EMPTY STATE
COMPARISON TOOL

Broadcom 6/100

(NasdaqGS:AVGO) 37 of 40 (2018)

Broadcom Inc. (Broadcom) is a semiconductor supplier to companies such as Apple, HP and Hewlett Packard Enterprise. It ranks 37th out of 40 companies. The company discloses less information on its forced labor policies and practices than its peers and is the lowest scoring US company. Since 2016, its score has decreased substantially, from 33 to 6. This is due in large part to the decrease in information made available by the company on its efforts to address forced labor and human trafficking. For example, the company no longer discloses a modern slavery statement, a Human Rights Policy nor a Sustainability Report. It is also no longer a member of the Responsible Business Alliance. The company may consider reinstating its commitment to address forced labor, and improving its performance and disclosure on the themes of purchasing practices and recruitment.

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6 /100

2018 Ranking: 37 of 40

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33

Broadcom was evaluated both in 2016, when it ranked 13th out of 20 companies, and in 2018, when it ranked 37th out of 40 companies. Since 2016, its score decreased substantially, from 33/100 to 6/100. In addition to a strengthened methodology which makes it harder to achieve the same score, this decrease is due in large part to the decrease in information made available by the company on its efforts to address forced labor and human trafficking. For example, the company no longer discloses a modern slavery statement, a Human Rights Policy nor a Sustainability Report. It is also no longer a member of the Responsible Business Alliance.

2016 BENCHMARK

6

The average score for the sector was 32/100, compared to 39/100 in 2016. The drop in score is due in part to the increase in number of small and mid cap companies from 20 to 40, as well as the changes made to the methodology that strengthened it. The 20 companies benchmarked in both 2016 and 2018 saw their average score improve from 39/100 to 40/100, which is notable given the changes to the methodology.

METHODOLOGY

2016

33

Broadcom was evaluated both in 2016, when it ranked 13th out of 20 companies, and in 2018, when it ranked 37th out of 40 companies. Since 2016, its score decreased substantially, from 33/100 to 6/100. In addition to a strengthened methodology which makes it harder to achieve the same score, this decrease is due in large part to the decrease in information made available by the company on its efforts to address forced labor and human trafficking. For example, the company no longer discloses a modern slavery statement, a Human Rights Policy nor a Sustainability Report. It is also no longer a member of the Responsible Business Alliance.

2016BENCHMARK

2018

6

The average score for the sector was 32/100, compared to 39/100 in 2016. The drop in score is due in part to the increase in number of small and mid cap companies from 20 to 40, as well as the changes made to the methodology that strengthened it. The 20 companies benchmarked in both 2016 and 2018 saw their average score improve from 39/100 to 40/100, which is notable given the changes to the methodology.

METHODOLOGY

THEME AND INDICATOR SCORE

The benchmark methodology has seven themes, selected to capture the key areas where companies need to take action to eradicate forced labor from their supply chains. There are a total of 23 indicators across the seven themes. For each theme, a company can score a total of 100 points.

Commitment and Governance

This theme evaluates a company's commitment to addressing forced labor, supply chain standards, management processes and board oversight, training programs, and engagement with stakeholders.

OVERALL 8
INDICATORS
Commitment
0
Supply Chain Standards
40
Management and Accountability
0
Training
0
Stakeholder Engagement
0

Traceability and Risk Assessment

This theme measures the extent to which a company demonstrates an understanding of its suppliers and their workforce by disclosing relevant information, and assesses and discloses forced labor risks across its supply chains.

OVERALL 19
Traceability
37.5
Risk Assessment
0

Purchasing Practices

This theme assesses to what extent a company adopts responsible purchasing practices and integrates supply chain standards into supplier selection and supplier contracts. It also assesses the degree to which a company cascades their standards down its supply chains.

OVERALL 13
Purchasing Practices
0
Supplier Selection
0
Integration into Supplier Contracts
0
Cascading Standards through the Supply Chain
50

Recruitment

This theme measures a company's approach to reducing the risk of exploitation of supply chain workers by recruitment agencies, eliminating workers' payment of fees during recruitment processes throughout its supply chains, and protecting the rights of migrant workers.

OVERALL 0
Recruitment Approach
0
Recruitment Fees
0
Monitoring and Ethical Recruitment
0
Migrant Worker Rights
0

Worker Voice

This theme measures the extent to which a company engages with workers in its supply chains, enables freedom of association, and ensures access to effective and trusted grievance mechanisms.

OVERALL 0
INDICATORS
Communication of Policies
0
Worker Voice
0
Freedom of Association
0
Grievance Mechanism
0

Monitoring

This theme evaluates a company's process for auditing suppliers (including whether it performs non-scheduled visits, reviews relevant documents such as wage slips or contracts, interviews workers, and audits lower-tier suppliers) and providing disclosure on the outcomes of supplier audits.

OVERALL 0
Auditing Process
0
Audit Disclosure
0

Remedy

This theme measures the extent to which a company has corrective action plan processes for non-compliant suppliers and ensures remedy is provided to workers in its supply chains who are victims of forced labor. Publicly available allegations of forced labor in a company's supply chains which occurred in the past three years, and how a company has responded to and addressed those allegations, are also assessed as part of this theme.

OVERALL 0
Corrective Action Plans
0
Remedy Programs and Response to Allegations
0

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