Supply Chain Transparency
Statement on Eradication of Slavery and Human Trafficking
Introduction
Keysight Technologies, Inc., along with Keysight Technologies UK Limited (collectively, “Keysight”), is proud of its record of uncompromising integrity, its commitment to promoting human rights globally, and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. This includes a commitment to comply with both the California Transparency in Supply Chains Act of 2010 (effective January 1, 2012, the “California Act”) and the Modern Slavery Act 2015 (effective October 29, 2015, the “U.K. Act”).
The California Act requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. Similarly, the U.K. Act requires companies that supply goods and/or services in the United Kingdom to disclose information regarding their efforts to eradicate slavery and human trafficking from their own organization and direct supply chains.
This Statement on Eradication of Slavery and Human Trafficking reflects Keysight’s efforts to combat forced and bonded labor in its business and supply chain. It is intended to provide current and potential customers, shareholders, and employees the ability to make a better, more informed choice about the products and services they buy, the investments they make, and the company they support.
The sections below describe Keysight’s efforts to meet the letter and spirit of the California Act and the U.K. Act and address human rights issues generally.
Our Business
Keysight is one of the world’s leading test and measurement companies supplying hardware, software, solutions and services to help accelerate our customers' innovations to connect and secure the world.
Keysight Technologies, Inc. is a United States publicly listed company trading under the symbol KEYS with operations in 140 locations, conducting business with customers in 100+ countries through approximately 14,300 employees. Keysight has entities in many countries, with manufacturing in the U.S., Japan, Germany, Spain, Finland, China and Malaysia. In addition, we use a few selected contract manufacturers. A list of significant Keysight subsidiaries can be viewed in our latest Form 10-K filing with the U.S. Securities and Exchange Commission.
Keysight’s business is organised into the following groups:
Communication Solutions Group serves customers spanning the worldwide commercial communications and aerospace, defense and government end markets. The group’s solutions consist of electronic design and test software, electronic measurement instruments, systems and related services. These solutions are used in the simulation, design, validation, manufacturing, installation and optimization of electronic equipment and networks
Electronic Instrument Solutions Group provides test and measurement solutions and related services across a broad set of electronic industrial end markets, focusing on high-value applications in the automotive and energy industries and measurement solutions for consumer electronics, education, general electronics design and manufacturing, and semiconductor design and manufacturing. The group provides electronic measurement instruments, design and test software and systems and related services used in the simulation, design, validation, manufacturing, installation and optimization of electronic equipment, and automated test software that uses artificial intelligence and machine learning to automate test creation and test execution.
Keysight Global Services Organization provides services solutions including product support services, technical support and training and consulting. Customer demand is fulfilled by trained engineers and technicians through regional support and service centers, located near customers or through on-site teams. Our global presence with localized service proximity is an important factor in sustaining our customers’ solutions, uptime and utilization requirements. We also provide industry-specific services to deliver complete Keysight solutions and help customers reduce their total cost of ownership for their design and test equipment. Our services solutions include the following general types of services:
- Product support services: Comprehensive support that includes repair, parts, and accredited calibrations of Keysight products and solutions.
- Technical support for software and hardware: Customer support for the usage and utilization of our products.
- Professional services: Installation, training and engineering services to optimize equipment adoption, utilization, and design of test processes.
Keysight Global Sales is our direct sales force consisting of sales and application engineers who have in-depth knowledge of the customers’ business and technology needs. Our direct sellers concentrate on providing more complex, end-to-end solutions where customers require strategic consultation. Our application engineers bring deep solution and application expertise to provide a combination of consulting, systems integration and software engineering services that span all stages of the sale, deployment and support of our complex systems and solutions. Our direct sales organizations serve customers globally across the commercial communications, aerospace, defense and government, automotive and energy, semiconductor, general electronics, network test and network visibility markets. To complement our direct sales force, we have an extensive network of channel partners around the world. These channel partners include resellers, manufacturer’s representatives and distributors. They serve thousands of customers across a wide range of end-user markets.
Keysight Enterprise Functions such as Finance, Tax, Global Trade, Logistics, Legal, Workplace Services, HR and Global Sourcing. Resources are spread across the world, typically supporting multiple countries, with centers of excellence providing certain centralized services.
Keysight Technologies UK Limited is registered in England and Wales, and has approximately 550 employees operating from eight offices. The principal activities in the U.K. are sales, service, administration, software research and development and small-scale system production.
Employee Engagement
Keysight and all its employees strictly adhere to the company’s Standards of Business Conduct (“SBC”), which states: “We are committed to respecting human rights throughout our global supply chain and do not knowingly conduct business with any individual or company that participates in the exploitation of children (including child labor), physical punishment, forced labor or human trafficking. We expect that anyone who conducts business on our behalf will operate ethically, in compliance with the law and in a manner that is consistent with our Standards and our policies.”
Annually, all Keysight employees complete training on our code of conduct and certify compliance with the SBC. In addition, Keysight conducts specialized training for procurement employees that emphasizes the importance of ensuring that Keysight’s suppliers abide by Keysight’s Supplier Code, including its prohibitions on slavery and human trafficking.
Supply Chain Management
Keysight has manufacturing facilities in US, Germany, Japan, Spain, Finland, China and Malaysia. In addition, we use a few selected contract manufacturers. Our global supplier base consists of approximately 10,000 suppliers from more than 70 countries. In respect of the U.K., the majority of the supply chain is driven by the sale of products manufactured by Keysight in other countries. Keysight UK also has direct suppliers who provide facilities management, payroll, logistics, legal and financial services.
Keysight maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain. These include Keysight’s Supplier Code of Conduct (the “Supplier Code”), its Human Rights and Labor Policy and the SBC.
The Supplier Code requires all Keysight suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking.” The Supplier Code also requires Keysight suppliers to abide by the bans on forced or compulsory labor set forth in International Labour Organization guidelines, including Article 2 of the Forced Labour Convention 29 and Article 1 in the Abolition of Forced Labour Convention 105.
Keysight communicates to all suppliers its expectation that they comply with our Supplier Code, including the provisions barring forced labor, slavery, or human trafficking. Keysight further requires suppliers to certify their compliance with the Supplier Code and all its provisions.
Verification
Keysight has the right to audit all suppliers for compliance with its Supplier Code. Keysight employs an independent third party to audit and evaluate suppliers’ compliance with the Supplier Code, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in both the California Act and the U.K. Act.
Accountability
Keysight has a zero-tolerance policy for violations of laws banning forced labor, slavery and human trafficking. Keysight’s contractual terms and conditions permit the termination of a supplier for even a single violation. Similarly, Keysight’s employee disciplinary policy permits a range of measures, up to and including termination, for Keysight employees involved in any misconduct related to human rights abuses.
Keysight employees are required to speak up if they see or suspect conduct that violates the SBC, Keysight policies, or the laws and regulations that apply to our business. Keysight has an Open Door Policy that allows employees to report concerns to any level of management. Keysight also maintains a Compliance Hotline, which is operated by an independent reporting service that allows individuals to communicate concerns anonymously (where permitted by law) and confidentially, via phone or internet.
Conclusion
It is essential – and it is Keysight’s expectation – that all persons involved in the production of our products, whether Keysight employees or not, are treated with dignity and respect. Keysight will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain.
This statement pertains to all of Keysight for our fiscal year 2022 and beyond. It has been specifically reviewed and approved by the Board of Directors of Keysight Technologies UK Limited, in accordance with the requirements of the U.K. Act.
Date April 22, 2022
Ingrid Estrada
Senior Vice President, Chief People and Administrative Officer, Chief of Staff
Keysight Technologies, Inc.
Chris Trim
Managing Director
Keysight Technologies UK Limited
