Supply Chains Act Policy

NeoPhotonics Corporation expects its own organization and its suppliers to comply with all applicable laws and regulations, including those governing working conditions, environmental protection, and fair business practices. NeoPhotonics is currently in the process of studying existing supply chain operations and developing a global company policy in an effort to ensure, to the extent practicable, that our supply chain is free of any products of forced labor, child labor, human trafficking and slavery.

This policy will address issues related to: (i) verification of product supply chains to evaluate the potential for products of forced labor, child labor, human trafficking, and slavery to be present in its direct supply chain; (ii) the possibility of auditing suppliers should NeoPhotonics become aware of any credible indication of potential inhumane labor practices on the part of a direct supplier; (iii) supplier certification in writing that materials incorporated into their products comply with the laws regarding forced labor, child labor, human trafficking, and slavery in the country or countries where they do; (iv) maintaining internal accountability standards and procedures for employees or contractors failing to meet company standards regarding avoidance of forced labor, child labor, human trafficking, and slavery; and (v) providing company employees and management, who have direct responsibility for supply chain management, training on forced labor, child labor, human trafficking, and slavery, particularly with respect to mitigating risks within the supply chain of products.

California Transparency in Supply Chains Act requires manufacturers to provide consumers with information regarding their efforts to eradicate slavery and human trafficking from their supply chains, and to disclose to what extent, if any, they are engaging in specific actions to address these concerns.