SANDISK UK LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents

Training described

Your whole organisation Your front line staff Human resources Executive-level staff Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Civil society organisations Professional auditors Workers within your organisation Businesses in your industry or sector

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

We regularly audit our supply chain through our partnership with the RBA. We conduct audits of labor brokers and providers of on-site services such as cafeteria, janitorial cleaning and security.

Actions addressing ILO indicators

Financial remediation, including repayment of recruitment fees

Demonstrated progress

The key performance indicator used is the RBA audit scores for our own operations and our suppliers. We regularly audit our supply chain through our partnership with the RBA, and in some instances we use our own staff. Suppliers are required to perform periodic self-assessments, and many are required to undergo independent RBA audits. Suppliers must give Sandisk access to their completed self-assessment questionnaires (SAQs) and any completed RBA audit reports.

Reported risks and mitigations

• Risk: Labour issues in manufacturing location – Malaysia
• Area: Within your own operations
• Mitigation: Because our manufacturing workforce based in Malaysia is particularly susceptible to human rights violations, we pay close attention to this population. Sandisk’s manufacturing workforce is predominantly composed of directly hired workers whom we employ and manage ourselves. This gives us direct control over their working conditions, so we can ensure that they are treated with dignity and respect and experience fair and sustainable working conditions.
• Risk: Recruitment fees
• Area: Within your supply chains
• Tier: Tier 1 suppliers
• Group: Migrants
• Mitigation: We engage in dialogue with employees and suppliers while also working with third parties to audit ours and our suppliers’ practices. If and when we find issues regarding recruitment fees, we work quickly to remediate them. We ensure suppliers are following appropriate recruiting practices and that any necessary reimbursements are promptly provided to impacted employees.
• Risk: Human right issues
• Mitigation: We regularly remind employees and suppliers about the availability of our global ethics helpline, an anonymous service managed by an independent third party, for reporting misconduct or other problems. The helpline is available 24 hours a day in all of the major languages spoken by our employees and is available to suppliers’ workers and legitimate representatives. When we receive reports of misconduct, we promptly investigate any confirmed problems.