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BELKIN MODERN SLAVERY ACT TRANSPARENCY STATEMENT

INTRODUCTION

Here at Linksys (a division of Belkin International, Inc.) we are committed to the highest standards of ethics and business integrity in our supply chain. Our dedication to this endeavor ensures working conditions are safe and workers are treated fairly, with respect and dignity. We are committed to ensuring that manufacturing processes are conducted in an environmentally conscious and socially responsible manner.

Belkin does not tolerate modern slavery or human trafficking anywhere in our organization or in our supply chains and is committed to taking all necessary steps to ensure the risk of modern slavery is eliminated as far as possible.

Our statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 and identifies the steps we have taken to ensure slavery and human trafficking does not form part of our supply chains or anywhere within our business.

Our group and supply chain structure

Our high ethical standards are at the core of how we work as an organisation. They play an integral part in guiding decisions and processes in our supply chain. We partner with people and organizations that align with our beliefs and standards. Belkin employs people worldwide and conducts business in countries all around the world. Our operations extend to the United States, Canada, the United Kingdom, Australia, New Zealand, Germany, the Netherlands, France, Spain, Greece, Italy, Sweden, Denmark, Norway, Russia, Mexico, India, Dubai, Brazil, Singapore, Malaysia, the Philippines, Hong Kong, Japan, Korea, Thailand and China.

Our supply chain (where we purchase goods and services) is sourced from countries all over the world. Vendors are carefully vetted to make sure they align with not only our legal and contractual obligations, but also our supplier code of conduct. This code of conduct covers topics such as labor, health and safety, environment, management, and ethics. One of the benefits of having a diverse supply chain is our ability to establish and quickly apply best practices to our suppliers around the world.

Our policies

Our non-tolerant attitude towards issues such as human trafficking and slavery is confirmed in our company policies that govern our own conduct and that of our suppliers.

Our conduct

Belkin’s Employee Code of Conduct governs the conduct of every Belkin employee in our organization. The Code of Conduct is an agreement where our employees attest their compliance and confirm they carry on business with high ethical standards and in compliance with law.

We have set up a dedicated reporting service – the Belkin Ethics Hotline – in order for employees to anonymously report any potential breaches of the Code of Conduct. An employee is also able to report a concern in relation to the Code of Conduct by logging on to our dedicated ‘Ethics Point’ system online. The Belkin Ethics Hotline and Ethics Point is overseen by our Human Resources group and our Compliance group who are devoted to analyzing the facts and circumstances provided in any report submitted by an employee and carrying out a thorough investigation.

Our suppliers’ conduct

Our firm stance on eradicating human trafficking and modern slavery is echoed in our implementation and enforcement of a certification requirement for our supplies. Belkin requires suppliers to certify that any materials incorporated into Belkin products comply with applicable law regarding slavery and human trafficking, child labour, health and safety, working hours and anti-discrimination legislation in every jurisdiction the supplier is carrying on business. This certification requirement is supported and verified by Belkin’s supplier audit process which is described below as well as the mandatory contractual obligations we impose on our suppliers in our standard supplier agreements.

Our due diligence and risk assessment

We are extremely careful when taking on a new supplier. Accordingly, we carry out thorough due diligence to ensure the potential supplier conforms to the Supplier Social Accountability Audit Checklist (SSAAC). Our stringent audits are performed by our internal staff rather than a third party agency. The results of the due diligence efforts are then further scrutinized by our compliance and on-boarding teams who make a determination as to whether the potential supplier conforms to our requirements.

All new suppliers are carefully vetted by our respective teams in order to become an approved Belkin vendor. Our sourcing team looks at price, capacity and capability, and we have a special task force that evaluates the quality processes to make sure the supplier is aligned with our high quality standards. Furthermore, we have environmental and social accountability standards that include identification of any risk of human trafficking or modern slavery entering our supply chain. The supplier is audited in accordance to these metrics. Based on our findings we can then make informed decisions to determine if the supplier is aligned with our principles in each respective area. If a supplier is not in accordance with our standards and code of conduct, they will be rejected.

In addition to annually scheduled audits of both first and second tier suppliers and raw material suppliers, our internal quality, regulatory, environmental and social accountability teams complete a scorecard for our suppliers quarterly. Issues are outlined by the respective department immediately. We perform social accountability audits by regularly conducting onsite inspections to assess our suppliers’ practices with respect to treatment of its workers and assessing any potential risks including modern slavery and human trafficking. We audit each supplier against the SSAAC. The content of the SSAAC is then used to create a Supplier Social Accountability Audit Report (SSAAR) in respect of each supplier. Each supplier’s SSAAR report is assessed by our compliance experts who determines whether a supplier conforms to our requirements.

As part of our continuous improvement program we follow internally and with our suppliers, we take remedial actions if necessary when findings from the scorecards are reviewed with each supplier. We also have a Corrective Action/Preventative Action (CAPA) procedure. Based on our findings from an audit, we can deliver a CAPA to the supplier for any issue we find. Depending on the severity, the corrective actions can vary from simple issues such as documentation updates, training and new procedures or more complex issues that can result in halting production and rejection of goods. Each team (quality, environmental, etc.) has the power to issue corrective actions at any point in time and prohibit the use of a supplier until the corrective actions are addressed.

We maintain the utmost vigilance to extinguish potential risks of human trafficking and modern slavery within our supply chains and throughout our organization. We are committed to conducting standard and thorough due diligence processes on our suppliers and their supplier chains and operations.

Our training

Our mandatory training must be completed by all employees annually and is designed to ensure our employees understand their obligations under the Code of Conduct. For employees and managers who work in global supply chain roles, we provide specific training relating to identifying and combatting the risks of modern slavery and human trafficking. Our training is delivered to employees in a diverse range of mediums such as online courses, in-person meetings with management and written resources.

Key performance indicators

Social accountability and environmental stewardship in our industry is a key priority for us. This includes understanding the impacts of our decisions and remaining accountable, mindful and responsible. We listen to the needs of not only our customers and employees but our suppliers as well. Since 2007 we have maintained a whistleblower line to encourage all the reporting of all concerns regarding the workplace. All reported concerns are promptly reviewed and investigated.

We measure the effectiveness of our high ethical standards by looking at a few key metrics.

  • 100% of any new finish goods suppliers are audited before we begin any work with them
    • New supplier training and qualification includes several topics such as worker rights, age of workers, wage of workers, safety and discrimination.
  • 87% of all of our finish goods suppliers are audited biannually
  • 100% of suppliers also have quarterly evaluations via our scorecard
  • Several of our component suppliers (2nd tier) suppliers are also audited annually. We rely on our 1st tier suppliers to conduct these audits and provide support and training as needed.
  • Additional supplier training and employee training is conducted throughout the year as needed