Supply Chain Transparency

Statement on Eradication of Slavery and Human Trafficking

Introduction

Keysight Technologies, Inc., along with Keysight Technologies UK Limited and Keysight Technologies Canada Inc. (collectively, “Keysight”), is proud of its record of uncompromising integrity, its commitment to promoting human rights globally, and the measures it takes to uphold the highest standards of conduct among its employees, business partners and suppliers. This includes a commitment to comply with the California Transparency in Supply Chains Act of 2010 (effective January 1, 2012, the “California Act”), the Modern Slavery Act 2015 (effective October 29, 2015, the “U.K. Act”), and the Fighting Against Forced Labour and Child Labour in Supply Chains Act (effective January 1, 2024, the “Canada Act”).¹

The California Act requires manufacturers and retailers doing business in the State of California to disclose information regarding their efforts to eradicate slavery and human trafficking from their direct supply chains. The U.K. Act requires companies that supply goods and/or services in the United Kingdom to disclose information regarding their efforts to eradicate slavery and human trafficking from their own organization and direct supply chains. The Canada Act requires certain entities doing business in Canada to report the steps taken during the previous financial year to prevent and reduce the risk that forced labor or child labor is used by them or in their supply chains. This Statement on Eradication of Slavery and Human Trafficking reflects Keysight’s efforts to combat forced, bonded, or child labor in its business and supply chain. It is intended to provide current and potential customers, shareholders, and employees the ability to make a better, more informed choice about the products and services they buy, the investments they make, and the company they support.

The sections below describe Keysight’s efforts to meet the letter and spirit of the California Act, the U.K. Act, and the Canada Act and address human rights issues generally.

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¹ For the purpose of the Canada Act, Keysight Technologies Canada Inc. (“Keysight Canada”) is the only “entity” under the Canada Act and makes this statement as a single report pursuant to section 11. For the purpose of the relevant approval and signing requirements, this statement has been approved by the governing body of Keysight Canada and has been signed by a director of Keysight Canada.

Our Business

Keysight is one of the world’s leading test and measurement companies supplying hardware, software, solutions and services to help accelerate our customers' innovations to connect and secure the world.

Keysight Technologies, Inc. is a United States publicly listed company trading under the symbol KEYS with operations in approximately 140 locations, conducting business with customers in 100+ countries through approximately 15,000 employees. Keysight has entities in many countries, with manufacturing in the U.S., Japan, Germany, Spain, Finland, China and Malaysia. In addition, we use a few selected contract manufacturers. A list of significant Keysight subsidiaries can be viewed in our latest Form 10-K filing with the U.S. Securities and Exchange Commission.

Keysight’s business is organized into the following groups:

The Communication Solutions Group serves customers spanning the global commercial communications and aerospace, defense and government end markets. The group’s solutions consist of electronic design and test software, instrumentation, systems and related services. These solutions are used in the simulation, design, validation, manufacturing, installation and optimization of communication systems in wireless, wireline, enterprise, and aerospace, defense, and government end markets. In addition, the group provides automated software test solutions that include artificial intelligence and machine learning to automatically identify, build, and execute tests critical to digital business success and a strong customer experience.

The Electronic Instrument Solutions Group serves customers across a diverse set of end markets focused on automotive and energy, semiconductor solutions, and general electronics. The group’s solutions consist of electronic design and test software, instrumentation, systems and related services. These solutions are used in the simulation, design, validation, manufacturing, installation and optimization of electronic equipment. In addition, the group provides automated software test solutions that include artificial intelligence and machine learning to automatically identify, build, and execute tests critical to digital business success and a strong customer experience.

Keysight Global Services Organization provides services solutions including product support services, technical support and training and consulting. Customer demand is fulfilled by trained engineers and technicians through regional support and service centers, located near customers or through onsite teams. Our global presence with localized service proximity is an important factor in sustaining our customers’ solutions, uptime and utilization requirements. We also provide industry-specific services to deliver complete Keysight solutions and help customers reduce their total cost of ownership for their design and test equipment. Our services solutions include the following general types of services:

• Product support services: Comprehensive support that includes repair, parts, and accredited calibrations of Keysight products and solutions.
• Technical support for software and hardware: Customer support for the usage and utilization of our products.
• Professional services: Installation, training and engineering services to optimize equipment adoption, utilization, and design of test processes.

Keysight Global Sales is our direct sales force consisting of sales and application engineers who have in-depth knowledge of the customers’ business and technology needs. Our direct sellers concentrate on providing more complex, end-to-end solutions where customers require strategic consultation. Our application engineers bring deep solution and application expertise to provide a combination of consulting, systems integration and software engineering services that span all stages of the sale, deployment and support of our complex systems and solutions. Our direct sales organizations serve customers globally across the commercial communications, aerospace, defense and government, automotive and energy, semiconductor, general electronics, network test and network visibility markets. To complement our direct sales force, we have an extensive network of channel partners around the world. These channel partners include resellers, manufacturer’s representatives and distributors. They serve thousands of customers across a wide range of end-user markets.

Keysight Enterprise Functions such as Finance, Tax, Logistics, Legal, Workplace Services, HR and Global Sourcing. Resources are spread across the world, typically supporting multiple countries, with centers of excellence providing certain centralized services.

Keysight Technologies UK Limited is registered in England and Wales and has approximately 550 employees operating from four offices. The principal activities in the U.K. are sales, service, administration, software research and development and small-scale system production.

Keysight Technologies Canada Inc. has approximately 150 employees operating from six offices. Keysight’s primary activities in Canada include sales, service, administration, and software research and development. 

Employee Engagement

Keysight and all its employees strictly adhere to the company’s Standards of Business Conduct (“SBC”), which states: “We are committed to respecting human rights throughout our global supply chain and do not knowingly conduct business with any individual or company that participates in the exploitation of children (including child labor), physical punishment, forced labor or human trafficking. We expect that anyone who conducts business on our behalf will operate ethically, in compliance with the law and in a manner that is consistent with our Standards and our policies.”

Annually, all Keysight employees complete training on our code of conduct and certify compliance with the SBC. In addition, Keysight conducts specialized training for procurement employees that emphasizes the importance of ensuring that Keysight’s suppliers abide by Keysight’s Supplier Code of Conduct (“the Supplier Code”), including its prohibitions on slavery and human trafficking.

Supply Chain Management

Keysight’s largest manufacturing facility in Malaysia. Other principal finished good manufacturing facilities are in the United States, Germany, and Japan. In addition, we use a few selected contract manufacturers. Our global supplier base consists of approximately 10,000 suppliers from more than 60 countries. In respect of the U.K. and Canada, the majority of the supply chain is driven by the sale of products manufactured by Keysight in other countries. Keysight UK and Keysight Canada also have direct suppliers who provide facilities management, payroll, logistics, legal and financial services.

Keysight maintains written policies that strictly prohibit the use of slavery or human trafficking in its direct supply chain. These include the “Supplier Code the Global Human Rights and Labor Standards Policy and the SBC.

The Supplier Code requires all Keysight suppliers to “comply with all applicable labor laws, rules, and regulations, including but not limited to, all laws forbidding the solicitation, facilitation, or any other use of slavery or human trafficking.” The Supplier Code also prohibits Keysight suppliers from employing child labor.

Keysight communicates to all suppliers its expectation that they comply with the Supplier Code, including the provisions barring forced labor, slavery, child labor, and human trafficking. Keysight further requires suppliers to certify their compliance with the Supplier Code and all its provisions.

Verification

Keysight has the right to audit all suppliers for compliance with its Supplier Code. Keysight employs an independent third party to audit and evaluate suppliers’ compliance with the Supplier Code, including monitoring each supplier’s compliance with all applicable labor laws governing forced labor, slavery and human trafficking, as set forth in both the California Act and the U.K. Act.

Accountability

Keysight has a zero-tolerance policy for violations of laws banning forced labor, slavery, child labor, and human trafficking. Keysight’s contractual terms and conditions permit the termination of a supplier for even a single violation. Similarly, Keysight’s employee disciplinary policy permits a range of measures, up to and including termination, for Keysight employees involved in any misconduct related to human rights abuses.

Keysight employees are required to speak up if they see or suspect conduct that violates the SBC, Keysight policies, or the laws and regulations that apply to our business. Keysight has an Open Door Policy that allows employees to report concerns to any level of management. Keysight also maintains a Compliance Hotline, which is operated by an independent reporting service that allows individuals to communicate concerns anonymously (where permitted by law) and confidentially, via phone or internet.

Actions Taken in Fiscal Year 2023

Keysight has identified risks to the best of its knowledge and will continue to strive to identify emerging risks. Keysight utilizes the Responsible Business Alliance (“RBA”) Self-Assessment Questionnaire (“SAQ”) to assess key suppliers’ compliance status. Additionally, Keysight engages a third-party consultant to perform an in-depth corporate social responsibility assessment of the company’s suppliers. Suppliers that score below the satisfactory score are considered high-risk facilities. Each high-risk facility is then audited according to the RBA Validated Assessment Program (“VAP”).

In Fiscal Year 2023, priority non-conformances were found related to the issues of freely chosen employment, working hours, and service provider recruitment fees at 2 suppliers. Corrective action plans have been implemented to address those findings and to remediate the situation.

Keysight is not aware of specific instances of child labor with any of its suppliers; therefore, no measures have been taken during the last fiscal year to remediate child labor or the loss of income to the most vulnerable families resulting from measures taken to eliminate the use of child labor. 

Assessing Effectiveness

Keysight utilizes a Plan>Do>Check>Act approach to evaluating the program components, accountabilities, and actions taken. If warranted, internal and/or external goals and targets are identified to evaluate progress. Those actions and goals or targets are then managed through a quarterly reporting process that tracks key impact goals throughout the year. All lessons learned and trends are fed back into the Plan>Do>Check>Act approach as appropriate.

Keysight evaluates the effectiveness of programs in this area through various mechanisms, including:

• Keysight's Corporate Social Responsibility (“CSR”) KPI Dashboard which systematically monitors and evaluates key CSR function pillars and program performance, and
• The Keysight Labor Management System (“KLMS”) and its repository supports Keysight's human rights and labor management process and functions as a comprehensive system to monitor, track and assess labor compliance and drive continuous improvement.

Conclusion

It is essential – and it is Keysight’s expectation – that all persons involved in the production of our products, whether Keysight employees or not, are treated with dignity and respect. Keysight will continue to update its policies and procedures as needed to ensure that it has appropriate safeguards against any mistreatment of persons involved in our direct supply chain.

This statement pertains to all of Keysight for fiscal year 2024. It has been specifically reviewed and approved by the Board of Directors of Keysight Technologies UK Limited, in accordance with the requirements of the U.K. Act and the Board of Director of Keysight Canada, in accordance with the requirements of the Canada Act. 

May 31, 2024

Ingrid Estrada
Senior Vice President, Chief People and Administrative Officer,
Chief of Staff Keysight Technologies, Inc.

Gareth Smith
Managing Director
Keysight Technologies UK Limited

Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.

I have the authority to bind Keysight Technologies Canada Inc.

Jodi Juskie
Director and Secretary
Keysight Technologies Canada Inc