2-24 - Embedding policy commitments

Describe how policy commitments for responsible business conduct are embedded throughout activities and business relationships:

In furtherance of the principles and other values enshrined within the Universal Declaration of Human Rights, Rambus has adopted multiple policies and practices, including the Rambus Code of Business Conduct and Ethics and Rambus Vendor Code of Conduct (which is based on the Responsible Business 2 Alliance (RBA) Code of Conduct; such Rambus codes, collectively, the “Rambus Codes”). Rambus is committed to working with its vendors, partners, employees, management, and Board of Directors to uphold this Policy and revisit it as necessary. Rambus expects our vendors to follow the standards set forth in the Rambus Codes, as well as all applicable laws and regulations. The Rambus Codes require Rambus personnel and vendors to respect personal privacy, treat workers with dignity and respect, and comply with all applicable laws pertaining to freedom of association, collective bargaining, immigration, working time, wages, benefits and hours, safe and healthy working conditions, as well as laws prohibiting forced, compulsory and child labor, human trafficking, harassment, and employment discrimination. Assessments are conducted annually to evaluate high risk suppliers' performance in the area of human rights. We track the number of employees or contractors that do not meet standards on slavery and trafficking and have a corrective action system. Rambus' employee onboarding training includes a Human Rights component. We provide Rambus personnel with training, resources, and systems to effectuate our commitment to protecting human rights. Rambus' employee training includes training on human trafficking and slavery for its employees and management with direct responsibility for supply chain management The Rambus Codes and Rambus Global Anti-Corruption Policy require personnel to comply with all applicable laws regarding bribery and corruption, e.g., the United States Foreign Corrupt Practices Act. We train our personnel on this requirement regularly. The Rambus Conflict Mineral Policy requires us to follow applicable law to ensure we, and our applicable vendors, are sourcing minerals for our products in a manner that does not contribute to human rights violations. Rambus maintains board-level oversight and engagement with senior executives regarding our corporate responsibility priorities, including this Human Rights Statement and the policies and practices mentioned herein. We prohibit retaliation against any employee for reporting, in good faith, a suspected violation of law, or any other Rambus code or policy. We regularly assess our top suppliers to evaluate their conformance with Rambus's Vendor Code of Conduct and the human rights-related obligations therein. If any issues arise, Rambus will properly address them.

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