporting requirements shall be followed.

2)

Pollution Prevention and Resource Reduction

Emissions and discharges of pollutants and generation of waste shall be minimized or eliminated at thesource or by practices such as adding pollution control equipment; modifying production, maintenance, andfacility processes; or by other means. The use of natural resources, including water, fossil fuels, minerals, andvirgin forest products, shall be conserved by practices such as modifying production, maintenance and facility
processes, materials substitution, re-use, conservation, recycling, or other means.

3)

Hazardous Substances

Chemicals, waste, and other materials posing a hazard to humans or the environment shall be identified,labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, anddisposal. Hazardous waste data shall be tracked and documented.

4)

Solid Waste

Suppliers shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or
recycle solid waste (non-hazardous). Waste data shall be tracked and documented.

5)

Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances,and combustion byproducts generated from operations shall be characterized, routinely monitored,
controlled, and treated as required prior to discharge. Ozone- depleting substances shall be effectively
managed in accordance with the Montreal Protocol and applicable regulations. Suppliers shall conductroutine monitoring of the performance of its air emission control systems.

6)

Materials Restrictions

Suppliers shall adhere to all applicable laws, regulations, and customer requirements regarding theprohibition or restriction of specific substances in products and manufacturing, including labeling forrecycling and disposal.

7)

Water Management

Suppliers shall implement a water management program that documents, characterizes, and monitors water
sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination.
All wastewater shall be characterized, monitored, controlled, and treated as required prior to discharge or
disposal. Suppliers shall conduct routine monitoring of the performance of its wastewater treatment andcontainment systems to ensure optimal performance and regulatory compliance.
68)Energy Consumption and Greenhouse Gas Emissions

Suppliers shall establish and report against an absolute corporate-wide greenhouse gas reduction goal.
Energy consumption and all Scopes 1, 2, and significant categories of Scope 3 greenhouse gas emissions shallbe tracked, documented, and publicly reported. Suppliers shall look for methods to improve energy efficiency
and to minimize their energy consumption and greenhouse gas emissions.

D.

ETHICSTo meet social responsibilities and to achieve success in the marketplace, Suppliers and their agents shalluphold the highest standards of ethics including the following:

1)

Business Integrity

The highest standards of integrity shall be upheld in all business interactions. Suppliers shall have a zerotolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.

2)

No Improper Advantage

Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorized,
given, or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything ofvalue, either directly or indirectly through a third party, in order to obtain or retain business, direct businessto any person, or otherwise gain an improper advantage. Monitoring, record keeping, and enforcement
procedures shall be implemented to ensure compliance with anticorruption laws.

3)

Disclosure of Information

All business dealings shall be transparently performed and accurately reflected on the Supplier’s businessbooks and records. Information regarding supplier’s labor, health and safety, environmental practices,business activities, structure, financial situation, and performance shall be disclosed in accordance withapplicable regulations and prevailing industry practices. Falsification of records or misrepresentation of
conditions or practices in the supply chain are unacceptable.

4)Intellectual Property

Intellectual property rights shall be respected. Transfer of technology and know-how is to be done in amanner that protects intellectual property rights, and customer and supplier information shall besafeguarded.

5)

Fair Business, Advertising and Competition

Standards of fair business, advertising, and competition shall be upheld.

7

6)

Protection of Identity and Non-Retaliation

Programs that ensure the confidentiality, anonymity, and protection of supplier and employee
whistleblowers1 shall be maintained, unless prohibited by law. Suppliers shall have a communicated process
for their personnel to be able to raise any concerns without fear of retaliation.

7)

Responsible Sourcing of Minerals

Suppliers shall adopt a policy and exercise due diligence on the source and chain of custody of the tantalum,tin, tungsten, gold, and cobalt in the products they manufacture to reasonably assure that they are sourced
in a way consistent with the Organisation for Economic Co-operation and Development (OECD) Guidance for
Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas or an equivalent andrecognized due diligence framework.

8)

Privacy

Suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone
they do business with, including suppliers, customers, consumers, and employees. Suppliers shall comply
with privacy and information security laws and regulatory requirements when personal information iscollected, stored, processed, transmitted, and shared.

1 Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public
official or official body.

8

E.

MANAGEMENT SYSTEMS

Suppliers shall adopt or establish a management system with a scope that is related to the content of thisCode. The management system shall be designed to ensure: (a) compliance with applicable laws,
regulations and customer requirements related to the supplier’s operations and products; (b) conformancewith this Code; and (c) identification and mitigation of operational risks related to this Code. It shall also
facilitate continual improvement.
The management system shall contain the following elements:

1)

Company Commitment

Suppliers shall establish human rights, health and safety, environmental and ethics policy statements
affirming Supplier’s commitment to due diligence and continual improvement, endorsed by executive
management. Policy statements shall be made public and communicated to workers in a language they
understand via accessible channels.

2)

Management Accountability and Responsibility

Suppliers shall clearly identify senior executive and company representative(s) responsible for ensuring
implementation of the management systems and associated programs. Senior management reviews thestatus of the management systems on a regular basis.

3)

Legal and Customer Requirements

Suppliers shall adopt or establish a process to identify, monitor and understand applicable laws,
regulations, and customer requirements, including the requirements of this Code.

4)

Risk Assessment and Risk Management

Suppliers shall adopt or establish a process to identify the legal compliance, environmental, health andsafety2, labor practice and ethics risks, including the risks of severe human rights and environmental
impacts, associated with Supplier’s operations. Suppliers shall determine the relative significance for eachrisk and implement appropriate procedural and physical controls to control the identified risks and ensure
regulatory compliance.

5)

Improvement Objectives

Suppliers shall establish written performance objectives, targets and implementation plans to improve theSupplier’s social, environmental, and health and safety performance, including a periodic assessment ofSupplier’s performance in achieving those objectives.

2 Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage facilities,
plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker housing/dormitories.

96)

Training

Suppliers shall establish programs for training managers and workers to implement Supplier’s policies,
procedures, and improvement objectives and to meet applicable legal and regulatory requirements.

7)

Communication

Suppliers shall establish process for communicating clear and accurate information about Supplier’s
policies, practices, expectations, and performance to workers, suppliers, and customers.

8)

Worker/Stakeholder Engagement and Access To Remedy

Suppliers shall establish processes for ongoing two-way communication with workers, their representatives,and other stakeholders where relevant or necessary. The process shall aim to obtain feedback on
operational practices and conditions covered by this Code, and to foster continuous improvement. Workers
shall be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation.

9)

Audits and Assessments

Suppliers shall conduct periodic self-evaluations to ensure conformity to legal and regulatory requirements,
the content of the Code, and customer contractual requirements related to social and environmental
responsibility.

10)

Corrective Action Process

Suppliers shall establish a process for timely correction of deficiencies identified by internal or external
assessments, inspections, investigations, and reviews.

11)

Documentation and Records

Suppliers shall create and maintain documents and records to ensure regulatory compliance and conformity
to company requirements along with appropriate confidentiality to protect privacy.

12)

Supplier Responsibility

Suppliers shall establish a process to communicate Code requirements to suppliers and to monitor suppliercompliance to the Code.

10