Our goal at Garmin is to ensure human rights are upheld for all workers involved in our supply chain and individuals experience safe, fair and non-discriminatory working conditions. Garmin supports suppliers who share our belief that fair labor practices and safe working environments are an inherent part of human rights.
California Transparency in Supply Chains Act of 2010
On Jan. 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect. This law was designed to increase the amount of information made available by certain manufacturers and retailers regarding their efforts, if any, to address the issue of modern slavery and human trafficking. Specifically, the act requires certain manufactures and retail sellers to “disclose their efforts to eradicate modern slavery and human trafficking from their direct supply chains for tangible goods offered for sale.”
Our supply chain relies on sources of materials and labor from all around the world. The raw materials used in our products are produced globally, and our products are manufactured domestically and internationally. Garmin has a cross-functional team of associates who are responsible for supply chain management.
Garmin expects our suppliers to meet and maintain fundamental labor and human rights standards. We conduct periodic surveys and audits of a number of our suppliers to assess and verify compliance. Our Supplier Code of Conduct addresses supplier policies on labor and human rights issues such as maximum working hours, basic wage, respect, equality and restrictions on forced labor. Additionally, our standard supply agreements require suppliers to assure us that products they supply are not produced, manufactured or packaged by forced, prison or child labor.
Garmin conducts periodic surveys and audits of a number of our suppliers to assess and verify compliance with our Supplier Code of Conduct and other supply chain requirements. These surveys and audits include evaluations of compliance with policies implemented to prevent child labor, forced labor, and other human rights issues. We are working to bring these auditing procedures to all of our offices worldwide. While Garmin’s supply chain management processes do not currently include unannounced audits or the engagement of a third party to verify our supply chain or conduct audits, our Supplier Code of Conduct requires all suppliers and entities throughout our supply chain to comply with all applicable laws, regulations and international labor and human rights standards.
Garmin is also committed to educating our workforce about modern slavery and human trafficking and ensuring compliance with applicable laws. Our associate Code of Conduct requires our associates to comply with all applicable laws and regulations, which include those regarding modern slavery and human trafficking. We have standards and procedures in place to encourage associates to report any legal or Code of Conduct violations or concerns, and we will hold associates and contractors accountable for any noncompliance with applicable laws and regulations or our Code of Conduct. Garmin also provides employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery. We intend to update and expand our internal policies and training programs to address the risks of modern slavery and human trafficking as appropriate as our business and supply chain continue to evolve.
Conflict minerals include tin, tantalum, tungsten and gold, also known as 3TG. Although Garmin does not directly purchase any raw 3TG minerals from our suppliers, we purchase component parts from our suppliers that could include 3TG derived from mines in the DRC or adjoining countries.
Garmin collaborates with others in industry through its participation in the Responsible Minerals Initiative (RMI) (formerly known as the Conflict Free Sourcing Initiative), an initiative created to develop control systems regarding smelters and refiners through independently validated audits under the RMI's Responsible Minerals Assurance Process (RMAP). Through the RMAP, the RMI identifies smelters and refiners that produce conflict-free materials. The RMI uses specially trained independent third-party auditors to verify that these smelters and refiners can be deemed conflict-free, then publishes online a list of smelters and refiners that meet the standards of the audit. In addition, RMI developed the Conflict Minerals Reporting Template (CMRT) to standardize the collection of conflict minerals information from suppliers throughout the industry’s supply chains.
Garmin expects each of our suppliers to perform the following:
- Adopt a policy of responsible sourcing of minerals and pass this requirement through its supply chain.
- Implement due diligence processes and mitigation plans to support that policy.
- Comply with our Supplier Code of Conduct.
- Use the Garmin Conflict Minerals Training Program to train and instruct their applicable employees.
- Source materials from socially responsible suppliers.
- Complete and return to us the CMRT in a timely manner and provide us all other information we may request regarding the sourcing of minerals in products they supply.
Copies of the Garmin conflict minerals reports are located below.
If Garmin becomes aware of a supplier that is not in compliance with the supplier expectations set forth in this policy, then we will follow our escalation process and take the appropriate actions to remedy the situation, including possible discontinuance of the supplier relationship.
Suppliers and other external parties are encouraged to contact their regular sourcing channel or Garmin representative if they wish to seek guidance on the application of this approach or if they wish to report suspected abuse. Suppliers, other external stakeholders and associates may report
concerns related to the sourcing of 3TG in Garmin products to the Garmin conflict minerals team and chief compliance officer by emailing [email protected] or by mail to the following address:
Chief Compliance Officer
Garmin Ltd., Mühlentalstrasse 2