Operating with Integrity

Lumentum is committed to the highest standards of social, ethical, and environmental conduct and responsibility. This applies to our facilities, processes, and employees, as well as to the companies with which we do business.

Our Business Highlights

To find out more about our initiatives, download our CSR Report (PDF, 8.66 MB)

Business Conduct and Ethics

Business Conduct and Ethics

Lumentum’s Code of Business Conduct outlines the broad principles of legal and ethical business conduct embraced by the company as part of our commitment to integrity. We expect all Directors, employees, agents, and contractors to act in a manner that complies both with the letter and the spirit of the Code. The Code is available in all local languages where we operate.


Human Rights

Human Rights

Lumentum is committed to uphold the human rights of workers and to treat each of them with dignity and respect. Lumentum enforces several policies to protect the rights of its workers. These are embedded in our Corporate Social Responsibility Policy, Code of Business Conduct, Supplier Code of Conduct and through our commitment to the Responsible Labor Initiative (RLI). In addition, we ensure there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain.

Disclosure for the UK Modern Slavery Act (MSA 2015) and the California Transparency in Supply Chains Act (SB 657).


Data Privacy and Security

Data Privacy and Security

The security of our information systems is critical to our business success. Information security can impact both reputational and competitive aspects of our work. It helps us to capture our innovations through the protection of intellectual property and it enables our everyday work across all our teams. Our Privacy Program Committee oversees the protection of data, information, and assets and ensures compliance with all applicable global data privacy requirements.


Supply Chain Management

Supply Chain

Key to our success is our relationship with, and the performance of, our supply chain partners. We engage with over 700 direct suppliers and several core contract manufacturers. Strategically, we aim to design agility, resiliency, and scale into our global supply chain for all new and existing products.

Lumentum is committed to acting ethically and complying with all applicable laws and regulations of the countries where we do business. We have the same high expectations of our suppliers and require their signed acknowledgement of our Supplier Code of Conduct and/or Channel Partner/Distributor Code of Conduct.

We complete annual risk assessments of our supply chain using RBA’s tools and approach. We evaluate our direct and indirect suppliers to the RBA Code of Conduct which covers five categories: labor and human rights, environment, health and safety, ethics and the management systems that support these topic areas. 

The first level assessment includes an evaluation of our top 200 suppliers by spend and considers geographical locations, spend level, industry, and international indices from organizations such as UNICEF, World Resources Institute, International Labor Organization.

The second level assessment is based on a detailed Self-Assessment Questionnaire (SAQ) that evaluates suppliers’ compliance with the RBA Code at their corporate and manufacturing sites. This assessment covers all major suppliers and any supplier that was rated high risk in the first level assessment. We work with our suppliers on corrective actions for the areas identified as high risk. 

We also require key management staff of our Contract Manufacturers to complete RBA Code of Conduct training to ensure the Code requirements are understood and implemented within their facilities. 


Responsible Business Alliance

RBA Logo

Lumentum is a proud member of the Responsible Business Alliance (RBA), the world’s largest industry coalition dedicated to corporate social responsibility in supply chains. The RBA Code of Conduct establishes industry guidelines for social, environmental, and ethical practices.

Lumentum fully supports the vision and mission of the RBA, its Code of Conduct, and the collaborative approach to improving working and environmental conditions across the supply chain. Our Corporate Social Responsibility Policy aligns with the RBA and its objectives. We conduct internal reviews and audits of our facilities to the RBA Code of Conduct to continuously improve our own operations.

We require the same high levels of commitment from our partners and suppliers through our Supplier Code of Conduct. We encourage and hold our first-tier suppliers accountable to attain high-level standards. Using RBA’s tools and approach, we actively monitor our supply chain, where applicable.  

Together, we envision an electronics industry that is devoted to leading global sustainability and ethical practices for the well-being of its workers, businesses, and the environment.


Conflict Minerals

Lumentum is committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity, and environmental responsibility. Lumentum complies with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as well as the applicable requirements of Section 1502 of the Dodd-Frank Act, which aims to prevent the use of minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC) or in adjoining countries.

As a member of the Responsible Minerals Initiative (RMI) we require all our suppliers to source tin, tantalum, tungsten and gold (3TG) only from smelters conformant with the Responsible Minerals Assurance Process (RMAP) assessment protocols. Affected suppliers are required to provide completed Conflict Minerals Reporting Templates (CMRT) detailing the tin, tantalum, tungsten, and gold (3TG) smelters in their supply chain. Lumentum pays additional attention to suppliers reporting high-risk smelters (i.e. a smelter that sources from the covered countries and is not currently RMAP conformant).

In 2020, we expanded our Conflict Minerals program to include cobalt sourcing in our supply chain, and in 2022, extended it to mica. We follow the same process of supplier inquiry for cobalt and mica sourcing as for conflict minerals (3TG) by using the cobalt reporting template and the extended minerals reporting template for mica.

Our annual Specialized Disclosure Report (Form SD), including the Lumentum Holdings Inc. Conflict Minerals Report, is publicly available at www.lumentum.com/investors. For more information on Lumentum conflict minerals program contact ConflictMinerals@Lumentum.com.


Substance Restrictions

Lumentum is committed to compliance with all applicable product environmental laws and regulations, inclusive of EU Directive 2011/65/EC (RoHS), Directive 2012/19/EC (WEEE) and Regulation 1907/2006/EC (REACH). We have issued position statements on REACH, RoHS and WEEE.

Lumentum currently fulfills, and will continue to fulfill, all our obligations under these regulatory schemes. We participate in technical working groups and stakeholder consultations for EU RoHS legislation reviews and RoHS exemptions evaluations to ensure we are up to date on the latest and future regulations to appropriately plan our product development.  

We require all our suppliers to complete Lumentum’s Compliance Data Form with material composition and to disclose any regulated substances present in parts and materials purchased by Lumentum. Compliance with substance restrictions is required for component qualification, release to manufacturing, and is continuously reviewed against new substance requirements until product discontinuance.

We continuously monitor technical progress and work closely with our suppliers to proactively reduce the use of hazardous substances in our products. Lumentum eliminated four phthalates (BBP, DBP, DEHP and DIBP) restricted by the RoHS amending Directive (EU) 2015/863 from all products. Our products also comply with the new TSCA restriction of phenol, isopropylated phosphate (3:1) (PIP 3:1) and pentachlorothiophenol (PCTP) before the ban takes effect in 2024. We regularly evaluate our products against declarable substances included in the International Electrotechnical Commission (IEC) 62474 standard.

Please contact Customer.Service@lumentum.com for more information on Lumentum product compliance.


Global Trade

It is the policy of Lumentum, headquartered in the United States, to conduct business in compliance with all relevant export laws and regulations of the United States as well as with those of all other countries in which Lumentum and its subsidiaries operate. Lumentum's products and technology may be subject to the Export Administration Regulations (EAR) or the International Traffic in Arms Regulations (ITAR). Lumentum complies fully with these laws and regulations as well as with those of the Office of Foreign Assets Control (OFAC). For more information on Lumentum's Export Compliance policy and practices contact GlobalTrade@Lumentum.com.