Electronic industry supply chain code of conduct

• Risk-based supplier evaluations.

  Trimble performs evaluations of potential suppliers according to our risk-based approach. This approach includes preliminary risk assessments and supplier assessment questionnaires.

• Supplier audits.

  Our periodic supplier audit program includes an evaluation of our supplier’s compliance with the EICC Code. A finding of nonconformance with the EICC Code will result in a corrective action plan and timetable to remedy. The corrective action plans outline how a supplier will resolve issues uncovered in audits.

• Supplier agreements.

  Trimble seeks to incorporate requirements of compliance with the EICC Code and the terms of this Trimble Supply Chain Code of Conduct in our purchasing agreements and/or purchase order terms and conditions that are put in place with our direct suppliers and ODM (original design and manufacturing) suppliers.

The following paragraphs explain Trimble’s Risk-Based supplier management system:

Phase 1: Supplier EICC Risk review

Trimble considers supplier risk profiles and conducts a formal risk assessment if necessary. The risk factors we use include:

• Location.

  Risk is higher in some locations than others.

• Procurement category.

  Risk is higher in some procurement categories, such as a small business manufactured parts supplier, and lower in others, such as large business or a Western (USA or European) owned company operating in a developing country.

• Company information.

  Insight from previous audits, press articles, incidents, or accidents may affect our assessment of supplier risk.

Phase 2: Assessment

If Trimble's risk assessments show a supplier poses high risk, the supplier must complete a self-assessment questionnaire. These help us identify potential risks, and help suppliers understand our expectations for conformance to the EICC Code of Conduct. Trimble reviews and provides feedback on the self-assessment, and suppliers create and implement an improvement plan, if required.

Phase 3: Validation and Improvement

• Validating conformance:

  Trimble periodically audits suppliers for quality control purposes and such audits will include compliance to EICC Code of Conduct requirements.

• Responding to Non-conformance:

  We rank non-conformance to the EICC Code using standard ISO guidelines.

  • Major non-conformance: A significant failure in the management system that affects a company's ability to ensure conditions conform to the EICC Code. Suppliers must demonstrate that they have addressed major non-conformances within 180 days, by delivering appropriate documentation or other evidence of resolution. For major non-conformances that require subsequent monitoring, we return to all audited sites within one year.

  • Minor non-conformance: Not a systemic problem and typically an isolated finding, such as an overdue corrective action from an internal audit or a procedure that has not been revised to reflect a change in regulations. Suppliers have up to 360 days to address minor non-conformances.

  • Corrective action plans: Trimble requires suppliers to provide a detailed corrective action plan addressing all identified non-conformances within 30 days of receipt of the site audit report. We review these plans and may request quarterly reports to allow us to monitor progress and subsequent closure of non-conformances. When progress is inadequate, we will intervene to help create a more effective plan.

  • New suppliers: We introduce prospective suppliers to the EICC Code requirements as implemented pursuant to our Trimble supply chain code of conduct in the early stages of evaluation; and a supplier’s acceptance of these becomes one of our conditions for engagement with the new supplier.

Trimble Inc.

Rev. October, 2016