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                                                                                             Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007




Version 2.0.1 October 2007

ELECTRONIC INDUSTRY CODE OF CONDUCT


The Electronic Industry Code of Conduct outlines standards to ensure that working
conditions in the electronics industry supply chain are safe, that workers are treated with
respect and dignity, and that manufacturing processes are environmentally responsible.

Considered as part of the electronics industry for purposes of this Code are Original
Equipment Manufacturers (OEMs), Electronic Manufacturing Services (EMS) firms and
Original Design Manufacturers (ODMs) including contracted labor that may design,
market, manufacture and/or provide goods and services that are used to produce
electronic goods. The Code may be voluntarily adopted by any business in the electronics
sector and subsequently applied by that business to its supply chain and subcontractors.

To adopt the Code and become a participant (鈥淧articipant鈥?), a business shall declare its
support for the Code and seek to conform to the Code and its standards in accordance
with a management system as set forth in the Code.

For the Code to be successful, it is acknowledged that Participants should regard the code
as a total supply chain initiative. At a minimum, participants shall require its next tier
suppliers to acknowledge and implement the Code.

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
鹿countries in which it operates. The Code encourages Participants to go beyond legal
compliance, drawing upon internationally recognized standards, in order to advance
social and environmental responsibility.

The Electronic Industry Code Participants are committed to obtaining regular input from
stakeholders in the continued development and implementation of the Electronic Industry
Code of Conduct (EICC).

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 outlines the elements of
an acceptable system to manage conformity to this Code. Section E adds standards
relating to business ethics.

________________________________
1
The Code is not intended to create new and additional third party rights, including for employees


Page 1 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007




A. LABOR
Participants are committed to uphold the human rights of workers, and to treat them with
dignity and respect as understood by the international community.

Recognized standards such as the Universal Declaration of Human Rights (UDHR), Social
Accountability International (SAI) and the Ethical Trading Initiative (ETI) were used as
references in preparing the Code and may be a useful source of additional information.

The labor standards are:

1) Freely Chosen Employment
Forced, bonded or indentured labor or involuntary prison labor is not to be used. All
work will be voluntary, and workers should be free to leave upon reasonable notice.
Workers shall not be required to hand over government-issued identification,
passports or work permits as a condition of employment.
2) Child Labor Avoidance
Child labor is not to be used in any stage of manufacturing. The term 鈥渃hild鈥? refers
to any person employed under the age of 15 (or 14 where the law of the country
permits), or under the age for completing compulsory education, or under the
minimum age for employment in the country, whichever is greatest. The use of
legitimate workplace apprenticeship programs, which comply with all laws and
regulations, is supported. Workers under the age of 18 should not perform
hazardous work and may be restricted from night work with consideration given to
educational needs.
3) Working Hours
Studies of business practices clearly link worker strain to reduced productivity,
increased turnover and increased injury and illness. Workweeks are not to exceed
the maximum set by local law. Further, a workweek should not be more than 60
hours per week, including overtime, except in emergency or unusual situations.
Workers shall be allowed at least one day off per seven-day week.
4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws,
including those relating to minimum wages, overtime hours and legally mandated
benefits. In compliance with local laws, workers shall be compensated for overtime
at pay rates greater than regular hourly rates. Deductions from wages as a
disciplinary measure shall not be permitted. The basis on which workers are being
paid is to be provided in a timely manner via pay stub or similar documentation.



Page 2 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007



A. LABOR (con鈥檛.)
5) Humane Treatment
There is to be no harsh and inhumane treatment, including any sexual harassment,
sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of
workers: nor is there to be the threat of any such treatment.
6) Non-Discrimination
Participants should be committed to a workforce free of harassment and unlawful
discrimination. Companies shall not engage in discrimination based on race, color,
age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political
affiliation, union membership or marital status in hiring and employment practices
such as promotions, rewards, and access to training. In addition, workers or
potential workers should not be subjected to medical tests that could be used in a
discriminatory way.
7) Freedom of Association
Participants are to respect the rights of workers as established by local law to
associate freely on a voluntary basis, seek representation, join or be represented by
Works Councils, and join or not join labor unions and bargain collectively as they
choose. As provided by law, employees who become worker representatives shall
not be the subject of discrimination and shall have access to management and co-
workers in order to carry out their representative functions. Workers shall be able to
communicate openly with management regarding working conditions without fear of
reprisal, intimidation or harassment. In saying that worker rights are to be respected
as established or provided by local law, what HP means is that in countries that
have legal systems that support those rights, they are to be understood in the context
of the definitions, conditions and procedures that local law provides. However,
basic worker rights to open communication, direct engagement and humane and
equitable treatment must be respected even in countries where they are not given
meaningful legal protection. Where worker representation and collective bargaining
are restricted by law, participants are to facilitate open communication and direct
engagement between workers and management as alternative ways of ensuring that
workers鈥? rights, needs and views are considered and acted upon appropriately and
in good faith. Open communication and direct engagement between workers and
management are the most effective ways to resolve workplace and compensation
issues.




Page 3 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007




B. HEALTH and SAFETY
Participants recognize that the quality of products and services, consistency of production
and workers鈥? morale are enhanced by a safe and healthy work environment.
Participants also recognize that ongoing worker input and education is key to identifying
and solving health and safety issues in the workplace.
Recognized management systems such as OHSAS 18001 and ILO Guidelines on
Occupational Safety and Health were used as references in preparing the Code and may
be a useful source of additional information.
The health and safety standards are:
1) Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy
sources, fire, vehicles, and fall hazards) are to be controlled through proper design,
engineering and administrative controls, preventative maintenance and safe work
procedures (including lockout/tagout). Where hazards cannot be adequately
controlled by these means, workers are to be provided with appropriate personal
protective equipment. Workers shall not be disciplined for raising safety concerns.
2) Emergency Preparedness
Emergency situations and events are to 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, appropriate fire detection and suppression equipment, adequate
exit facilities and recovery plans.
3) Occupational Injury and Illness
Procedures and systems are to be in place to manage, track and report occupational
injury and illness, including provisions to: a) encourage worker reporting; b) classify
and record injury and illness cases; c) provide necessary medical treatment; d)
investigate cases and implement corrective actions to eliminate their causes; and d)
facilitate return of workers to work.
4) Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified,
evaluated, and controlled. When hazards cannot be adequately controlled by
engineering and administrative means, workers are to be provided with appropriate
personal protective equipment.
5) Physically Demanding Work
Worker exposure to physically demanding tasks, including manual material
handling and heavy lifting, prolonged standing and highly repetitive or forceful
assembly tasks is to be identified, evaluated and controlled.

Page 4 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007



B. HEALTH and SAFETY (con鈥檛.)
6) Machine Safeguarding
Physical guards, interlocks and barriers are to be provided and properly maintained
for machinery used by workers.
7) Dormitory and Canteen
Workers are to be provided with clean toilet facilities, access to potable
water and sanitary food preparation and storage facilities. Worker
dormitories provided by the Participant or a labor agent are to be clean,
safe, and provide emergency egress, adequate heat and ventilation and
reasonable personal space.




Page 5 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007



C. ENVIRONMENTAL
Participants recognize that environmental responsibility is integral to producing world
class products. In manufacturing operations, adverse effects on the community,
environment and natural resources are to be minimized while safeguarding the health and
safety of the public.
Recognized management systems such as ISO 14001, the Eco Management and Audit
System (EMAS) were used as references in preparing the Code and may be a useful
source of additional information.

The environmental standards are:

1) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring) and registrations are
to be obtained, maintained and kept current and their operational and reporting
requirements are to be followed.
2) Pollution Prevention and Resource Reduction
Waste of all types, including water and energy, are to be reduced or eliminated at
the source or by practices such as modifying production, maintenance and facility
processes, materials substitution, conservation, recycling and re-using materials.
3) Hazardous Substances
Chemical and other materials posing a hazard if released to the environment are to
be identified and managed to ensure their safe handling, movement, storage,
recycling or reuse and disposal.
4) Wastewater and Solid Waste
Wastewater and solid waste generated from operations, industrial processes and
sanitation facilities are to be monitored, controlled and treated as required prior to
discharge or disposal.
5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone
depleting chemicals and combustion by-products generated from operations are to
be characterized, monitored, controlled and treated as required prior to discharge.
6) Product Content Restrictions
Participants are to adhere to all applicable laws and regulations regarding
prohibition or restriction of specific substances including labeling laws and
regulations for recycling and disposal. Participants are also to adhere to processes
to comply with each agreed-upon customer-specific restricted and hazardous
materials list.



Page 6 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007




D. MANAGEMENT SYSTEM
Participants shall adopt or establish a management system whose scope is related to the
content of this Code. The management system shall be designed to ensure (a) compliance
with applicable laws, regulations and customer requirements related to the participant鈥檚
operations and products; (b) conformance with this Code; and (c) identification and
mitigation of operational risks related to this Code. It should also facilitate continual
improvement.
The management system should contain the following elements:
1) Company Commitment
Corporate social and environmental responsibility statements affirming Participant鈥檚
commitment to compliance and continual improvement.
2) Management Accountability and Responsibility
Clearly identified company representative[s] responsible for ensuring implementation
and periodic review of the status of the management systems.
3) Legal and Customer Requirements
Identification, monitoring and understanding of applicable laws, regulations and
customer requirements.
4) Risk Assessment and Risk Management
Process to identify the environmental, health and safety虏 and labor practice risks
associated with Participant鈥檚 operations. Determination of the relative significance
for each risk and implementation of appropriate procedural and physical controls to
ensure regulatory compliance to control the identified risks.
5) Performance Objectives with Implementation Plan and Measures
Written standards, performance objectives, targets and implementation plans
including a periodic assessment of Participant鈥檚 performance against those
objectives.
6) Training
Programs for training managers and workers to implement Participant鈥檚 policies,
procedures and improvement objectives.




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



Page 7 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007




D. MANAGEMENT SYSTEM (con鈥檛.)
7) Communication
Process for communicating clear and accurate information about Participant鈥檚
performance, practices and expectations to workers, suppliers and customers.
8) Worker Feedback and Participation
Ongoing processes to assess employees鈥? understanding of and obtain feedback on
practices and conditions covered by this Code and to foster continuous
improvement.
9) Audits and Assessments
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
Process for timely correction of deficiencies identified by internal or external
assessments, inspections, investigations and reviews.
11) Documentation and Records
Creation of documents and records to ensure regulatory compliance and
conformity to company requirements along with appropriate confidentiality to
protect privacy.




Page 8 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007



E. ETHICS
To meet social responsibilities and to achieve success in the marketplace, Participants and
their agents are to uphold the highest standards of ethics including:
1) Business Integrity
The highest standards of integrity are to be expected in all business interactions.
Any and all forms of corruption, extortion and embezzlement are strictly prohibited
resulting in immediate termination and legal actions.
2) No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be
offered or accepted.

3) Disclosure of Information
Information regarding business activities, structure, financial situation and
performance is to be disclosed in accordance with applicable regulations and
prevailing industry practices.
4) Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-
how is to be done in a manner that protects intellectual property rights.

5) Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld. Means
to safeguard customer information should be available.

6) Protection of Identity
Programs that ensure the protection of supplier and employee whistleblower
confidentiality are to be maintained.

7) Community Engagement
Community engagement is encouraged to help foster social and economic
development.




Page 9 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007



References: The following standards were used in preparing this Code and may be a
useful source of additional information. The following standards may or may not be
endorsed by each Participant.
ILO Code of Practice in Safety and Health
www.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf
National Fire Protection Agency
www.nfpa.org/catalog/home/AboutNFPA/index.asp
ILO International Labor Standards
www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm
OECD Guidelines for Multinational Enterprises
www.oecd.org
United Nations Convention Against Corruption
www.unodc.org/unodc/en/crime_convention_corruption.html
United Nations Global Compact
www.unglobalcompact.org
Universal Declaration of Human Rights
www.un.org/Overview/rights.html
ISO 14001
www.iso.org
SA 8000
www.cepaa.org/
SAI
www.sa-intl.org
Ethical Trading Initiative
www.ethicaltrade.org/
OHSAS 18001
www.bsi-global.com/index.xalter
Eco Management & Audit System
www.quality.co.uk/emas.htm




Page 10 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D
Supply Chain Operations
Social and Environmental Responsibility
October 11, 2007



DOCUMENT HISTORY
Version 1.0 - Released October 2004.
Version 1.1 - Released May 2005. Converted document to EICC format, minor page
layout revisions; no content changes
Version 2.0 - Released October 2005 with revisions to multiple provisions.
December 15, 2005 - Added HP-specific language for Labor provision #7, Freedom of
Association.
Version 2.0.1 - HP - Moved 1st sentence in FOA provision to last sentence in section.



svs

The Electronic Industry Code of Conduct was initially developed by a number of
companies engaged in the manufacture of electronics products between June and October
2004. Participating companies included Celestica, Dell, Flextronics, HP, IBM, Jabil,
Sanmina SCI, and Solectron.
Companies adopting/endorsing the code and/or joining the Implementation Group
include: Celestica, Cisco, Dell, Flextronics, Foxconn, HP, IBM, Intel, Jabil, Lucent,
Microsoft, Sanmina SCI, Seagate, and Sony. Other companies are invited and
encouraged to adopt this code. You may obtain additional information from
www.eicc.info.




Page 11 of 11
Date: October 11, 2007
HP Supplier DWG. No. 5990-6486
Changes since previous issue noted by
Code of Conduct
Approval: Lindsey Ridgeway Rev. D

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