California Human Trafficking in the Supply Chain Disclosure

(pursuant to the California Transparency in Supply Chains Act of 2010)

iRobot Corporation is pleased to share our guiding principles and the work we do to ensure the integrity and dignity of those who make the robots that empower our customers to do more with their lives. We comply with applicable laws and regulations in the countries where we manufacture products and we expect our business partners to comply with applicable laws in the countries in which they operate. We would never knowingly do business with any partner who engages in human rights violations whether it involves the use of child labor, forced labor, discrimination, harassment, occupational health and safety, human slavery or human trafficking issues.

iRobot works with our contract manufacturers, suppliers and vendors (collectively “Suppliers”) to maintain fundamental labor and human rights standards. Specifically, we include policies in our key supplier agreements specifying that each Supplier: “represents and warrants that it and its subcontractors/suppliers will comply with all applicable local government regulations regarding minimum wage, living conditions, overtime, working conditions, child labor laws and the applicable labor and environmental laws.” In addition, each key Supplier “represents and warrants that it and its subcontractors/suppliers do not use any form of forced prison labor and/or child labor under the age of 15 or the minimum age required by local government, whichever is older.” Suppliers failing to meet these standards would be in breach of our supplier agreements. At this time, we do not require our Suppliers to certify that all materials incorporated into our products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Our internal audit team, in conjunction with our manufacturing oversight function, invests significant time and resources to audit our contract manufacturers and the factories that build our robots. Our internal audit team performs an independent audit and verification of key non-U.S. manufacturing facilities for compliance with our supplier agreements. Audits are announced and scheduled, which helps us build trust with our key manufacturing partners. Our manufacturing oversight team, located in Guangzhou, China, makes unannounced visits to our key manufacturing partners and suppliers. Third party audit reports and certifications from industry specialists (e.g. Electronics Industry Citizen Coalition (EICC) and International Council of Toy Industry’s (ICTI) Care Foundation) assessing minimum wage, living conditions, overtime, working conditions, child labor laws and the applicable labor and environmental laws are also periodically obtained for key manufacturing partners.

Finally, we maintain standards and procedures for employees and Suppliers in the iRobot Code of Conduct & Business Ethics which includes the identification of accountability. All employees receive training on the iRobot Code of Conduct & Business Ethics. Failure by an employee to follow the standards set forth in the iRobot Code of Conduct & Business Ethics may subject such employee to disciplinary action up to and including termination of employment.

In addition, iRobot maintains a separate Human Trafficking Policy, which includes additional requirements for the performance of work on behalf of the U.S Government . The Human Trafficking Policy is communicated to all employees and is flowed down to any subcontractors working on U.S. Government contracts.


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