As a global leader building wireless solutions that empower businesses and industries to transform and thrive in the connected economy , Sierra Wireless is continually committed to improving the economic, social and environmental impact of our business operations. Please read our 2017 Corporate Social Responsibility report to learn about the breadth of our initiatives.

Code of Business Conduct

Our commitment to social responsibility is grounded in our Code of Business Conduct which mandates that we:

• maintain the highest standards of integrity when conducting Company business and in dealing with our suppliers, customers, competitors, shareholders and each other;
• comply with the letter and the spirit of all laws, rules and regulatory requirements applicable to our business;
• are committed to a workplace that values the diversity of employees, is free of any type of discrimination and harassment, and is an environment in which all employees can work safely; and
• respect the employment rights of employees and others, including:
• freedom of choice,
• prohibition of the use of forced or child labour,
• fair renumeration in accordance with applicable minimum wages,
• compliance with the maximum number of working hours as set out in applicable laws and regulations,
• recognition of the right of free association of employees and the rights of workers to freely join labour unions, seek representation and join workers’ councils in accordance with local laws, and
• the right to have a workplace that is healthy and safe

Our Code of Business Conduct applies to all employees, independent contractors, officers and members of the board of directors and on an annual basis we require all of those who are subject to our Code of Business Conduct to review and acknowledge their compliance with the Code of Business Conduct.

Sierra Wireless is committed to conducting business in accordance with the highest standards of business conduct and integrity. As part of this commitment, Sierra Wireless sources materials and components from environmentally and socially responsible suppliers. In particular, Sierra Wireless supports the principle of freely chosen employment and we do not support the use of forced labour in any of its forms, including slavery and child labour.

RBA Commitment

The Responsible Business Alliance (RBA) is an industry initiative championing social and environmental responsibility. As a Member of the RBA, Sierra Wireless fully supports the vision and goals of the RBA:

Vision: Through the application of high standards we can create better social, economic and environmental outcomes for all those involved in the Electronics and ICT supply chains. This includes increased efficiency and productivity for customers and suppliers, improved conditions for workers, economic development and a cleaner environment for local communities.

Mission: To deliver these benefits through a shared approach to implementing the RBA Code of Conduct. This approach will reduce duplication, focus efforts on positive social and environmental change, build supply chain capabilities in social responsibility and employ a process that solicits feedback from stakeholders.

RBA Code of Conduct: The RBA Code of Conduct is a set of detailed standards on social, labour, health and safety, environmental and ethical issues applicable to the electronics industry supply chain. The standards set out in the RBA Code of Conduct reference international norms and standards including the Universal Declaration of Human Rights, ILO International Labor Standards, OECD Guidelines for Multinational Enterprises, ISO and SA standards, and many more. The RBA Code of Conduct includes detailed provisions related to freely chosen employment and prohibits the use of any form of forced labour or child labour in any stage of the electronics manufacturing process. The RBA Code of Conduct can be viewed here.

Sierra Wireless commits to progressively align its own operations with the provisions of the RBA Code of Conduct.

Wherever possible, Sierra Wireless will seek to adopt the RBA approach and tools in practical ways in the spirit of the industry’s common goals.

Environmental, Health and Safety (EHS)

Sierra Wireless is committed to minimizing the environmental impact during the design, manufacture, distribution, use and disposal of our products.

We are also committed to promote a safe and healthy workplace and environment for our employees and contractors, and to establish and maintain safe working practices through proper procedures and direction.

As a result Sierra Wireless will:

• Strive for continuous improvement in its environmental, health and safety management systems and in the environmental quality of its products, processes, and services.
• Continue to provide a safe and healthy work environment and ensure that employees are trained, informed and motivated to act safely and to respect the environment.
• Comply with all applicable EHS regulatory requirements including regular risk assessments.
• Require our suppliers to comply with our restricted substance requirements.
• Establish goals and objectives in the pursuit of continual improvement of our EHS performance in all activities, including the development of new products and processes.
• Track and document energy consumption and greenhouse gas emissions at the corporate level.
• Communicate with our customers, employees, and other stakeholders to ensure alignment of the company’s EHS policy and performance with the needs and expectations of those stakeholders.

Sierra Wireless does not directly operate any factory fabrication. We mandate that all our contract manufacturers maintain at least ISO 14001 environmental standard and align with OHSAS 18001 health and safety standard.

Conflict Minerals

Beginning in 2013 we implemented a conflict minerals program that includes due diligence measures which are consistent with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Since 2013 we have filed a Conflict Minerals Report annually with the SEC and copies of the reports are available using the link below.

For further information on our conflict minerals program including general inquiries and customer inquiries please contact conflictminerals@sierrawireless.com.

• Conflict Minerals Policy
• Conflict Minerals Report - 2016 / 2015 / 2014 / 2013
• Conflict Minerals Customer Statement

Supplier Social Responsibility

We expect any suppliers with which we do business to adhere to the same social, environmental, labour, health and safety and ethical standards that we apply to our business activities and to have in place programs and processes to ensure that our supply chain is free of any form of forced or child labour. Further, we contractually require our first-tier suppliers and primary contract manufacturers to acknowledge compliance with the RBA Code of Conduct and Sierra Wireless’ EHS standards and Conflict Minerals Policy.

Audit and Compliance

One of the most fundamental programs the RBA provides to its members and Applicant Members is the Validated Audit Process (VAP). Established in 2009, the VAP program has completed more than 1,000 audits of compliance with the RBA Code of Conduct and finalized its fifth audit protocol. As the program has grown it has become more complex, with hundreds of auditors from nine firms executing the protocol in more than 20 countries.

Audits carried out on RBA Member and Applicant Member facilities and their suppliers' facilities are completed by independent, third-party auditors specially trained in social and environmental auditing and the VAP audit protocol. The RBA offers training for auditors and corporate audit program managers in VAP audits. The training is run by an internationally-recognized, non-profit supply chain sustainability group during multi-day, in-person training sessions that take place several times per year.

In addition to the RBA VAP, Sierra Wireless has implemented its own audit program using trained auditors to monitor compliance with the RBA Code of Conduct. Sierra Wireless’ audit results and those done using the RBA VAP program are shared through RBA Online, a proprietary system for sharing audit results across the RBA membership. This is also true of audits conducted directly on Sierra Wireless. This allows our customers to transparently assess our overall compliance. Companies not meeting the standard set by the RBA Code of Conduct are offered training through RBA and are removed from our supply chain if non-compliance persists.

Reporting and Escalation

Beyond the standard audit process detailed above, Sierra Wireless may receive reports alleging a violation of our Code of Business Conduct or the RBA Code of Conduct. Reports may be received by Sierra Wireless both internally and externally, including via the following two channels:

• Directly via businessconduct@sierrawireless.com
• Indirectly by RBA members through RBA Online and RBA’s escalation processes.

Sierra Wireless will investigate and assess the circumstances of any alleged violations which are brought to our attention and determine any follow on action that may be required. In 2016, we were made aware of one violation of the RBA Code of Conduct which was addressed directly with the company involved and corrective actions were taken by that company with their supplier.

Commitment to Continuous Improvement

As a globally operating company, Sierra Wireless recognizes that supply chain social responsibility is an ongoing process and is committed to continuous improvement. We leverage the industry leading RBA standards to provide us with a range of measures to achieve the RBA mission and vision.