Effective Date: 1 March 2024
PURPOSE
Trimble is transforming the way the world works by delivering products and services that connect the physical and digital worlds. Core technologies in positioning, modelling, connectivity and data analytics enable customers to improve productivity, quality, safety and sustainability. Trimble is a truly global company with operations in over 40 countries and over 12,000 employees.
COMMITMENT
Trimble is committed to respecting human rights and upholding the highest standards of ethical conduct in all of its operations and throughout its supply chain. This commitment to human rights covers forced labour, slavery, child labour, and human trafficking and is outlined in our Code of Conduct and Trimble’s Third-party Code of Conduct. As an active member of the Responsible Business Alliance ("RBA"), Trimble uses the RBA Code of Conduct as the basis of its Supplier Code of Conduct.
We are committed to acting ethically, with integrity and promoting work environments that engender conditions of freedom, equality, security and dignity. Trimble expects its employees, contractors, and suppliers to prevent acts of modern slavery and human trafficking from occurring within both its business and supply chains and has codes of
conduct (including the Code of Conduct and the Third Party Code of Conduct) in place to establish standards expected across our business activities.
Trimble's commitment to responsible business practices is not limited to its efforts to prevent forced labour. The company is also committed to promoting a more inclusive and sustainable future for all. Trimble's sustainability goals include reducing its environmental impact, promoting social responsibility, and creating a more diverse and inclusive
workforce.
COMPLIANCE
Trimble's Code of Conduct and its Third-party Code of Conduct outline the company's expectations regarding human rights compliance. As an active member of the Responsible Business Alliance (RBA), Trimble uses the RBA Code of Conduct as the basis of its Supplier Code of Conduct. The RBA Code of Conduct contains specific requirements covering slavery and human trafficking, and it goes beyond simply eliminating human trafficking. It also includes compliance with global labour standards and applicable laws, worker health and safety, the environment, business ethics, and the management of internal systems and controls to ensure effective compliance. Trimble is committed to working with its suppliers to ensure that they meet the company's high standards for human rights compliance. The company conducts audits of its suppliers to assess their compliance with the RBA Code of Conduct, and it provides training and support to help suppliers improve their performance.
Our governance framework and related corporate policies empower our employees and contractors to report and escalate any concerns of unethical conduct, whether relating to modern slavery, human trafficking or other matters. All Trimble employees are provided with the Code of Conduct upon hire and undergo initial and continual training on the contents of the Code. The company's commitment to ethical conduct and human rights is reflected in its codes of conduct, its membership in the RBA, and its training and support programs for employees and suppliers.
DUE DILIGENCE AND SUPPLIER ASSESSMENTS
Trimble conducts due diligence on all new suppliers during onboarding and on existing suppliers at regular intervals.
We require suppliers, vendors, and contract manufacturers to fully comply with local and national laws where Trimble
does business. Our Third Party Code of Conduct requires an authorised member of the supplier to observe and
execute the code. The Third Party Code of Conduct, along with Trimble's Code of Conduct, sets standards for our employees, suppliers, and partners. Suppliers are required to commit to Trimble’s Third Party Code of Conduct which includes having a policy on how they prevent modern slavery and human trafficking within their organisation.
Each year, Trimble selects a number of suppliers for assessment based on various criteria, such as specific spend, country-specific requirements, and risk analysis. Trimble's risk assessment process considers country, sector, and transaction risk. New business partnerships or relationships are also included in the risk assessment.
Trimble's supplier due diligence and risk management processes help the company to identify and mitigate the risks of modern slavery and human trafficking in its supply chain. By requiring suppliers to comply with its Third-Party Code of Conduct and conducting regular assessments, Trimble can help to ensure that its suppliers are meeting its standards for ethical conduct and human rights compliance.
TRIMBLE’S SUPPLIER ASSESSMENT PROCESS
Trimble uses the MetricStream application to automate the registration, onboarding, and continuous monitoring of
suppliers. The application includes sections on Business Conduct and Ethics, Supply Chain Management,
Environmental Health and Safety, and Labor and General Human Rights. Suppliers can submit evidence-based
documentation and data as part of the assessment process. Trimble may also conduct on-site audits of suppliers as
part of the assessment process.
The suppliers’ responses are assessed to evaluate their management system in terms of compliance with our Third
Party Code of Conduct and Corporate Social Responsibility. Responses are also reviewed to evaluate the risks of
each supplier or engagement, and sequence due diligence assessments, while also qualifying, segmenting, and
ranking third parties, including frequency of periodic assessments based on the supplier’s risk profile. The
MetricStream database is designed to flag the responses to certain questions, so Trimble can conduct further due
diligence and request further information where necessary. The initial due diligence and validation of responses is
completed with the use of the database. Trimble also reviews the scores of the SAQ completed by its suppliers who
are members of the RBA to confirm that they are not deemed to be high risk. Trimble reached out to those suppliers
with responses that were flagged in the system and closed any additional action items. We encourage suppliers to
participate in training programs, to recognize and prevent modern slavery. We also seek to raise supplier awareness
of and conformance to Trimble’s Third Party Code of Conduct and specialised labour standards, including ways to
identify and address the risks of modern slavery.
APPROVAL
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes
Trimble’s modern slavery and human trafficking statement for the financial year ending 31
December 2023. It has been approved by the TEBV company board of directors for and on behalf
of UK-based subsidiaries.