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Our Code of Conduct promotes honest and ethical conduct, compliance with applicable laws and regulations, and protection of our business interests.
It applies to all of our employees, consultants, temporary workers, officers, and members of the Board of Directors, regardless of location, seniority level, business unit, function, or region, and is supported by written programs, training, investigations, root cause analysis, risk assessment, and monitoring.
Our Code lays out guidance on making ethical decisions while conducting business on behalf of Illumina.
Key topics include fraud prevention, bribery and corruption, anti-discrimination, anti-harassment, human rights, diversity and inclusion, employee safety, corporate social responsibility, marketing and sales claims, and government interaction.
and Training Our Compliance Committee directs and oversees compliance activities, including administration of our Code of Conduct.
We actively engage our employees in our ethical governance program to ensure they have a thorough understanding of what is expected of them.
Employees and managers are expected to behave ethically, ask questions when in doubt, and report any wrongdoing.
We offer Code of Conduct training through our enterprise learning management system (LMS).
All employees receive training when onboarded and annually.
Anti-Corruption and Anti-Bribery We forbid bribery and corruption in the conduct of our business, and comply with anti-corruption laws wherever we operate.
We support businesses working against corruption in all its forms, including extortion and bribery, and expect all our partners to maintain the same standards.
Anti-Competitive Behavior We aim to compete and succeed in a fair and honest marketplace, and do not engage in unethical, unfair, or illegal communications with competitors.
We always deal fairly with customers, suppliers, competitors, and employees, and do not take unfair advantage of anyone.
We do not enter into formal or informal agreements with competitors to engage in any anti-competitive behavior, and strictly comply with all related laws.
We forbid anti-competitive behavior, antitrust, and monopoly practices.
Pricing We maintain a responsible approach to pricing our products.
Illumina is committed to offering prices that enable broad access to genomic technology.
Most of Illumina’s customers are not on a supply/ purchasing agreement.
Illumina’s pricing reflects its value proposition and enables Illumina to continue to innovate for our customers and accelerate access to genomics for all.
Professionals and Organizations As a company that manufactures and sells products and services for medical use, we are subject to rigorous standards of conduct regarding our interactions with healthcare professionals and organizations.
The Illumina Policy for Interactions with Healthcare Professionals and Organizations guides how we conduct business with these groups, together with ensuring compliance with applicable laws, regulations, and standards of conduct.
the Universal Declaration of Human Rights and the United Nations Global Compact.
Right to exercise freedom of association • Fair wages and working hours • Protection of privacy • Safe workplace • Elimination of child and forced labor • Equal opportunity Human Rights Impact Assessment In rights impact assessment to review additional opportunities.
We have highlighted a few of our key Human Rights Policy pledges: Elimination of Child Labor, Forced Labor, and Human Trafficking We condemn all forms of exploitation of children, will not recruit child labor, and support the elimination of exploitive child labor.
We support the elimination of all forms of forced, bonded, indentured, and involuntary prison labor, and human trafficking.
We will never knowingly use a supplier, contractor, channel partner, or business partner, engaged in child, forced, or slave labor, nor will we condone such practices.
Safe Workplace Our Injury and Illness Prevention Program and Environment, Health and Safety (EHS) Management System Policy enable us to proactively manage risk and engage employees.
We are committed to creating a work environment free from violence and harassment of any kind that threatens, intimidates, or coerces another person.
Equal Opportunity and Non-Discrimination We support the elimination of discriminatory practices with respect to employment.
In addition, the Illumina State Sponsors of Terrorism (SST) Policy prohibits business in or with SST countries, as defined by the US Department of State, and the Illumina Sanctioned and Embargoed Countries Policy prohibits business in or with parties (country, entity, individual) that violate any applicable trade sanct...
This policy is based on the foundation of compliance with economic sanctions, laws, and regulations administered by the United States Department of the Treasury, Office of Foreign Assets Control (OFAC), and all applicable trade sanction regulations in the countries where we do business.
It provides a risk-based approach to commercial and philanthropic opportunities in sanctioned and embargoed countries.
We take concerns about the ethical use of Illumina technology and its impact on human rights very seriously and have implemented contractual and procedural safeguards to prevent misuse.
Our customer agreements outline our expectations regarding the ethical use of our technology and the steps we can take in the event of a possible violation.
In addition, we have expanded and enhanced the sales-review process for entities and geographies of heightened concern in order to monitor and enforce this commitment and prevent sales that could result in misuse or human rights concerns before they happen.
Illumina will not hesitate to cease sales and servicing in the event of a confirmed ethics or human rights-related concern.
and manage emerging issues to identify potential risk and opportunities.
The Internal Audit Department provides independent and objective feedback to the Board Audit Committee.
We continue to assess risks in our business, and endeavor to ensure that all employees adhere to our ethics and compliance protocols.
Our Business Continuity team is working toward standardized processes across our manufacturing network.
a sustainable, just, and resilient future for all.
We are committed to climate action and the integration of climate resilience planning into our risk and opportunity program, and we support the calls for greater data transparency.
We recognize that the risk and opportunities span both physical risk (extreme weather) and transition risks (regulations, technology, policies).
In scenario analysis using 2°C, 3°C, and 4°C models.
See the Appendix for additional details on our Task Force on Climate-related Financial Disclosures (TCFD) index and climate scenario insights.
Progress in genomics holds immense promise to revolutionize clinical care.
With the large-scale analysis of genomic data, scientists can better identify rare and undiagnosed diseases, discover variants associated with cancer, and enable insights into infectious disease research.
strong privacy and data security protections, is essential to promote trust and support innovation.
How we handle personal information is aligned to our four fundamental privacy guiding principles.
https://www.illumina.com/company/legal/privacy.html https://emea.illumina.com/content/dam/illumina-marketing/documents/company/privacy-principles_120219.pdf Cybersecurity Genomics data is powering positive progress around the world.
Our technologies and services inherently involve handling large amounts of genomic and health data that must be protected, making cybersecurity integral to achieving our company mission.
Magnifying Our CSR Impact Through Our Supply Chain Supply Chain Overview Our suppliers are critical to our mission.
Together, we can magnify the positive impact to our customers and communities where we operate.
Our global supply chain consists of suppliers, sub-contractors, channel partners, manufacturing sites, distribution centers, and customers.
Our main manufacturing facilities are in the US and Singapore.
We consider it business-critical to work with suppliers who share our commitment to integrity, and who support an ethical and compliant culture.
The Illumina Supplier Code of Conduct is consistent with commitments we made both as a signatory of the United Nations Global Compact and as a member of the Dow Jones Sustainability World Index.
All new suppliers are required to acknowledge the Supplier Code of Conduct in order to complete the onboarding process.
In of Conduct to better reflect our growing CSR program and expectations of our supply partners.
Our updated Supplier Code of Conduct now includes guidance for suppliers to provide options that support environmentally preferable products (EPP) that meet performance requirements when submitting proposals to Illumina for commodities and services, wherever possible.
Our internal buying teams will prioritize purchasing EPPs when competing products have comparable function and value.
and the Illumina Human Rights Policy • Ensure a safe and healthy workplace • Demonstrate social and environmental responsibility • Conduct business in an ethical manner Supplier Diversity Program Illumina is committed to establishing collaborative partnerships with qualified small and diverse suppliers and recognizes t...
Globally, we encourage the use of local businesses wherever possible to support economies where our employees work and live.
Our goal is to achieve diverse suppliers by 2030.
OUR SUPPLY CHAIN We have different types of suppliers that range from off-the-shelf packaging material to highly sophisticated reagents.
We split our suppliers into the following categories: direct, indirect, strategic, differentiating, core, transactional, finished medical device, custom spec, off the shelf, internal, external, and services.
We source components, software, equipment and services from across the Americas, Asia, Europe and Africa.
spend Strategic Supplier Sustainability Through our supplier scorecard program, we have assessed our strategic suppliers for commitments to reduce their environmental footprint.
https://www.illumina.com/content/dam/illumina-marketing/documents/company/illumina-supplier-diversity-program.pdf https://www.illumina.com/content/dam/illumina-marketing/documents/company/supplier-code-of-conduct.pdf https://www.illumina.com/content/dam/illumina-marketing/documents/company/supplier-code-of-conduct.pdf ...
This process involves conducting initial risk assessments when onboarding new suppliers, and conducting periodic assessments of performance.
Modern Slavery Illumina is committed to conducting its business lawfully and with integrity.
We work to continually strengthen our practices to ensure no human trafficking, slavery, or forced or compulsory labor occur in any part of our supply chains and global operations.
Furthermore, through our Conflict-Free Minerals Policy we expect all our suppliers to establish their own due diligence program to ensure supply chains are free of conflict minerals and to make their due diligence measures available to Illumina upon request.
Illumina routinely evaluates its suppliers to ensure that they are adhering to Illumina’s expectations and values.
The Illumina Channel Partner Code of Conduct requires that channel partners match Illumina’s commitment to business integrity, ethical conduct in the marketplace, adherence to all applicable laws, and the fundamental elements of human rights.
Illumina is a member of the Advanced Medical Technology Association (AdvaMed) and MedTech Europe.
ESG AppendixIntegrity https://www.illumina.com/content/dam/illumina-marketing/documents/company/illumina-ca-transparency-supply-chain-modern-slavery.pdf https://www.illumina.com/content/dam/illumina-marketing/documents/company/illumina-ca-transparency-supply-chain-modern-slavery.pdf http://www.responsiblebusiness.org/c...
The supplier quality management life cycle incorporates the following phases: • Initial risk assessments • Qualification • Audits • Monitoring Working with our suppliers, we can focus on the customer experience, continual improvement, effectiveness of our quality management system, and compliance.
Product Quality Quality Policy Illumina is dedicated to being the leading provider of integrated solutions that advance the understanding of genetics and health.
We will achieve this through our focus on the customer experience, our commitment to continual improvement, maintaining the effectiveness of our quality management system, and complying with regulatory requirements.
product life cycle, ensuring that policies and objectives are in place and product quality standards are met to the highest caliber.
M onitoring Supplier Compone nt Qualifi ca tio n Concept Feasibility and Planning Development Pilot Transfer Sustaining The essence of the Illumina quality philosophy is that all employees, both at Illumina and at our suppliers, have the responsibility and discipline to ensure the quality of their own work before passi...
We strive to build quality into our products and processes starting early in the development cycle to ensure that we meet customer expectations.
Partnering With Policymakers to Improve Human Health We believe proactive, responsible engagement with public policy stakeholders translates to sharing accurate and reliable information about genomics and advocating for policies that ensure and promote broad access.
Illumina participates in the political and public policy process with governments and organizations around the world to engage and educate policymakers and key stakeholders on issues that impact our mission and business.
Pursuant to our Code of Conduct, we commit to deal with governments, government agencies, and public officials according to the highest ethical standards and in compliance with all applicable laws.
Our Global Government Affairs team is responsible for advocacy activities.
They may also provide expertise on policy and specific regional issues.
on our behalf • Respective legislative body contacted We file a similar publicly available lobbying report at the state level as required by state law.
Disclosures & Transparency Illumina complies with all applicable laws and requirements in connection with its global political and public policy activities.
Trade Associations & Memberships Illumina participates in various trade associations for collaboration and exchange of ideas.
Illumina pays annual dues to a number of trade and industry associations, some of which utilize a portion of membership for non-deductible state and federal lobbying and political expenditures.
As part of this policy, we disclose memberships in trade associations for which we contributed over $as well as the total amount of such dues.
Section Code, such as payments to organizations designated as 501(c)(4) and 501(c)(6).
Oversight How we interact with policymakers must align with our core values, ethical responsibilities and legal obligations.
The Nominating/Corporate Governance Committee of Illumina’s Board of Directors oversees this policy and Illumina’s contribution practices.
The Committee maintains responsibility for ensuring all Illumina political activities promote ethical and transparent engagement, advance the Company’s mission, and comply with applicable laws and reporting requirements.
On an annual basis, Illumina will provide an update on the Company’s public policy priorities, political contributions, lobbying expenditures, and information about significant memberships.
About This Report This report was prepared in accordance with the GRI Standards: Comprehensive option.
It has been designed to address disclosures and material issues to provide a comprehensive and integrated view of our commitments, progress, and activities related to sustainability and corporate social responsibility.