Lutron Electronics Co., Inc.
Supplier Code of Conduct

Lutron’s supplier code of conduct describes our corporate responsibility requirements for our suppliers. These requirements are consistent with the Principals and Standards found within the Ethical Supply Management Conduct guidelines published by the Institute for Supply Management.

Since 1961, Lutron Electronics Co., Inc. has been committed to conducting its procurement business in an ethical, legal, environmentally and socially responsible manner. Lutron is guided by it’s 5 principles: Take care of the Customer, Take care of the Company, Take Care of People, Innovate with a High Standard of Quality and Deliver Value to the Customer.

Lutron’s commitment to the aforementioned business practices extends to its diverse and worldwide supply base. It is Lutron’s expectation that all suppliers embrace and conform to this code without delay. Suppliers are expected to be familiar with the business practices of their suppliers, agents and subcontractors and ensure they operate within the guidelines of this code. Failure to comply with this code may result in discontinuance of business relationships. All Lutron suppliers must meet the following minimum requirements:

I. COMPLIANCE WITH LAWS, REGULATIONS AND PUBLISHED STANDARDS

All suppliers must comply with all applicable laws, codes or regulations of the countries, states and localities in which they operate. This includes, but is not limited to, laws and regulations relating to environmental, occupational health and safety, and labor practices. In addition, Lutron suppliers must require their suppliers to do the same.

II. ETHICS AND STANDARDS OF CONDUCT

Suppliers, their agents and subcontractors are expected to conduct business with integrity and mutual respect and to uphold the highest standards of ethics and behavior, including:

1) Business Integrity
Any and all forms of illegal or inappropriate activity, including, but not limited to, corruption, misrepresentation, extortion, embezzlement or bribery, are strictly prohibited and may result in termination of any or all supply agreements with Lutron Electronics Co., Inc.and possible legal action.

2) Company Information
Confidential and proprietary information addressing matters such as Lutron’s business activities, strategies, plans, structure, technology, customers, financial situation and performance is critical to the company’s success, and cannot be disclosed or used, except in accordance with applicable regulations, contractual requirements and this code. It is vital that our business partners safeguard Lutron’s information and therefore suppliers must:
• comply with applicable non-disclosure agreements and contractual confidentiality requirements regarding information belonging to or in the possession of Lutron.
• never misuse or disclose confidential or proprietary information to unauthorized parties.
• properly handle information regarding the Lutron brand or logo.
• receive Lutron’s written approval before using information about Lutron or Lutron’s name or brand identity publicly in any publicity, advertising or website.

3.) Conflicts of Interest
Suppliers should avoid engaging in any business activity that would conflict or interfere with their provision of products and services to Lutron.

4.) Business Gratuities
Lutron and its employees are not permitted to accept gifts from current or potential suppliers. Lutron’s suppliers are expected to compete based on the merit of their products and services, not through gifts, entertainment, or other business gratuities. Although business courtesies can promote successful working relationships and good will, Lutron expects its suppliers to follow all applicable laws and Lutron’s rules and procedures with respect to gifts, entertainment, and other business courtesies when working with or representing Lutron.

III. LABOR PRACTICES

1.) Child Labor
Lutron will not engage in or support the use of child labor. Suppliers are expected to comply with all applicable local child labor laws and employ only workers who meet the applicable minimum legal age requirement for their location.

2.) Minimum Wages
Suppliers shall provide wages for regular and overtime work and benefits that meet or exceed legal requirements

3.) Forced Labor
Suppliers shall not use any forced, prison or indentured labor. Lutron will not engage in or support the use of forced or involuntary labor and as a result, Lutron will not purchase material or services from a supplier utilizing forced or involuntary labor.

4.) Discrimination
Lutron supports diversity and equal opportunity in employment. Unlawful discrimination in the workplace is not tolerated. Suppliers are expected to comply with all applicable local laws concerning discrimination in hiring and employment practices.

IV. ENVIRONMENTAL PRACTICES

Lutron values environmentally preferred products. We work with and encourage our suppliers to create products that are energy efficient, highly recyclable, and contain recycled materials and the lowest amounts of hazardous materials. All Suppliers to Lutron shall comply with all the environmental laws and regulations applicable to their operations worldwide. Such compliance shall include, among other things, the following items:

• obtaining and maintaining environmental permits and timely filing of required reports
• proper handling and disposition of hazardous materials
• monitoring, controlling and treating discharges generated from operations
• conform to applicable labeling and warning requirements

Adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public.

V. HEALTH AND SAFETY

Lutron is committed to the safety and health of its employees and conducts its operations in compliance with applicable laws and regulations. Suppliers are expected to provide a safe working environment and must comply with all applicable health and safety laws and regulations in the countries in which they operate.

Suppliers shall, among other things, address the following:

• be committed to the safety and health of its employees, and shall ensure that required training of personnel has been completed prior to initiating any work activity. The supplier should have or subscribe to a written safety and health program.
• be responsible for addressing and controlling worker exposure to potential safety hazards in conformance with all applicable standards and/or regulations and by utilizing suitable means, e.g., design, engineering and administrative controls, preventative maintenance, training, work procedures, and appropriate personal protective equipment.
• have emergency plans and response procedures that implement all applicable laws
and regulations regarding emergency preparedness, addressing emergency reporting, notification and evacuation procedures, training and drills and appropriate hazard detection and suppression equipment.
• have procedures and systems to manage, track and report occupational injuries and
illnesses.

VI. COMMUNICATION

Suppliers are encouraged to take appropriate steps to ensure that provisions of this code are communicated to their employees and throughout their own supply chain. Suppliers are also encouraged to ensure that the principles referred to above are adopted and applied by their employees, suppliers, agents and subcontractors as far as reasonably possible.