Governance and Ethics

Avago is committed to maintaining the highest standards of business conduct and ethics in all of our worldwide operations and locations. To support this goal, Avago Technologies requires every regular employee and contractor to certify each fiscal year that they have reviewed, understand and agree to abide by the policies and guidelines by taking the following online classes:
 
  •     Code of Ethics and Business Conduct - is designed to help you act according to the highest standards of legal and ethical conduct. The course details stakeholders’ responsibility to report any inappropriate behavior and to seek assistance regarding work-related ethical dilemmas.
  •     Insider Trading - helps stakeholders understand Insider Trading, the potential pitfalls, such as massive fines and even jail time, for inadvertent mistakes.
  •     Foreign Corrupt Practices/Anti-Corruption - explores the basics of the law, who is affected, and what is required. Video scenarios and practice questions challenge stakeholders to make decisions in compliance with this law and business best practices.
 
Avago currently achieves over 96% completion rate on each of the classes across all employees and contractors at all locations worldwide.
 
In addition, Avago publishes the following Code of Ethics and Business Conduct and Open Door Policy documents for all employees, partners, vendors and other stakeholders. This Code reflects the business practices and principles of behavior that support our commitment to the UN Global Compact Principle #10 and to industry best practices for responsible corporate citizens.
 
 
The policy documents include contact information to report any transgressions to our Compliance Officer. We also provide contact information so a person witnessing any transgressions can report them directly to members of the Audit Committee on the Board of Directors.
 
Avago also maintains a Compliance Hotline, hosted by EthicsPoint (a third party vendor) that is available to those who wish to ask questions about Avago policy, seek guidance on specific situations or report violations of the Code. Filing a report can be done using either of the following methods on the Compliance Hotline:
 
  •     Click on File a Report or go to the EthicsPoint website, or
  •     Call (800) 422-3240 in the United States and Canada, or for other international numbers click here.
 
Avago Technologies' suppliers are expected to adhere to the following requirements with respect to their operations, products and services:
 
  •     Suppliers shall comply with all applicable environmental, health and safety laws, rules, and regulations. Direct material suppliers shall comply with Avago Technologies’ general requirements for restricting or prohibiting certain substances in products manufactured for or delivered to Avago Technologies.
  •     Supplier shall comply with all applicable for laws, rules, and regulations.
  •     Supplier shall not employ under-age labor as described in Minimum Age Convention 138 and Worst Forms of Child Labor Convention 182 of the International Labor Organization.
  •     Supplier shall not make use of forced or compulsory labor as described in Article 2 in the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105 of the International Labour Organization.
  •     Supplier shall provide equal remuneration and shall respect, within the framework of local laws and established practices, the principles of Article 1 in the Equal Remuneration Convention 100 and Article I in the Discrimination [Employment and Occupation] Convention 111 of the International Labour Organization.
  •     Supplier shall respect, within the framework of local laws and established practices, the principles of Article 2 in the Freedom of Association and Protection of the Right to Organize Convention 87 and Articles 1 and 2 in the Right to Organize and Collective Bargaining Convention 98 of the International Labour Organization.
  •     Supplier shall encourage sub-suppliers to adhere to similar environmental and social responsibility principles.
 
Avago also provides existing and prospective vendors a self-evaluation checklist for them to certify compliance and cite references where the policies are referenced:
 
  •     Compliance with Laws and Regulations
  •     Basic Human rights
  •     Safety Requirements
  •     Fair and Honorable Business Practices
 
Vendors acknowledge their agreement to these principles by signing an appropriate Avago Affidavit.
 
Avago is modifying its Supplier Agreements in 2012 to include provisions for an annual self-certification process and neutral third party audits that are both EICC and UN Global Compact compliant to ensure vendors and stakeholders continue to adhere to these standards of conduct.