S u s
Transcription
S u s
Sustainability Systems Manual Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 2 of 22 Table of Contents INTRODUCTION ........................................................................................................................................... 3 1.1 2 DOCUMENTATION STRUCTURE ...................................................................................................... 3 2.1 2.2 2.3 2.4 2.5 3 LEVEL I: SKYWORKS SUSTAINABILITY MANUAL ................................................................................. 4 LEVEL II: STANDARD OPERATING PROCEDURES .............................................................................. 4 LEVEL III: WORK INSTRUCTIONS...................................................................................................... 4 LEVEL IV: FORMS ........................................................................................................................... 4 REFERENCE DOCUMENTS ............................................................................................................... 4 STRUCTURE & RESPONSIBILITY..................................................................................................... 5 3.1 4 SCOPE .......................................................................................................................................... 3 SUSTAINABILITY PROGRAMS STRUCTURE ........................................................................................ 6 ENVIRONMENTAL MANAGEMENT SYSTEM REQUIREMENTS..................................................... 6 4.1 GENERAL REQUIREMENTS .............................................................................................................. 6 4.2 SKYWORKS SUSTAINABILITY POLICY ............................................................................................... 6 4.2.1 Policy Communication ............................................................................................................. 8 4.2.2 Product Portfolio Development and Management .................................................................. 9 4.3 PLANNING ...................................................................................................................................... 9 4.3.1 Environmental Aspects............................................................................................................ 9 4.3.2 Legal and Other Requirements ............................................................................................. 10 4.3.3 Objectives, Targets and Programme(s) ................................................................................ 10 4.4 IMPLEMENTATION AND OPERATION ................................................................................................ 11 4.4.1 Resources, Roles, Responsibility and Authority ................................................................... 11 4.4.2 Competence, Training and Awareness ................................................................................. 11 4.4.3 Communication...................................................................................................................... 12 4.4.4 Documentation ...................................................................................................................... 12 4.4.5 Control of Documents ............................................................................................................ 13 4.4.6 Operational Control ............................................................................................................... 13 4.4.7 Emergency Preparedness and Response ............................................................................ 14 4.5 CHECKING ................................................................................................................................... 14 4.5.1 Monitoring and Measurement................................................................................................ 14 4.5.2 Evaluation of Compliance...................................................................................................... 14 4.5.3 Nonconformity, Corrective Action and Preventative Action .................................................. 15 4.5.4 Control of Records ................................................................................................................ 15 4.5.5 Internal Audit ......................................................................................................................... 15 4.6 MANAGEMENT REVIEW ................................................................................................................. 16 5 SUSTAINABILITY PROGRAMS ....................................................................................................... 16 5.1 LABOR ......................................................................................................................................... 17 5.1.1 Conflict Minerals .................................................................................................................... 17 5.1.2 Slavery and Human Trafficking Prevention (Freely Chosen Employment) ........................... 18 5.2 HEALTH & SAFETY ....................................................................................................................... 18 5.3 ENVIRONMENTAL.......................................................................................................................... 19 5.4 MANAGEMENT SYSTEM ................................................................................................................ 19 5.5 ETHICS ........................................................................................................................................ 19 5.6 SUPPLY CHAIN REQUIREMENTS .................................................................................................... 19 6 GLOSSARY OF TERMS (DEFINITIONS) ......................................................................................... 19 7 REVISION HISTORY ......................................................................................................................... 20 NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 3 of 22 Introduction This manual defines the Skyworks Solutions, Inc. approach to and assignment of responsibilities for the Skyworks’: Sustainability Policy Environmental Management System Health & Safety Programs Ethics Programs Labor Programs Supply Chain Sustainability Programs Skyworks maintains an ISO 14001 certification. ISO 14001 requirements are written in Section 4 of this manual. The whole of section 4 follows the numeric order of the ISO standard for ease of reference. Section 5 details the elements of Environmental, Health & Safety, Ethics, and Labor, as well as Supply Chain sustainability requirements. 1.1 Scope Sections 1-4 of this manual apply to the design, development, manufacturing, and support organizations at the following Skyworks locations: Newbury Park, CA Woburn, MA Mexicali, B.C., Mexico Adamstown, MD (Trans-Tech, Inc. is a wholly owned subsidiary of Skyworks) Section 4.2 “Skyworks Sustainability Policy” and Section 5 “Sustainability Programs” apply to all business operations across all sites globally. 2 Documentation Structure This manual outlines the quality system design for Environmental Management Systems and Sustainability Programs at Skyworks Solutions, Inc. This manual is a part of a hierarchy of documentation that is established to ensure uninterrupted quality from all levels of Skyworks. The documentation structure is in line with and conformant to the documentation structure outlined in the Skyworks Quality Manual, SQ01-0001. The pre-fix letters such as “NP,” “WB,” etc. indicate the location or business unit to which the document applies (NP = Newbury Park, WB = Woburn). The pre-fix letters “SQ” indicate a global document that applies to two or more locations / business units (as indicated in the “Scope” section of each specific document). NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 4 of 22 2.1 Level I: Skyworks Sustainability Manual The Sustainability Systems Manual is the level I document. It establishes policies to which all other sustainability programs and documentation must conform to. 2.2 Level II: Standard Operating Procedures Each Skyworks location or business unit keeps and maintains level II standard operating procedures. The SOP’s are site or organization specific and outline the details of each site/organizations’ sustainability programs. Level II SOP’s are conformant to the Sustainability Manual. Where applicable, global (SQ) SOPs are developed and maintained. 2.3 Level III: Work Instructions Level III work instructions are site or organization specific procedures that define how the tasks referenced in the level II documents are performed. Where applicable, global (SQ) work instructions are developed and maintained. 2.4 Level IV: Forms Level IV forms provide a means to record results achieved or evidence of activities performed. Where applicable, global (SQ) forms are developed and maintained. 2.5 Reference Documents Management Systems SQ01-0001 Quality Systems Manual Environmental Management Systems NP-01386 Newbury Park Environmental Management System WB-0001-ENV Woburn Environmental Management System MX-SAA-0036 SAA Mexicali Environmental Management System TT-SOP-0045 Trans-Tech Environmental Management System Operational Controls IRV-0006 Design Center Site Environmental Operational Controls (applicable to non-manufacturing sites only – outside of ISO 14001 audit scope per Sec. 1.1 of this document) SQ02-0034 Design & Development and Supply Chain Sustainability Operational Controls Health & Safety Refer to Skylink – Departments - Env. Health & Safety page Ethics Refer to Skylink – Departments – Legal page Labor NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 5 of 22 Refer to Skylink – Departments – Human Resources page Supply Chain SQ03-0337 – Supplier Sustainability Specification External Reference Documents ISO 14001-2004 Electronic Industry Citizenship Coalition Code of Conduct version 4.0 – 2012 Additional reference documents are identified in specific sections throughout this manual, as applicable to the section. 3 Structure & Responsibility For the company management structure, refer to the Skyworks Quality Manual, SQ01-0001. Signatories to this manual are responsible for conformance to the requirements of this manual as they apply to their respective organizations. For “Top Management” structure with respect to the EMS, refer to Section 4.4.1 of this manual. NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 6 of 22 3.1 Sustainability Programs Structure 4 Environmental Management System Requirements 4.1 General Requirements The requirements of the EMS are described in the whole of section 4. The scope is defined in Section 1.1. 4.2 Skyworks Sustainability Policy For the purposes of the EMS (the whole of section 4), the terms Environmental Policy and Sustainability Policy can be used interchangeably. Skyworks has developed a NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 7 of 22 single comprehensive policy intended to cover Sustainability and conform to all of the established requirements for an Environmental Policy under the ISO 14001 standard. NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 8 of 22 4.2.1 Policy Communication Direct or equivalent translations of the Sustainability Policy to foreign languages are approved and available at applicable Skyworks locations. 4.2.1.1 Internal Communication The following methods are utilized for communication of the Sustainability Policy to Skyworks employees: Document Control System Skylink (Skyworks intranet site) Posters Employee badges (see Policy Summary Statement section below) Additionally, the policy may be communicated via other means as needed, including periodic company meetings, pamphlets, notices, etc… 4.2.1.2 External Communication The following methods are utilized for communication of the Sustainability Policy to other interested parties (ie: customers and the general public): Skyworks external website: www.skyworksinc.com Skyworks Sustainability Report (non-financial public report) Other means of communication may be utilized as needed and at the discretion of the Skyworks Environmental Dept. and established Top Management for the EMS. 4.2.1.3 Policy Summary Statement The following is an approved Sustainability Policy summary statement. The summary statement is not intended to substitute the policy, but rather to enhance general communication and awareness of the Skyworks Sustainability Policy. The summary statement may be used on badges and other general awareness communication where a shorter statement is needed or preferred. NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 9 of 22 4.2.2 Product Portfolio Development and Management Skyworks recognizes that, in addition to the manufacturing and support processes required to build our products, the products themselves may also have impacts to the environment. In recognition of this and in support of the Skyworks Sustainability Policy, Skyworks is committed to offering product portfolio to meet customer requirements for regulatory compliant (ie: RoHS) and environmentally preferred products. Identified restricted substances are controlled at the design / development stages as well as in materials sourcing and final product manufacturing. Global Reference Documents SQ02-0034 – Design & Development and Supply Chain Sustainability Operational Controls 4.3 Planning 4.3.1 Environmental Aspects Skyworks maintains defined procedures by which environmental aspects (from business activities that Skyworks can control or which it can be expected to have influence) are identified, taking into account planned or new developments, or new or modified activities, products and services where applicable. These NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 10 of 22 procedures act to determine those aspects which have or can have significant impacts on the environment. These “significant aspects” are considered in setting environmental objectives and targets. This information is kept up to date via regular review. Identified significant environmental aspects are taken into account in establishing, implementing and maintaining the EMS. Global Reference Documents SQ03-0140 – Environmental Improvement 4.3.2 Legal and Other Requirements Skyworks maintains procedures to identify and have access to legal and other requirements to which Skyworks subscribes that are applicable to the identified environmental aspects. These procedures are developed as needed on a site or organization specific basis. These procedures include, but are not limited to: applicable environmental regulations and permits (including permit conditions). Skyworks maintains an Environmental Department whose task it is to identify applicable legal and other requirements utilizing available resources including those listed above. Legal and other requirements are taken into account in the establishment, implementation, and maintenance of the EMS. 4.3.3 Objectives, Targets and Programme(s) Skyworks maintains documented procedures for the establishment of objectives and targets for environmental improvement and continuous improvement of the EMS. In the establishment of these objectives and targets, the following are taken into account: 1. Legal requirements and other requirements to which Skyworks subscribes, 2. Significant environmental aspects, 3. Technological options, 4. Financial issues, 5. Operational and business requirements, 6. Customer requests / requirements, and 7. Views of interested parties. All established objectives and targets are measurable, where practicable (environmental performance indicators – EPIs) and are consistent with the Environmental Policy. In order to achieve established environmental objectives and targets, environmental management programs are established and maintained. These programs include: 1. Designation of responsibility for achieving the objectives and targets, and 2. The means and time frame by which the objectives and targets are to be achieved. Environmental management programs are maintained and amended where necessary to reflect new developments and new or modified activities, products, or services. Global Reference Documents SQ03-0140 – Environmental Improvement NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 11 of 22 4.4 Implementation and Operation 4.4.1 Resources, Roles, Responsibility and Authority The signatories to this document are responsible for ensuring compliance to the Environmental Management System (EMS) Requirements (sec. 4 of this manual) throughout their respective organizations. Top management is designated for each Skyworks EMS (level II) by the signatories of this document. Top management ensures conformance to the EMS and provides feedback and information on the status and performance of the EMS to the respective Sustainability Systems Manual signatories, on an asneeded basis. Established top management provides resources essential to the implementation and control of the EMS at local levels. Such resources include, but are not limited to human resources and specialized skills, technology, and financial resources. Top management appoints the Skyworks Environmental Department as the management representative to ensure EMS requirements are established, implemented, and maintained in accordance with the ISO 14001 standard. The Environmental Department ensures the performance of the EMS is reported to Top Management for review purposes and as a basis for continuous improvement. Refer to Section 4.6 “Management Review” for more details. Contractors’ (those working on behalf of Skyworks) are responsible for working in accordance with the Skyworks Sustainability Policy and any other specified requirements (while performing work at a Skyworks facility or working on behalf of Skyworks). Contractor responsibilities (environmental) are communicated as follows: On site work at a Skyworks facility: Ref. SQ03-0067 – EHS Contractor Requirement Work on behalf of Skyworks: Ref. SQ03-0337 – Supplier Sustainability Specification Global Reference Documents SQ03-0067 – EHS Contractor Requirement SQ02-0020 – Supplier Quality Manual SQ03-0138 – Supplier Qualification and Monitoring SQ03-0132 – Green Procurement Supplier Specification SQ03-0337 – Supplier Sustainability Specification 4.4.2 Competence, Training and Awareness Training needs are clearly identified for persons whose work may create a significant impact upon the environment. Competency is based on appropriate NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 12 of 22 education, training, and/or experience. Procedures are established and maintained to keep employees and persons working on behalf of Skyworks (eg: contractors) at each relevant function and level aware of: a) The importance of conforming with the environmental policy and procedures and with the requirements of the EMS; b) The significant environmental aspects and associated impacts of their work activities and the environmental benefits from improved personal performance; c) Their roles and responsibilities in achieving conformance with the Sustainability Policy and requirements of the EMS including emergency preparedness and response requirements; d) The potential consequences of departure from specified operating procedures. Records of training are maintained. Global Reference Documents SQ02-0010 – Competency and Training 4.4.3 Communication Skyworks effectively communicates between various levels and functions the requirements of the environmental policy and the EMS to all employees as appropriate to their job function. Skyworks also has established methods for receiving, documenting, and responding to relevant communication from external interested parties, such as customers and the general public. With respect to its significant environmental aspects, they are communicated internally to Skyworks employees. Reference Sec. 4.3.1. Significant aspects are not required to be communicated externally unless for the purposes of training and awareness of persons working on behalf of Skyworks (contractors). Reference Sec. 4.4.2. Skyworks utilizes a non-financial public report – the Skyworks Sustainability Report – as a means of communication to customers, the public, and interested parties on elements of our Sustainability programs. The report is available on Skyworks’ external website: http://www.skyworksinc.com/GreenInitiative.aspx 4.4.4 Documentation Documents which make up the EMS are maintained detailing the core elements of the environmental programs and their interaction with one another. EMS documents are conformant to this manual and the ISO 14001-2004 standard. Within the EMS documents, appropriate references to all work instructions and associated forms are given. NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 13 of 22 Documents for effective planning, operation, and control of processes related to significant aspects are maintained in our company document control system and are a part of the overall EMS as defined in Section 1. 4.4.5 Control of Documents Documents required by this manual, the ISO 14001—2004 standard, and the EMS are maintained according to a Skyworks Document and Data Control Procedure – SQ02-0004. Documents must be: a) Easily located. b) Periodically reviewed and revised as necessary and approved for adequacy by appropriate personnel c) Current with current revisions available at all necessary locations to ensure effective functioning of the EMS d) Controlled such that obsolete documents are promptly removed at all points of use or are appropriately protected against unintended use. e) Controlled such that obsolete documents retained for legal or other purposes are appropriately identified. The established document control procedure defines: a) Approval of documents for adequacy prior to issue b) Review and update of documents as necessary c) Document changes and revision status identification d) Method by which relevant versions of documents are available at points of use e) Documents are legible and readily identifiable f) Method by which external documents are identified and their distribution controlled g) Method by which obsolete documents are identified to prevent their unintended use Global Reference Documents SQ02-0004 – Document and Data Control SQ03-0294 – Control of Documents of External Origin 4.4.6 Operational Control Skyworks ensures that all operations and activities associated with identified significant environmental aspects are clearly identified. These operations, in line with the policy and established environmental objectives and targets, are performed according to established documented procedures. This is done to cover situations where their absence could lead to deviations from the Sustainability Policy and established objectives and targets. Operating criteria are clearly stipulated. NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 14 of 22 Where suppliers or contractors may influence the policy or environmental objectives and targets, procedures exist to communicate relevant procedures and require the suppliers and contractors to conform to those procedures. 4.4.7 Emergency Preparedness and Response Appropriate procedures are maintained to identify the potential for accidents, respond to emergency situations and prevent and mitigate environmental impacts that may be associated with them. These procedures are reviewed and revised where necessary and following the occurrence of accidents or emergency situations. These procedures are periodically tested where practicable to ensure their effectiveness. 4.5 Checking 4.5.1 Monitoring and Measurement Skyworks maintains procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact on the environment. This includes the recording of information to track performance, relevant operational controls, and conformance with the established objectives and targets. Further, documented procedures are maintained to periodically evaluate compliance with relevant environmental legislation and regulations. Monitoring equipment required for compliance to regulations or conformance to the Skyworks EMS are calibrated according to an established Skyworks Calibration procedure or manufacturers’ recommendations. Depending on the equipment, calibration may be integrated into established (site specific) preventative maintenance procedures. 4.5.2 Evaluation of Compliance 4.5.2.1 A process for evaluating compliance to applicable environmental legal and regulatory requirements is in place and maintained at each manufacturing site and for Design & Development to ensure alignment to our commitment to comply (as referenced in the Sustainability Policy). Records of compliance evaluations, with results, are maintained as needed. Global Reference Documents SQ02-0038 – EMS Internal Audit SQ04-0076 – Design for Environment Checklist NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 15 of 22 4.5.2.2 In addition to regulatory and legal requirements as referenced above, Skyworks is committed to meeting the expectations of our customers and the communities in which we operate. We encourage environmental / social responsibility awareness and continuous improvement among our suppliers and associates. Global Reference Documents SQ03-0138 – Supplier Qualification and Monitoring SQ03-0132 – Green Procurement Supplier Specification SQ03-0337 – Supplier Sustainability Specification SQ02-0020 – Supplier Quality Manual SQ03-0185 – Green Supplier Survey, Customer Survey, and DfE Process 4.5.3 Nonconformity, Corrective Action and Preventative Action Skyworks keeps and maintains a Continuous Improvement / Corrective & Preventative Action procedure, as a means to ensure a robust system for timely correction of identified nonconformities. Internal Corrective Action Requests (ICAR) and Internal Preventative Action Requests (IPARS) are issued for actual and potential nonconformities to this manual, ISO 14001, or applicable legal and other requirements. Within the ICAR / IPAR system, effectiveness of the corrective / preventative actions taken are evaluated and reviewed. Global Reference Documents SQ02-0014 – Continuous Improvement / Corrective & Preventative Action SQ03-0258 – Internal Corrective / Preventative Action Request Processing 4.5.4 Control of Records Records are maintained at each manufacturing facility to demonstrate conformance to this Manual and the ISO 14001 standard. These records are maintained according to a Document and Data Control procedure. Global Reference Documents SQ02-0004 – Document and Data Control 4.5.5 Internal Audit Skyworks keeps and maintains programs and procedures for periodic audits of the EMS at each facility and/or business unit. The audits are designed to determine whether or not the EMS conforms to the requirements of ISO 14001 and if it has been properly implemented and maintained. Results of these audits are presented to the identified top management of the respective facilities and/or business units and records are maintained. The audit procedures developed at each facility and/or business unit are comprehensive, covering the complete audit procedures, scope, frequency, methodologies, as well as the responsibilities and requirements for conducting NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 16 of 22 audits and reporting results. They include requirements for the selection of auditors and conduct of the audit to ensure objectivity. Global Reference Documents SQ02-0038 – EMS Internal Audit 4.6 Management Review Established top management for each EMS (level II) periodically reviews the status of the EMS to ensure its continuing suitability, adequacy, and effectiveness. Procedures for this review ensure the appropriate and necessary information is collected to allow management to carry out an effective system evaluation. Management review includes: Results of internal audits and evaluations of compliance with legal requirements and with other requirements to which Skyworks subscribes (eg: customer requirements) Communication(s) from external interested parties, including complaints The environmental performance of the organization The extent to which objectives and targets have been met Status of corrective and preventative actions Follow-up actions from previous management reviews Changing circumstances including developments in legal and other requirements related to environmental aspects, and Recommendations for improvement. The management review process is documented for each EMS (level II) and may occur in various forms ensuring each of the above elements are covered. Global Reference Documents SQ02-0039 – EMS Management Review 5 Sustainability Programs In addition to our ISO 14001 certified Environmental Management System (EMS) programs (refer to Sec. 4), Skyworks keeps and maintains programs and policies covering the subjects of Environmental, Health & Safety, Ethics, Labor, and Management Systems in alignment with the Electronics Industry Citizenship Coalition Code of Conduct (Code). Program elements developed for alignment to the Code shall NOT be considered part of the auditable programs under our existing ISO 14001 certification. Skyworks Solutions, Inc. is committed to operating in full compliance with the laws, rules, and regulations of all the countries in which it operates. It recognizes the Electronics Industry Citizenship Coalition Code of Conduct (Code) and actively pursues conformance to it and its standards in accordance with the management systems as identified in this manual. We further recognize the Code as a total NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 17 of 22 supply chain initiative. Details regarding supplier requirements and alignment to the Code can be referenced in the Supplier Sustainability Specification (SQ03-0337) and in sec. 5.6 of this manual. The latest version of the Code can be found at: http://eicc.info/eicc_code.shtml Reference Documents SQ01-0001 – Skyworks Quality Manual SQ03-0337 – Supplier Sustainability Specification SQ02-0034 – Design & Development and Supply Chain Sustainability Operational Controls EICC Code of Conduct: http://eicc.info/eicc_code.shtml 5.1 Labor Labor programs within Skyworks are developed, implemented, and managed by the Skyworks Human Resources organization. Policies and programs ensuring conformance to the Sustainability Policy, this manual, and the EICC Code of Conduct can be referenced on the Skyworks’ intranet site at: http://skylink/Dept/HR/Pages/Policies-and-Guidelines.aspx Note: This is an intranet link and does not function outside of Skyworks. 5.1.1 Conflict Minerals Many industries, including the semiconductor and electronics industries, utilize tin, tantalum, tungsten (also known as the 3Ts), and gold in their products and manufacturing processes. Gold and the minerals used to produce tin, tantalum and tungsten are mined throughout the world, including in central and southern Africa. The operators of some mines extracting these minerals in central and southern Africa, particularly in The Democratic Republic of Congo (DRC) and the countries sharing an internationally recognized border with the DRC (the Covered Countries), are known to have inflicted rampant human rights abuses on the population of The Democratic Republic of Congo and adjoining countries and to have used the proceeds from the trade in these minerals to engage in violent conflicts in the DRC and its surrounding areas. In 2010, the United States federal government enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act which, among other things, contained a section addressing the humanitarian goal of ending the violent conflict and human rights abuses in the DRC and surrounding areas which are being funded by the exploitation and trade of “conflict minerals” mined in that region. As required by Section 1502 of the Dodd-Frank Act, a final rule has been adopted by the United States Securities and Exchange Commission (SEC) which requires, beginning on or before May 31, 2014, all publicly reporting companies for which conflict minerals are “necessary to the functionality or production” of products they manufacture or contract to manufacture to make disclosures about their use of “conflict minerals” in their products and manufacturing processes. NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 18 of 22 “Conflict minerals,” as defined in the final rule, include cassiterite, columbitetantalite and wolframite (and their derivatives, tin, tantalum and tungsten), gold and any other mineral or its derivatives determined by the Secretary of State to be funding conflict in the Covered Countries. 5.1.1.1 Conflict Minerals Policy Skyworks Solutions, Inc. is committed to the responsible sourcing of minerals. We have established programs to regularly evaluate our supply chain and require our suppliers to do the same. Suppliers are prohibited from supplying Skyworks with materials known to be derived from the DRC or adjoining countries that have not been confirmed as “DRC Conflict-Free” via a recognized and credible third party process such as the Conflict Free Sourcing Initiative’s Conflict Free Smelter Program (CFSP). Global Reference Documents SQ03-0337 – Supplier Sustainability Specification SQ03-0452 – Conflict Minerals 5.1.2 Slavery and Human Trafficking Prevention (Freely Chosen Employment) As a member of the Electronics Industry Citizenship Coalition (EICC) we have shown our commitment to environmental and social responsibility. Since 2004, the EICC has built upon the Code of Conduct which prohibits the use of forced, bonded, indentured labor or involuntary prison labor. We require our suppliers to develop their systems in alignment with the Code and take seriously all forms of non-conformance. The EICC also had a Freely Chosen Employment (FCE) task force (on which Skyworks was a participating member) designed to help identify opportunities to share best practices among members, expand the Code of Conduct, and make recommendations on available tools and training. Skyworks (both Skyworks directly and all our supply chain partners) requires compliance to all labor and ethics laws as applicable to the country where work is being performed. We further prohibit the use of human trafficking or slavery, including involuntary or bonded labor, or indentured servitude. Labor policies can be referenced on our intranet site at: http://skylink/Dept/HR/Pages/Policiesand-Guidelines.aspx . Ethics policies can be referenced on our intranet site at: http://skylink/Dept/Legal/Pages/Codes.aspx. Note: These are intranet links and do not function outside of Skyworks. Specific requirements for our supply chain are captured within the Supplier Sustainability Specification – SQ03-0337. 5.2 Health & Safety Health & Safety programs are developed, implemented, and managed by the Skyworks Health & Safety Dept. Policies and programs ensuring conformance to the Sustainability Policy, this manual, and the EICC Code of Conduct can be NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SQ01-0002 Rev. 13 Page 19 of 22 referenced on the Skyworks’ intranet site at: http://skylink/Dept/EnvSafetyHealth/Pages/OSH.aspx Note: This is an intranet link and does not function outside of Skyworks. 5.3 Environmental Environmental programs are developed, implemented, and managed as defined within this manual in Sections 1-4. Policies and programs ensuring conformance to the Sustainability Policy, this manual, the ISO 14001 standard, and the EICC Code of Conduct can be found throughout this manual and on the Skyworks’ intranet site at: http://skylink/Dept/EnvSafetyHealth/Pages/green-initiatives.aspx Note: This is an intranet link and does not function outside of Skyworks. 5.4 Management System Sustainability programs are developed and implemented via established management systems as defined by the Skyworks Quality Manual (SQ01-0001) and in this manual in conformance (as defined in the scope of each applicable program) to ISO 14001, ISO 9001, TS 16949, the EICC Code of Conduct, and applicable regulatory and customer requirements. The Skyworks Quality Manual can be reference on our external website at: http://www.skyworksinc.com/downloads/quality/skyworks_systemmanual.pdf 5.5 Ethics Ethics programs are developed, implemented, and managed by the Skyworks Legal Dept. Policies and programs ensuring conformance to the Sustainability Policy, this manual, and the EICC Code of Conduct can be referenced within the Skyworks Code of Business Conduct and Ethics. The Code of Business Conduct and Ethics can be referenced on our external website at: http://www.skyworksinc.com/downloads/investors/1CodeofEthics.pdf 5.6 Supply Chain Requirements Code of Conduct and Skyworks specific requirements are communicated to our Supply Chain via the Supplier Sustainability Specification (SQ03-0337). These requirements are captured under the overall supplier requirements as specified in the Supplier Quality Manual (SQ02-0020) and are referenced internally in the Design & Development and Supply Chain Sustainability Operational Controls doc. – SQ02-0034. 6 Glossary of Terms (Definitions) Code of Conduct EMS The Electronics Industry Citizenship Coalition Code of Conduct. It is available at: http://eicc.info/eicc_code.shtml Environmental Management System – Comprised of Sec. 4 of the Sustainability Systems Manual, NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual SOP Sustainability SQ01-0002 Rev. 13 Page 20 of 22 manufacturing site specific EMS programs (level II), and all supporting documentation at each facility. Standard Operating Procedure Operating according to business practices that meet the needs of the present without compromising the ability of future generations to meet their own needs. At a minimum, this encompasses the areas of Environmental, Labor, Health & Safety, Ethics, and Management Systems. 7 Revision History Rev. 1 2 3 4 5 Description of Change Initial release – Replaces NP-M-0009 and elevates to Level I (corporate) status. Sec. 2.1: Deleted “sole.” Sec. 2.5: Added SQ02-0014, deleted all Mexicali document references. Added MX-SAA-0036. Sec. 4.2: Added allowance for translation of Env. Policy to foreign languages. Sec. 2.5: Deleted WB-0014-ENV (obsolete) Sec. 3: Updated flow chart to include “Linear Products” BU. Sec. 4.2: Added the phrase “or equivalent” to the “Direct translations” allowance for the Env. Policy to foreign languages. Complete re-write to: 1. Update to ISO 14001 2004 and 2. Include design and development (BU’s) in scope. Added “Reference Documents” in specific sections as needed. Author Troy Schulze Submit Date 12/03/03 Troy Schulze 7/12/04 Troy Schulze 4/5/05 Troy Schulze 7/21/05 Troy Schulze 1/31/06 Added references to “Environmental ICAR/IPAR,” “EMS Management Review,” and “Environmental Internal Audit.” 4.5.5 – Internal Audit – Removed NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual 6 7 8 9 10 reference to Quality Dept. responsibility. Revised signature page 2.5 Reference Documents – Deleted obsolete documents and added WB0001-ENV. 2.6 EQM Flow Chart – Updated. 3.0 Skyworks Structure & Responsibility – Updated flow chart. 4.3.2 – Legal and Other Requirements – Added detail that programs are developed on a site specific basis. 4.5.1 – Monitoring and Measurement – Added detail that calibration can be a part of specific PM procedures. 4.5.2 – Evaluation of Compliance – Added “Reference Documents.” 2.6 – Updated EMS Doc. Structure chart 3 – Updated Mgt. team chart 4.2 – NEW Environmental Policy 4.2.1 – NEW policy summary statement Cover – Revised signatories 2.6 – Revised flow chart to remove references to LP 3.0 – Removed org. chart and added reference to SQ01-0001 – Quality Manual Removed “LP” references throughout Cover – Revised 4.2.1 – Added methods for policy communication – internally and externally 4.4.1 – Added reference to Contractor responsibilities 4.4.3 – Added reference to the Skyworks Sustainability Report 4.5.3 – Added reference to SQ030258 Cover – New graphic 1.1 – Added “outside of scope” for referenced TTI system currently under development SQ01-0002 Rev. 13 Page 21 of 22 Troy Schulze 1/4/07 Troy Schulze 9/28/07 Troy Schulze 3/6/09 Troy Schulze 1/5/10 Troy Schulze 1/31/11 NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system. Skyworks Solutions, Inc. Sustainability Systems Manual 11 2.5 – Separated out “EMS” docs. and “Operational Controls” 2.6 – New chart 4.4.2 – Added statement identifying how “competency” is determined. 4.5.2.2 – Added SQ03-0337 to reference docs. Minor wording revisions / corrections throughout Changed title from “Environmental Quality Manual” to “Sustainability Manual.” SQ01-0002 Rev. 13 Page 22 of 22 Troy Schulze 10/10/12 Environmental Policy re-write and change to Sustainability Policy Sec. 1-3 modifications to support changing the “Environmental Policy” to the “Sustainability Policy.” 12 13 Added Section 5: Sustainability Programs Sec. 5.1.1 – Conflict Minerals Troy Schulze Updated the general overview and policy statement Sec. 1.1 – Deleted the “under Troy Schulze development” language for TransTech, now putting them fully in-scope. Sec. 2.5 – Deleted “under development” in reference to TransTech’s EMS doc. Updated EICC Code of Conduct revision #. Sec. 4.4.5 – Added reference to SQ03-0294 – Control of Documents of External Origin Sec. 5 – Deleted language about Labor and Ethics docs. Sec. 5.1.1.1 – Added reference to the CFSI’s Conflict Free Smelter Program (CFSP) 5/2/13 5/27/14 NOTE: Printed versions are uncontrolled. The latest revision is available from Skyworks document control system. Contact Document Control for assistance. Electronic versions are uncontrolled except when accessed directly from Skyworks Document Control system.