MaxLinear Conflict Mineral Policy
As a fabless semiconductor company supplying Integrated Circuits (ICs) to customers worldwide, MaxLinear uses only world-class manufacturers to produce its products. MaxLinear’s supply chain spans the globe, with suppliers in many countries.
MaxLinear’s suppliers also have their own suppliers for the materials used in MaxLinear’s products. In particular, some or all of these minerals may be used in the manufacture of MaxLinear’s products:
- Tantalum (columbite-tantalite ore and its derivatives)
- Tin (cassiterite ore and its derivatives)
- Tungsten (wolframite ore and its derivatives)
The United States government has identified these four minerals as being potentially “conflict minerals,” which originate in the Democratic Republic of the Congo (DRC) or certain adjoining countries. In August 2012, the Securities and Exchange Commission (SEC) adopted requirements that require publicly-traded companies to report annually concerning the presence of “conflict minerals” that are necessary to the functionality or production of products they manufacture or contract to manufacture.
MaxLinear has taken the following actions to ensure that no conflict minerals are used in its products:
- MaxLinear has notified its manufacturing suppliers that, to the best of their ability or knowledge, they are not to source any conflict minerals and use them in MaxLinear’s products.
- MaxLinear requires each of its manufacturing suppliers to complete the Electronics Industries Citizenship Coalition (EICC) Conflict Minerals Survey and to comply with the EICC Code of Conduct, which requires that suppliers have a policy to reasonably assure that the tantalum, tin, tungsten, and gold in the products they manufacture are conflict-free. Suppliers must ensure that all parts used to manufacture products supplied to MaxLinear originate from certified conflict-free smelters validated as compliant to the EICC Conflict-Free Smelter (CFS) protocol, using the CFS Compliant Smelter List. The CFS program is a global program where an independent third-party evaluates a smelter’s procurement activities and determines if the smelter demonstrated that materials they processed originated from conflict-free sources. Through this industry-collaborative effort, smelters are audited globally. The list of compliant smelters and refiners is posted at www.conflictfreesmelter.org.
The use of conflict minerals in the electronics industry is extremely complicated due to the multi-layered international supply chain. MaxLinear expects its suppliers to use materials that are environmentally safe and sourced from socially responsible suppliers.
Modern slavery statement for financial year 2015/16
This statement is made pursuant to s.54 of the United Kingdom (“UK”) Modern Slavery Act 2015 and sets out the steps that MaxLinear Inc. has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. MaxLinear Inc. has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
About Maxlinear Group Business
MaxLinear, Inc. is a provider of radio frequency, or RF, and mixed-signal integrated circuits for cable and satellite broadband communications and the connected home, and wired and wireless infrastructure markets. Our high performance RF receiver products capture and process digital and analog broadband signals to be decoded for various applications. These products include both RF receivers and RF receiver systems-on-chip (SoCs), which incorporate our highly integrated radio system architecture and the functionality necessary to receive and demodulate broadband signals, and physical medium devices that provide a constant current source, current-to-voltage regulation, and data alignment and retiming functionality in optical interconnect applications. Through our acquisition of Entropic Communications, Inc., or Entropic, in April of 2015, we provide semiconductor solutions for the connected home, ranging from MoCA® (Multimedia over Coax Alliance) solutions that transform how traditional HDTV broadcast and Internet Protocol- (IP) based streaming video content is seamlessly, reliably, and securely delivered, processed, and distributed into and throughout the home. Through our acquisition of the Microsemi wireless infrastructure access business in April of 2016, we provide integrated circuits for wireless infrastructure markets, including wideband RF transceivers and synthesizers for 3G, 4G, and future 5G cellular base station and remote radio head (RRH) unit platforms. Through our recently closed acquisition of the Broadcom wireless infrastructure backhaul business in July of 2016, we also provide modem and RF transceiver solutions into cellular infrastructure backhaul applications.
A large percentage of our products are shipped to Asia, and we believe that a significant number of the systems designed by these customers and incorporating our semiconductor products are then sold outside Asia. For example, we believe revenue generated from sales of our digital terrestrial set-top box relate principally to sales to Asian set-top box manufacturers delivering products into Europe, Middle East, and Africa, or EMEA markets. There is a growing portion of our business, related specifically to our high-speed optical interconnect products, that are shipped to, and are ultimately consumed in Asian markets, with the majority of these products being purchased by end customers in China.
The HQ is based in the United States and we operate internationally in the following countries:
- United Kingdom
We currently use several major third-party vendors to supply the goods we sell, including UMC, Silterra Malaysia Sdn Bhd, Global Foundries, SMIC, TSMC, Jazz Semiconductor, and WIN Semiconductor. We do not have long-term supply contracts with any of our third-party vendors. We make substantially all of our purchases on a purchase order basis, and none of our contract manufactures are required to supply us products for any specific period or in any specific quantity.
The UK Business
The principal activities of the company during the year were the selling, marketing and development of semi-conductors.
Due to the restructuring plans of the company, the United Kingdom operations underwent a major reduction of the workforce with the closure of the Belfast Office in 2015. The UK business is no longer continuing to pursue wins for all set-top box system-on-a-chip (SoC) products already commercialised and will not continue to invest to support those programs, and has discontinued all new set-top box SoC product development. The company believes the set-top box SoC business will not contribute meaningful revenue beyond the next several quarters, based on products it has already brought to market. It is expected that the UK Company will continue to support the US parent with sales and marketing activities across the range of Maxlinear products, spanning broadband and wired and wireless infrastructure markets.
Maxlinear United Kingdom Limited was acquired by Maxlinear Inc. on 1st May 2015.
In 2016, the UK business has not engaged any third party suppliers and the work done by our members of staff is directly related to our US business.
Our high risk areas
We have not identified any areas of the business to be considered to be high risk. Employees are paid on commercial terms and we comply with all the relevant UK employment and other laws as required.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Maxlinear Inc operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business
- They hold their own suppliers to account over modern slavery
- (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
- (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
- We may terminate the contract at any time should any instances of modern slavery come to light
We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
Approval for this statement
This statement was approved by the Board of Directors on December 20, 2016.
Name: Kishore Seendripu
Signature: s/s Kishore Seendripu
Date: December 20, 2016