SALIENT HUMAN RIGHTS POLICY

SCOPE:

This Salient Human Rights Policy (“Policy”) applies to Credo Technology Group Holding Ltd and all its subsidiaries (together with its subsidiaries, “Credo”), and summarizes the standards that must guide our actions. This policy applies to all Credo employees worldwide, including part-time, temporary and contract employees.

PURPOSE:

Credo is committed to the highest possible standards of ethical, moral and legal business conduct on a global level. This Policy formalizes Credo’s commitment to the preservation and promotion of the fundamental rights of all humans1. This Policy reinforces Credo’s values in its Code of Business Conduct and Ethics, that one of our Credo’s most valuable assets is its reputation for integrity, professionalism and fairness. Credo and our employees recognize that our actions are the foundation of our reputation and that adhering to this Policy and applicable law is imperative to our success. This Policy embodies our commitment to conducting business with the utmost respect for global human rights. We comply with all applicable laws and respect each Human Right identified herein, and we expect our business partners to do the same.

POLICY:

Human Rights. As a global corporation, Credo recognizes that we have a responsibility to encourage ethical business conduct. Credo will respect generally acknowledged human rights principles and will not tolerate any known human rights abuses within our company, our operations, our supply chain, or any other course of conducting business. This Policy is intended to cover, at a minimum, the following human rights (each, individually, a “Human Right” and collectively, the “Human Rights”) that Credo identifies as being fundamental human rights principles:

  • Diversity;
  • Rights of workers2:
    • Anti-discrimination;
    • Anti-harassment3;
    • Forbidding human trafficking and modern slavery;
    • Forbidding child labor;
    • Respecting the right to organize and freely associate.
  • Compliance with all applicable labor laws4:
    • Minimum wage requirements;
    • Working hours;
    • Benefit requirements;
    • Health and safety in the workplace.
  • Environmental responsibility and environmental impact;
  • Ethical and legal distribution of Credo products5;
  • Humane business practices within our supply chain;
  • Anti-corruption6; and
  • Protection of privacy7.

Compliance Measures. Credo’s policies and codes of conduct reflect our dedication to respecting human rights principles; such policies and codes of conduct are available to all members of Credo worldwide.

Credo’s commercial contracts routinely obligate customers8, suppliers, vendors, and any other individual or entity with whom Credo engages in business to represent and warrant that the party will comply with all applicable laws, regulations, and ordinances. Credo relies on such representations and warranties to enforce this Policy, pursuant to our contractual provisions and applicable law.

Credo will address any known behavior within Credo or by our business partners that is:

  • Unlawful, unethical, or immoral;
  • Violates this Policy or any other Credo policy or code of conduct; or
  • Otherwise determined by Credo to amount to serious improper conduct.

Credo acknowledges and accepts its responsibility to comply with laws and regulations that govern human rights principles. Our most recent Form 10-K, which is accessible through Credo’s website, provides more information on Credo’s business and operations, including descriptions of how Credo plans to strengthen our existing compliance measures and to prepare for increased compliance obligations as we continue to grow as an international corporation.

Further, each employee of Credo Semiconductor Inc. must read and acknowledge an employee handbook (the “Handbook”) which details the policies and rules that Credo Semiconductor Inc. enforces as well as the benefits that such employees are entitled to. Employees of Credo Semiconductor Inc. must sign this Handbook to certify that they will comply with the policies and rules and understand the benefits detailed therein. All policies, rules, and benefits in this Handbook comply with applicable laws and regulations.

Training. Credo ensures that each employee is aware of the contents of this Policy and acknowledges Credo’s commitment to respecting the Human Rights named herein. Credo mandates that all employees complete annual training covering the following topics: Workplace Harassment, Cyber Security, Data Security, Ethics and Code of Conduct, and Employee and Supervisor Harassment Prevention.

Policy Enforcement. At our discretion, Credo may take remedial action to address any known violation of this Policy, including but not limited to, by terminating employment or by terminating any business relationship or contractual engagements with customers, business partners, suppliers, and/or vendors, pursuant to law and the applicable contractual provisions.

Reporting Procedure.  Any individual may report a violation of this Policy using any of the following means:

If the reporting individual is a Credo employee, Credo will not discipline, discriminate against, or retaliate against such an employee who, in good faith, reports violations or suspected violations of this Policy.

Policy Review and Maintenance. The aforementioned list of Human Rights is illustrative of the human rights principles that Credo will uphold, but not exhaustive. Credo will remain informed as to any changes to global fundamental human rights principles that may arise after this Policy is effected. Credo will revise this Policy as and when necessary upon knowledge of any such change, but in any case, Credo will review this Policy annually.

1 Including, but not limited to, those human rights defined by the Responsible Business Alliance.
2 As articulated in International Labour Organization Conventions
3 As detailed in Credo’s Discrimination, Harassment and Retaliation Prevention Policy
4 As required by local law in the location in which Credo is conducting business.
5 I.e., abiding by applicable rules or regulations relating to any entity or individual named on the Lists of Parties of Concern as published by the United States Department of Commerce’s Bureau of Industry and Security.
6 As detailed in Credo’s Anti-Corruption Policy.
7 As set forth in the relevant security laws and regulatory requirements that apply when personal information is collected, stored, processed, transmitted, and shared.
8 See Credo’s Terms and Conditions of Sale, Section 16.