Human Rights and Conflict Minerals

Our goal at Garmin is to ensure that human rights are upheld for all workers involved in our supply chain and that individuals experience safe, fair and nondiscriminatory 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 manufacturers 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 our 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

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 Conflict Minerals Fact Sheet

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 standardise 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 applicable employees.
  • Source materials from socially responsible suppliers.
  • Complete and return to us in a timely manner the CMRT, 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 a 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 mailing the following address:

Chief Compliance Officer
Garmin Ltd., Mühlentalstrasse 2
CH-8200, Switzerland

Modern Slavery Act 2015

Our goal at Garmin (Europe) Ltd. is to ensure that human rights are upheld for all workers involved in our supply chain and that individuals experience safe, fair and non-discriminatory working conditions. Garmin supports suppliers who share our belief that fair labour practices and safe working environments are an inherent part of human rights.

The Modern Slavery Act 2015 seeks to increase transparency in supply chains by requiring certain commercial organisations to provide information to the public regarding their efforts to address the issue of modern slavery and human trafficking. Specifically, the Act 2015 requires certain businesses to prepare “a statement of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place.”

GARMIN BUSINESS AND SUPPLY CHAIN STRUCTURE

Garmin is a provider of navigation, communications and information devices, most of which are enabled by Global Positioning System, or GPS, technology. Our products serve the marine, outdoor, fitness, auto, and aviation markets. Our supply chain relies on sources of materials and labour from all around the world. The raw materials used in our products are produced globally, and our products are manufactured internationally. Garmin has a cross functional team of associates who are responsible for supply chain management.

GARMIN POLICIES ON SLAVERY AND HUMAN TRAFFICKING

The Garmin group of companies, including Garmin (Europe) Ltd. (collectively, “Garmin”), Garmin have a zero tolerance policy with regard to slavery and human trafficking. Garmin’s internal Code of Conduct forbids acts constituting human trafficking and slavery, and Garmin has established internal procedures to facilitate the reporting of human rights abuses and violations of our Code of Conduct. Associates responsible for management of Garmin’s supply receive supplemental annual training conducted to help ensure that modern slavery, human trafficking and other human rights abuses have no place in our supply chain.

SUPPLIER ADHERENCE TO GARMIN POLICIES

Garmin has taken a number of measures aimed at eradicating slavery and human trafficking from our direct supply chain. First, Garmin and its affiliates have adopted a Supplier Code of Conduct, which is incorporated as part of our Terms and Conditions of Purchase. The Supplier Code of Conduct addresses issues such as maximum working hours, basic wage, respect, equality and restriction of forced labour, and prohibits suppliers from engaging in involuntary, forced, prison, indentured or slave labour, human trafficking or the hiring of trafficking and debt bondage victims. Secondly, Garmin requires its suppliers and entities throughout its supply chain comply with all applicable laws, regulations and international labour and human rights standards. A supplier’s failure to comply with Garmin’s policies may result in disqualification from doing business with Garmin. Finally, our factories are subject to periodic compliance audits by many of our distributors and other resellers in order to confirm our compliance with applicable laws, regulations and international labour and human rights standards.

This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and constitutes Garmin (Europe) Ltd.’s slavery and human trafficking statement for the financial year ending December 28, 2019.

Garmin (Europe) Ltd.
Date:March 27, 2020