Statement of Supply Chain Due Diligence

Related to

Human Rights, Child Labor and Working Conditions

1. Introduction

Some countries have enacted laws that require enterprises in the scope to report on identified actual adverse impacts on fundamental human rights and decent working conditions that the enterprises are involved with or on significant risks of such adverse impacts, as well as any measures taken to cease, prevent or mitigate such adverse impacts.

This report (this “Report”) has been drafted by Logitech International S.A. (“Logitech International”) in its capacity as a worldwide manufacturer and European importer of Logitech products as well as the holding company of the worldwide Logitech group to reflect its position and alignment with various regulations and covers its due diligence and reporting obligations with respect to human rights and working conditions, in particular child labor pursuant to Art. 964j-k of the Swiss Code of Obligations and the new Swiss Federal Ordinance on Due Diligence and Transparency in Relation to Minerals and Metals from Conflict-Affected Areas and Child Labour. All entities included in Logitech’s audited consolidated financial statements for FY24 or equivalent documents are covered by this Report and the approaches taken herein with no exceptions. The information contained in this Report reflects the period between Logitech International's financial year 2024, which started on April 1, 2023 and ended on March 31, 2024.

Logitech has assessed its risk exposure in relation to minerals and metals from conflict-affected areas based on the new Swiss statutory requirements referenced above  and has determined that given that Logitech does not directly import into or process conflict minerals within Switzerland, Logitech is therefore not subject to the statutory due diligence reporting obligations. Any information contained in this Report relating to conflict minerals is made on a voluntary basis, without specific reference to the Swiss statutory framework and the requirements thereunder, in order to contribute to the promotion of transparency.

2. Logitech’s operations and supply chains

Founded in 1981 and headquartered in Lausanne, Switzerland, Logitech International is a Swiss corporation listed on the SIX Swiss Exchange (LOGN) and the Nasdaq Global Select Market (LOGI).

Logitech International and its affiliates (collectively, “Logitech”) designs, manufactures and markets products that help our customers connect to the digital world, including mice, keyboards, headsets, webcams, speakers and video conferencing systems. Our manufacturing activities consist primarily of assembly and testing. 40% of these activities are performed in facilities owned and managed by Logitech in Suzhou, China. The remaining manufacturing activities are outsourced to contract manufacturers and joint design manufacturers located primarily in Asia. Logitech's major suppliers, which account for 80% of our annual direct spend, are located mainly in China, Malaysia, Taiwan, Switzerland, Vietnam, Mexico and Thailand. Those direct suppliers are supplied by a broader network of other suppliers further upstream.

Logitech's Worldwide Operations group manages both in-house and outsourced manufacturing. The group also supports the business units and marketing and sales organizations by managing distribution centers and supply chain and logistics networks.

1. Embedding responsible business practices

Logitech has committed to promoting responsible business practices and adheres to the Responsible Business Alliance (“RBA”) Code of Conduct and the United Nations Global Compact (UNGC). The RBA is the world’s largest industry coalition consisting of members from electronics, retail, auto and toy companies committed to supporting the rights and well-being of workers and communities worldwide affected by global supply chains. Logitech has been an RBA member since 2007. Our RBA Commitment Statement and UNGC Commitment Letter can be viewed on the Reporting page of our website.

As an RBA member, Logitech is committed to implementing the RBA Code of Conduct in full. The Code both applies in our own production facilities and in our entire supply chain. The Code is fully reflected in our internal policy framework, including our Logitech Code of Conduct and in our framework for supplier management and environment, health and safety, labor, human rights, and ethical good practice. The RBA Code of Conduct is a set of social, environmental, and ethical industry standards that specifically address risks in the electronics sector. The standards set out in the Code of Conduct reference international norms and standards including the Universal Declaration of Human Rights, ILO Conventions Nos. 138 and 182, ILO-IOE Child Labor Guidance Tool for Business, OECD Diligence Guidance for Responsible Business, ILO International Labor Standards, the OECD Guidelines for Multinational Enterprises, and many more.

As part of the implementation of the RBA Code of Conduct, Logitech is also committed to implementing a management system that shall ensure (a) compliance with applicable laws, regulations and customer requirements, (b) compliance with the RBA Code of Conduct and (c) identification and mitigation of operational risks related to the RBA Code of Conduct, as well as facilitate continual improvement.  The RBA management system inter alia requires Logitech to:

• Embed responsible business practices on the executive level and designate a senior executive who is responsible for the implementation of the management system.
• Ensuring a process for carrying out risk assessments and risk management to identify relevant risks and mitigating measures regarding legal compliance, environment, health and safety, labor practices and ethics.
• Setting out improvement objectives, carrying out periodic audits and training related to labor practices, environmental and social responsibility.
• Having processes for corrective action, grievance mechanisms and worker feedback safeguarding from retaliation.

For a more detailed overview of the management requirements, please see the RBA Code of Conduct (link above).

The RBA Code is further embedded in our due diligence process for new supplier qualification and onboarding as well as our processes for mergers and acquisitions. Compliance with the RBA Code and our sustainability requirements is incorporated into all significant supplier agreements. By default, we contractually require our suppliers to apply the RBA Code to their own supply chain, thus driving the adoption of the RBA Code across our full value chain.

We work in partnership with our suppliers to ensure Logitech products are produced in accordance with all relevant legal requirements and adhere to good practice sustainability standards and quality standards. As RBA members, we require our direct suppliers^[1] to adopt the RBA Code and implement similar supply chain management programs for their own supply chains.

In support of the RBA Code, we have also developed policies and standards around specific topics of importance for supply chain management, including:

• Statement on Slavery and Human Trafficking
• Responsible Sourcing of Minerals Policy
• Responsible Manufacturing: Recruitment Policy
• Health and Safety Policy
• Anti-Corruption Policy

These policies can be viewed on the Reporting page of our website.

2. Logitech’s process for human rights due diligence

Logitech’s prioritized risks are a result of a materiality assessment assessing the topics that represent the organization’s most significant impacts on the economy, environment and people, including impacts on their human rights. The materiality assessment is an ongoing process that occurs throughout the year in collaboration with relevant stakeholder groups and experts. Logitech has identified the following material risks to human rights, child labor and labor rights.

• Child labor and forced or compulsory labor
• Working hours, adequate wages and benefits
• Humane treatment, equity and freedom from discrimination
• Social dialogue, freedom of association and collective bargaining

To support the promotion of the rights listed above, Logitech’s materiality assessment also focuses on improving certain processes such as (i) audit protocols and assessments of supplier social and safety performance, (ii) whistleblowing and remediation provisions, (iii) supplier training, education and capacity building, (iv) supplier innovation, (v) hazard identification, risk assessment and incident investigations, (vi) safety incident rates and audits, and (vii) supplier social assessment and social performance of new suppliers including social impacts of the supply chain.

Logitech’s approach to working with the identified risks in our own operations and supply chains is to help develop the companies that we choose to work with. We prioritize open and transparent collaboration and capability-building to drive continuous improvement. Our role is as a leader in the development process, rather than an outsider coming in to impose checkbox compliance.  We do of course require suppliers to meet our standards for quality, environment, human rights, labor, safety, and ethical practices, but we also work with our suppliers to empower them to take ownership of improvement opportunities and develop their own solutions. We expect our suppliers to drive the same culture of continuous improvement in their supply chains.

We use several different strategies to foster collaboration for improvement in our supply chains, including:

• Clear performance standards: We establish clear performance standards and expectations for suppliers to ensure they meet our requirements. These standards are communicated clearly to suppliers and regularly reviewed to ensure they are being met. Our RBA membership and use of RBA’s Code of Conduct and auditing tools helps us ensure our approach is consistent with other peer companies in our industry and this magnifies the opportunity for suppliers to understand the importance and relevance of best practices, for Logitech, and beyond Logitech.
• Comprehensive supplier auditing: The RBA has established protocols, tools, and expertise for auditors working across our industry to assess key risks relevant to our industry. This process is known as the Validated Audit Process (VAP) and allows for like-for-like comparison across companies and supply chains and a common understanding of RBA Code requirements and audit procedures. The audit includes a full process for supplier engagement, shared learnings, corrective actions, tracking, and reporting. RBA members commit to building in-house audit capability to follow the VAP or commission third-party, independent VAP audits by RBA’s preferred vendor to enhance in-house audit capability. Our in-house auditing team comprises highly experienced auditors who replicate the RBA’s VAP using RBA-endorsed audit protocol and tools. We carry out on-site inspections of supplier factories. Our audit teams meet with supplier management, examine the facility, review documents, and conduct private, confidential interviews. On occasion, we use independent, third-party auditors, to supplement our in-house capability. We carry out regular supplier audits, to ensure our suppliers understand our performance standards and expectations around social, environmental, and ethical good practice. Audits are carried out by experienced professionals who understand local and cultural sensitivities, as well as the risk profile and business environment that our suppliers are working in.
• Training and education: We provide supplier training to help our suppliers meet our requirements and develop further. We leverage RBA training programs and materials to push suppliers towards bite-size training that is appropriate for our industry. In addition, we develop our own capability-building programs to address specific needs and supplement this industry-wide training.
• Fostering culture: We build long-term relationships with our suppliers and share our culture of open and transparent communication and collaboration to foster a culture of continuous improvement. We partner with suppliers to encourage them to be open about performance challenges and we share our experience and learnings with others. We believe this approach is critical to deliver positive and transformational change over time.
• Supplier innovation: Our innovation engine is often fueled by inputs and innovation with our suppliers. With our Continuous Improvement Process (CIP) Awards and Future Positive Challenge, we are creating innovation opportunities within and outside Logitech to incentivize and encourage innovation, and encourage individuals to rethink traditional ways of working.

1. Identified human rights risks and risks of indecent working conditions

Freely Chosen Employment

The manufacturing industry in Asia and the Pacific region are sectors exposed to higher risks of forced labor. This is reflected in the RBA Code of Conduct and is a prioritized risk for us when working with our supply chains.  

Our requirements in relation to Freely Chosen Employment include zero tolerance for any type of forced, involuntary, or exploitative prison, indentured, bonded (including debt bondage), trafficked, or slave labor. In August 2022, we established a public-facing Responsible Recruitment Policy (available to review here), which summarizes our requirements in clear terms and reflects RBA Code requirements. As communicated in that policy, we have zero tolerance for any type of forced, involuntary, or exploitative recruitment and employment, including use of prison labor, indentured labor, bonded (including debt-bonded) labor, human trafficking, or slave labor. We prohibit withholding of employee documents (e.g. IDs, passports, work permits, etc.) under any circumstances and we recognize the right of all workers to have a written employment agreement in their native language. Workers may resign whenever they wish and Logitech cannot terminate an employment agreement without giving reasonable notice, with notice periods being defined in the contract. We do not charge workers’ recruitment fees or retain wages under any circumstances and our payroll team verifies that social insurance is always paid.

At our production facility, we work with a limited number of Dispatch Agencies^[2] to supplement our own in-house capability to hire and manage the manufacturing workforce. Dispatch Agencies are subject to our normal supplier prequalification process and are audited a minimum of once annually. In addition, we require Dispatch Agencies to sign a special commitment letter to uphold the RBA Code of Conduct. This is additional to our normal contractual provisions for supply chain sustainability management.

In our supply chain, we expect and require the same standards of commitment, management, and performance as we practice in Logitech. We routinely enroll suppliers in relevant RBA training on this topic with our audit team regularly audit and check supplier performance with respect to this aspect of the RBA Code and maintain a similar level of vigilance when tackling this issue.

See more about our measures to eliminate the risk of slavery and human trafficking in our Zero Tolerance Statement on Slavery and Human Trafficking (available to review here).

Young workers

According to UNICEF's Children's Rights and Business Atlas, most of the jurisdictions in which Logitech has major suppliers are classified as having an enhanced risk of child labor, which requires us to be ambitious in our risk management work.

We are committed to respecting human rights throughout our value chain as reflected in our RBA Commitment Statement and UNGC Commitment Letter. Our commitment covers all internationally recognized human rights and we have a zero-tolerance policy for child labor ^[3] and prohibit child labor in any aspect of our business or supply chain. The RBA Code of Conduct specifically commits us to respect international labor rights, including:

• ILO C138 Minimum Age Convention, 1973;
• ILO C182 Worst Forms of Child Labor Convention, 1999;
• ILO-IOE Child Labour Guidance Tool for Business, ILO (2015) ;
• The OECD Due Diligence Guidance for Responsible Business Conduct (2018); and
• The UN Guiding Principles on Business and Human Rights (2011)

In addition, and in accordance with the RBA Code, we ensure that all workers under the age of 18 are protected from any job that may harm their health or safety, such as night shifts or excessive overtime.

Our Logitech Code of Conduct and Responsible Recruitment Policy reflect RBA requirements, and apprentices, interns, or student workers are only employed when that policy and RBA requirements are met.

Compliance with the RBA Code        of Conduct is also a contractual requirement of our purchase agreements with direct suppliers and those suppliers are        required to manage their supply        chain        in accordance with the RBA Code. We periodically review our supplier agreements in order to ensure compliance with our own supply chain policy. As a part of our internal and supplier audit programs, we periodically check worker identification and conduct interviews with a sample of employees to verify their age. Our approach ensures that we prioritize the safety, health, and well-being of young workers as well as eliminating the risk of child labor. We encourage suppliers to attend RBA e-learning and training on relevant topics (e.g. Young Workers, Responsible Recruitment) and routinely enroll suppliers in relevant training courses.

Working hours

Our company supports the RBA Code of Conduct’s commitment to eliminate excessive working hours. We acknowledge that this remains a major challenge for Logitech and our industry as a whole. Excessive working hours often arise in our industry due to inadequate demand planning and forecasting, capacity planning constraints, shortened production timelines, and unplanned seasonal spikes in production demand. In addition, traditional compensation models frequently incentivize overtime by offering extra pay, which can sometimes encourage workers to request more working hours than what is permitted by local law or the RBA Code of Conduct. We understand the importance of addressing these issues for the benefit of workers' overall welfare and well-being.

Management of working hours is also a challenge and priority in our supply chain. In 2022, we encouraged all our suppliers to participate in RBA training on working hours and we continue our efforts to raise awareness and build capability in our supply chain to ensure effective management and control of this important issue.

Wages and benefits

Our approach to the management of wages and benefits is fully aligned with the RBA Code of Conduct requirements. The RBA Code requires employers to ensure (1) worker compensation complies with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits, (2) workers are compensated for overtime, at pay rates greater than the regular hourly rate and the deduction of wages as a disciplinary measure is not permitted, and (3) workers are provided with wage statements—and we carry out worker interviews to ensure workers know how to check and verify that they have received accurate compensation for any work performed.

Humane Treatment, Equality, and Freedom from Discrimination

Logitech is committed to creating a safe and inclusive workplace, guided by the principles outlined in the RBA Code of Conduct. The Code emphasizes the importance of safeguarding workers from various forms of abuse and discrimination, including sexual harassment, corporal punishment, coercion, and verbal abuse. We have implemented comprehensive policies and disciplinary procedures to address these risks, ensuring that our employees are aware of their rights and the consequences of violating these policies.

Our commitment to diversity, equity, and inclusion extends beyond our internal operations to our supply chain. We recognize the value of promoting a culture that embraces different backgrounds, experiences, and perspectives. In our recruitment and employment practices, we prioritize fairness and non-discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status.

To ensure compliance with the Code, we conduct thorough audits and assessments of our facilities and suppliers. Our auditors closely examine the practices of security and medical personnel, review relevant procedures and company records, and conduct confidential interviews with employees. We also scrutinize wages, rewards, and training records to identify any signs of discriminatory practices. These efforts allow us to maintain transparency and accountability throughout our supply chain.

The emergence of concerns regarding the treatment of minorities in China and the associated allegations of forced labor and child labor have prompted us to strengthen our supply chain due diligence. We have collaborated with industry experts, including RBA insights and advisors, to raise awareness, review commodities and factories of concern, and survey our suppliers to ensure factories involved in such practices are not utilized. Additionally, we have implemented internal processes, such as our Change Control Management Procedure, to effectively manage factory locations and changes.

While we are pleased to report that our ongoing due diligence process has not identified any areas of concern, we remain vigilant and committed to continuous improvement. Third-party VAP audits and internal audits conducted over the past 3 years have not revealed any issues related to forced labor, child labor or mistreatment of workers.

By upholding the RBA Code of Conduct and prioritizing ethical practices, we strive to foster an environment that respects the rights and dignity of all workers, both within our organization and throughout our global supply chain.

Freedom of association

In compliance with local laws, we respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly. We also respect the right of workers to refrain from such activities. Workers and/or their representatives can openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

We maintain an open-door policy and provide workers with an opportunity to openly communicate and share their ideas and concerns with management on working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

Responsible sourcing of minerals

Sourcing of minerals, including mining and smelting are processes that carries with it potential social and environmental risks that, if not properly managed, can have lasting negative impacts. Mining and smelting of minerals such as tin, tungsten, tantalum and gold (“3TG”), cobalt and mica that are frequently used in electronics is associated with risks of hazardous/undesirable work, vulnerable, easily replaced and low skilled workforce, migrant workers, presence of labor contractors, recruiters and agents, long, complex and/or non-transparent supply chains. In addition, irresponsible sourcing of minerals can contribute to armed conflict and human rights abuses.

Logitech is actively working to prevent and mitigate these risks through our participation in the RBA Responsible Minerals Initiative (“RMI”). Through our membership in RMI, we have gained access to tools and resources for our Responsible Sourcing of Minerals Due Diligence program, including the Conflict Minerals Reporting Template, Reasonable Country of Origin Inquiry data, and a range of guidance documents supporting responsible minerals sourcing.

We look beyond 3TG and the countries covered by the US Dodd-Frank Act (Democratic Republic of Congo and surrounding countries) to consider all relevant legal requirements and industry best practices for responsible metal sourcing, including the OECD Due Diligence Guide.

We are continuously working to improve and track progress in our minerals supply chain. For more information see the Responsible Sourcing of Minerals section of our most recent annual Impact Report and Conflict Minerals Report as required under the Dodd-Frank Act. Both reports are available to review on the Reporting page of our website.

3. Measures to cease, prevent and mitigate identified risks

Logitech works continuously to prevent and mitigate identified risks related to human rights, child labor and labor rights in our own operations and supply chains. We audit and assess supplier compliance with the RBA Code of Conduct as part of our supplier prequalification process and follow up by requiring direct suppliers to provide reasonable assurance that they comply with international good practice as set out in the RBA Code of Conduct. As part of our supplier prequalification process, we review public available information, in particular from public authorities and international organizations. We also encourage and train our direct suppliers to monitor, audit and manage their own supply chain.

We adhere to RBA requirements and carry out due diligence processes to evaluate social performance and risks, including human rights compliance and risks. We employ the RBA’s Self-Assessment Questionnaire (SAQ) and Risk Assessment Tool to assess, prioritize, and communicate our performance. Our production facility is subject to periodic third-party audits to verify compliance with the RBA Code of Conduct, including the criteria relevant to human rights, child labor and labor management. These audits are carried out by RBA-approved auditors following the RBA-validated audit process (VAP), which comprises site observation, document reviews, and interviews with management and employees. Audit findings are reviewed and validated by an independent consulting firm to ensure accuracy and impartiality and are categorized as "minor," "major," or "priority". For all three categories of findings, Logitech, as the auditee, is given a specific duration to devise and implement Corrective Action Plans (CAPs) to address the identified issues and rectify them. Any potential, perceived, or actual violation of human rights and related RBA Code aspects are taken very seriously, and prioritization is given to investigation and speedy determination of the root cause, along with capability-building to avoid longer term recurrence of the issue.

In our annual Impact Report we illustrate the types of human rights and labor rights issues that arise in our supply chain and share information on how we manage such risks and incidents.

4. Supply Chain Traceability System

We systematically record the names and addresses of all our direct suppliers and the commodity category and trade names of the goods or services they provide. As part of our risk management process, we keep records of our monitoring activities, assessments, and completed questionnaires.

We will continue to monitor and improve the tracking systems we use to further enhance our ability to address human rights risks.

5. Stakeholder engagement

To communicate our sustainability risks, objectives and progress Logitech reports in accordance with several good practice standards including the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), Sustainability Accounting Standards for the Technology and Communications Sector, Hardware and Electronic Manufacturing and UN Global Compact Communication on Progress Guidelines. Our sustainability reporting is made available annually in our Impact report available on Logitech’s website.

Logitech also engages more directly with stakeholders, including customers, employees, shareholders, industry peers and competitors, regulators and policymakers. For the purpose of communicating with affected stakeholders and rights-holders regarding how adverse impacts to human rights and labor rights are addressed, we focus on communication with special interest groups through the RBA that guides the engagement of stakeholder groups via mechanisms that are governed by Chatham House Rules. Logitech participates in these sessions or leverages the learning that arise for these engagements.

Further, Logitech engages in different benchmarking surveys for the electronics industry that provide feedback and help to develop and understand best practices industry wide. Our engagement with these benchmarks provided fresh insight on current expectations around supply chain transparency and the need for companies to share their experience of human rights and labor challenges in their supply chain, and the actions that companies are taking to remedy any issues that are identified in auditing programs.

6. Whistleblowing and remediation

Every employee and other interested parties have the right and responsibility to report any observations, concerns, grievances, or issues relevant to our Code of Conduct. The Logitech Code of Conduct includes a specific and overt commitment to comply with local human rights laws for all countries in which we, or our suppliers, do business and references the fact that, as a global policy, we prohibit the use of forced labor, child labor, and unsafe working conditions in our own operations and in any of our suppliers’ operations. We regularly review our risk management measures on effectiveness.

We have an established Ethics Hotline, which is hosted by EthicsPoint, which can be used by employees as a whistleblowing mechanism to confidentially and anonymously report any issues they identify or observe. Reports to the hotline are investigated and managed in accordance with defined procedures, which are overseen by our Legal, People and Culture and Internal Audit functions and ultimately by our Board-level Audit Committee. We have a no retaliation policy – the identity of individuals who may choose to report issues are protected.

Our Internal Audit team is responsible for investigating allegations that are raised as a result of internal audits and certain submissions via the Ethics Hotline. Audit findings are reviewed and documented and remediation actions are reported to the Audit Committee on a quarterly basis.