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Due Diligence and
Supplier Code of Conduct

Our due diligence framework and processes are modeled after the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Business Conduct and the United Nations Guiding Principles on Business and Human Rights.

The Cisco Supplier Code of Conduct (the “Code”) is a central component of our due diligence process. The Code sets forth our expectations of suppliers across five key areas: labor, health and safety, environment, ethics, and management systems. As a founding member of the Responsible Business Alliance (RBA), Cisco contributed to the development of the RBA Code of Conduct and adopted the Code as our own Supplier Code of Conduct. Using common standards for social and environmental responsibility enables participating companies to more effectively drive change across global supply chains.

We hold our suppliers — and their suppliers — accountable to the Code and other responsible sourcing policies, and we engage our suppliers to foster improvement through support and education. The Supply Chain Human Rights team develops and implements our due diligence strategy, including our engagement process described below:

Supplier Engagement on Code of Conduct

  • Supplier onboarding

    New suppliers are assessed to identify potential social and environmental risks within their operations.

    After suppliers are fully onboarded to provide products to Cisco, they become part of our regular supplier engagement process.

  • Risk assessment

    We evaluate suppliers based on social and environmental risk factors and Cisco's exposure to those risks from operations and production.

    Suppliers produce CAPs and evidence that they have implemented their plans.

  • Self assessment and audits

    We require suppliers to complete RBA Self-Assessment Questionnaires (SAQs) and audit high-risk suppliers using RBA's Validated Assessment Program (VAP) to assess their conformance to our Code of Conduct.

    Suppliers must address or downgrade priority issues within 30 days and other findings within 180 days.1

  • Corrective action plans

    If nonconformances are found, we review and approve supplier Corrective Action Plans (CAPs) and monitor their progress toward closure.

    For issues such as the monitoring of working hours, suppliers provide long-term improvement plans.

  • Capability building

    We offer training to help suppliers better align with our values and to drive continuous improvement. For example, we provide guidance and support to sites where practicable to engage workers on use of personal protective equipment (PPE).

    Cisco works closely with suppliers until performance improves and to validate finding closure.

  • Suppliers produce CAPs and evidence that they have implemented their plans.

  • Suppliers must address or downgrade priority issues within 30 days and other findings within 180 days.1

  • For issues such as the monitoring of working hours, suppliers provide long-term improvement plans.

  • Cisco works closely with suppliers until performance improves and to validate finding closure.

1 In alignment with RBA guidance.

Identifying and Assessing Risk

Proactively assessing prospective mergers and acquisitions

As Cisco continues to grow through its acquisition strategy, we have taken steps to embed responsible business into the evaluation process of target companies before closing. We initiate environmental and human rights risk assessments as soon as a target company is announced. We assess if the target company has policies and procedures to safeguard the environment and respect human rights within their operations and supply chains.

Responsible Business Survey

We assess new suppliers and new supplier sites during the onboarding process through a questionnaire designed to identify potential social and environmental risks. If risks are identified, we follow up with the supplier to further investigate and determine if the risks need to be addressed prior to launching or scaling business with the supplier. Examples of the types of risk that the questionnaire can identify include:

  • Forced labor risks, such as foreign migrant workers paying recruitment fees
  • Under age child labor; young workers working overtime or the night shift
  • Critical nonconformances to the RBA Code of Conduct
  • Existing pollution violations

In fiscal 2025, we identified four sites with risks through this survey process, and these cases are either closed or in progress towards closure.

Self-Assessment Questionnaire (SAQ)

Our suppliers are required to refresh the RBA's industry-standard SAQs annually. This assessment gives suppliers insight into their own performance and helps Cisco develop leading indicators for risks that can be addressed during an audit or other due diligence processes. Data on SAQ Coverage by Supplier Type can be found on the Data and Assurance page.

Social and Environmental Risk Assessment

Our due diligence processes follow a risk-based approach. Every year, we prioritize suppliers and sites for RBA's Validated Assessment Program (VAP) audits by assessing a variety of risk indicators. Our analysis includes geographic risk factors that may highlight social and environmental risks associated with the countries where our suppliers operate. Our analysis also incorporates suppliers’ past audit performance, repeated audit nonconformances, and presence of vulnerable workers, including foreign migrant workers, young workers, and student workers in their operations. The results of these assessments inform our due diligence, audit plan, and supplier engagement. Each year, we aim to audit at least 50% of supplier sites deemed high-risk according to this annual risk assessment process.

Risk Assessment Factors

Supplier Risk

High-risk
vs.
Low-risk

Geographic Risk Factors

  • Indicators for forced labor and child labor
  • Indicators for environmental, health and safety, and ethics risks

Site-level Risk

  • Past performance on supplier audits
  • Recruitment of vulnerable workers
  • Unresolved issues and repeat audit findings

Exposure Risk

  • Site’s strategic importance to Cisco’s supply chain

Assessing Potential and Actual Impacts Through Audits

Our comprehensive supplier auditing program helps suppliers improve alignment to the Code. We have adopted the RBA's VAP for onsite audits. As with the SAQs, using RBA's industry-standard programs and protocols reduces survey and audit fatigue and creates consistent conformance expectations for suppliers across the industry.

RBA trains and approves third-party auditors to conduct audits on site. The RBA sets clear conduct and qualification requirements for the independent third-party audit firms and auditors, as shared in the RBA Auditor Guidebook. Auditors walk through production areas, dormitories, and canteens; interview workers and management; and review policy and procedure documentation.

We aim to audit 100% of our outsourced manufacturing partner sites. During fiscal 2025, we audited2 94% of our manufacturing partner sites. Sometimes, sites are unable to maintain valid audits due to relocation of manufacturing operations. We work with the supplier to determine when they can renew their audit at the earliest possible opportunity when the transition is complete. In fiscal 2025, we also audited more than 50% of component supplier facilities that were deemed high-risk according to our annual risk assessment process.

In fiscal 2025, 179 Cisco supplier facilities conducted an Initial RBA Audit. We estimate these audits covered more than 436,358 workers.3 Working hours and emergency preparedness continue to be the largest percentage of our audit nonconformances. We continue to work with suppliers to drive conformance to our standards and develop long-term improvement plans when necessary.

Visit the Data and Assurance page to review data of our supplier auditing program, including RBA audits and audit findings.

2 According to industry standards, RBA Audits are valid for two years from the date of the Initial audit.

3 The RBA is an industry standard scheme that allows suppliers of multiple customers to demonstrate conformance to a single responsible business conduct standard. Number of workers represents all the workers in the supplier facility, not just those supporting Cisco business.

Key Audit Nonconformances and Actions Taken Across the Globe

The map below shows some of the most common audit nonconformances in fiscal 2025,
including nonconformances that are persistent and challenging.

Prohibition of Forced Labor

  • China
  • India
  • Malaysia
  • Singapore,Taiwan
  • Thailand

Finding

  • Foreign migrant workers paid recruitment fees (e.g., passport or renewal fee, transportation fee, health examination fee, labor agent fee)
  • Orientation health check fee paid by workers, though most are reimbursed within 90 days after commencement of employment

Action Plan

  • Stop charging fees immediately and reimburse workers per RBA Code; for fees exceeding the equivalent of one-month gross base salary, conduct an RBA-approved third-party fees investigation then reimburse workers per RBA-approved amount
  • Take training on the RBA requirements to ensure orientation health check fees are paid by employer at the very beginning
  • Establish a "Zero Fee" policy and communicate it to workers and labor agencies
  • Update procedures and train workers on recruitment fees
  • Monitor the labor agencies to ensure implementation of the "Zero Fee" Policy

Context

  • Supplier had insufficient understanding of RBA Code and requirements regarding recruitment fees, including misinterpretation of the RBA Definition of Fees
  • Local law allows certain recruitment fees to be charged to workers; moreover, local law is silent on orientation health check fee practice, which does not comply with RBA Code
  • Supplier had insufficient monitoring of labor agencies or onsite service providers

Working Hours and Days of Rest

  • China
  • Czech Republic
  • Germany
  • India
  • Japan
  • Malaysia
  • Mexico
  • Philippines
  • Singapore
  • South Korea
  • Taiwan
  • Thailand
  • USA

Finding

  • Overtime in violation of local law requirement
  • Weekly working hours exceed 60 hours
  • Workers do not receive at least one day off every seven days

Action Plan

  • Refine procedures on working hours, enhance the internal working hours controls system, and monitor working hours internally
  • Hire more workers
  • Adjust the production plan to meet production demand
  • Provide training to workers and improve personnel efficiency
  • Forecast on customer demand to deploy the required human resources
  • Deploy more automated machines

Context

  • Local law has strict overtime (OT) limit (e.g., China only allows 36 OT hours/month) that cannot meet company's production demand
  • Labor shortage in local labor market
  • Workers willing to work more OT to increase their income
  • Insufficiently trained workers
  • Lack of supply material, workforce allocation, production demand, urgent business orders, and lead times are complex factors that can lead to excessive overtime

Wages and Benefits

  • China
  • India
  • Malaysia

Finding

  • Social insurance or housing fund not provided per legal requirement
  • The baseline of social insurance and housing fund is lower than that legally required

Action Plan

  • Enroll workers into social insurance and housing fund programs
  • Communicate social insurance and housing fund information and changes to workers and make efforts to meet legal requirements
  • Because the local government accepts current practice on social insurance and housing fund, these issues should be improved step by step, given worker willingness and sufficient communication with workers

Context

  • Chinese social insurance and housing fund standards and exemptions differ across local jurisdictions, leading to a variety of calculation schemes for workers and employers to pay into social insurance and housing fund programs
  • Sometimes contributions are calculated based on minimum wages, rather than workers' average monthly salary that is typically required by law
  • Significant cost for facilities if the social insurance and housing fund is fully covered according to law requirement

Occupational Safety (Health & Safety Permits, Licenses, and Testing Reports, and Risk Assessment)

  • China
  • Indonesia
  • Malaysia
  • Philippines
  • Taiwan
  • Thailand
Finding
  • Legally required permits, licenses, and testing reports are expired or not available
  • Safety inspection on buildings, special equipment and machines were not conducted per legal requirement
  • Inadequate assessment of health and safety hazards
Action Plan
  • Conduct relevant testing
  • Keep a checklist on all certificates/permits and ensure they are renewed/updated on time
  • Appoint responsible persons for certificates/permits and provide training for relevant staff members
  • Refine/amend procedures on certificates/permits management
  • Conduct safety inspections as legally required
  • Identify and assess health and safety hazards throughout the compound
Context
  • For factories (in China) whose buildings were constructed a few years prior and didn't get the building completion approval or fire approval at that time, the local government will no longer issue the certificates
  • Renewal process delayed by government
  • Lack of awareness of the permits' expiration
  • Lack of understanding of legal and RBA requirements
  • Lack of awareness of hazard identification and assessment

Emergency Preparedness (Emergency Exit and Evacuation Drills)

  • China
  • Czech Republic
  • India
  • Japan
  • Malaysia
  • Netherlands
  • Philippines
  • South Korea
  • Taiwan
  • Thailand
  • USA
Finding
  • Exit route and/or doors do not meet legal or RBA requirements (e.g., missing emergency exits, lack of lighting, blocked exits or evacuation routes, doors cannot be opened in one single motion, and/or improper fire doors)
  • Emergency support facilities not inspected as required
  • Evacuation fire drills not conducted as per legal or RBA requirement
Action Plan
  • Install fire equipment on emergency exits as required
  • Upgrade the emergency exit doors to meet RBA and legal requirements
  • Train employees on RBA and legal requirements
  • Inspect emergency exits regularly and record the results
  • Conduct fire drills as required
  • Develop and amend procedures on emergency exits, management, and evacuation fire drills
Context
  • Auditee did not thoroughly understand RBA Code requirements, which clearly specify emergency exit doors to be opened by one single motion without keys, card swiping, locking devices, etc.
  • Misinterpretation of the fire regulation requirements
  • Negligence of personnel and lack of safety awareness
  • Inadequate regular monitoring or inspection of emergency exit doors

Supplier Responsibility

  • China
  • India
  • Malaysia
  • Mexico
  • Philippines
  • South Korea
  • Taiwan
  • Thailand

Finding

  • Missing verification visits or audits on major suppliers, onsite service providers (such as cafeteria, janitorial, or security services), or labor agencies
  • Audits on major suppliers, onsite service providers, or labor agencies have critical nonconformances that have not been closed
  • Inadequate or missing process to ensure next-tier major suppliers implement the RBA Code

Action Plan

  • Conduct verification visits or audits on major suppliers, onsite service providers, or labor agencies
  • Follow up and correct the nonconformances on major suppliers, onsite service providers, or labor agencies
  • Establish proper procedures to ensure next-tier major suppliers implement the RBA Code
  • Communicate and provide training to next-tier major suppliers on RBA Code requirements

Context

  • Lack of understanding that major suppliers, onsite service providers, or labor agencies need to have verification visits or audits per RBA Code requirements
  • Some nonconformances, such as overtime and social insurance, are more complex or difficult to close
Learn more about our RBA audit nonconformances.

Ceasing, Mitigating, and Preventing Adverse Impacts

Corrective Action Plans (CAPs)

When we receive RBA audit reports, our team records and tracks individual nonconformances from discovery until closure, and suppliers must develop CAPs for individual nonconformances. We typically engage with our suppliers remotely to support implementation of onsite actions. In this process, suppliers are required to identify root causes of the nonconformances and develop CAPs with proposed changes to policies, procedures, worker training, and/or communications. They also propose key performance indicators to measure the effectiveness of their actions. Plans are submitted to Cisco and approved if they meet our requirements. A CAP will be opened for any audit that does not achieve all of the following: RBA Gold Recognition, full conformance with the Code requirements on the Prohibition of Forced Labor and Young Workers, and no other Major nonconformances. In fiscal 2025, Cisco reviewed and approved 100% of these CAPs.

If a CAP does not meet our requirements, we coach suppliers on root cause analysis using best practice frameworks, such as the 5 Whys or fishbone mapping. This work drives lasting positive change by addressing the root cause rather than implementing short-term fixes.

Supplier CAPs must adhere to Cisco deadlines and closure requirements as informed by the RBA VAP Protocol. We consider nonconformances closed after we review evidence confirming that workers have been remediated, communicated to, and/or trained in revised policies and procedures. As needed, we use third-party auditors to conduct closure audits on site, as informed by the RBA VAP Protocol, to validate nonconformances have been adequately addressed.

Supply chain management is routinely informed of suppliers’ performance on these plans and holds suppliers accountable to make progress. When we lack leverage to drive resolution, Cisco collaborates with industry peers to foster collective action. If a supplier fails to make efforts to improve, we may stop awarding new business and, when necessary as a last resort, terminate the relationship.

In fiscal 2025, we achieved a 99% closure rate for Priority and Major nonconformances, excluding working hours and social insurance nonconformances due to their longer resolution times. Nonconformances not closed during the year were primarily a result of awaiting government permits and posed no significant risks to workers or the environment.

Visit the Data and Assurance page for more details on CAPs.

Worker Engagement in CAP Review

We’ve observed that encouraging suppliers to involve their workers in the corrective action process for health and safety issues can lead to longer-lasting solutions. To address health and safety nonconformances — such as personal protective equipment, chemical safety management, and accessibility infrastructure for workers with disabilities — we require selected sites to actively involve workers during the CAP process. The site is instructed to establish a project team, comprising both worker representatives and management. These teams are responsible for identifying root causes of the issue(s), jointly developing improvement plans, and collaborating to implement these plans alongside relevant internal stakeholders. During this process, the team gathers frontline workers’ perspectives on the underlying causes of the issues and solicits suggestions for improvements — for example, via surveys and interviews — to ensure their health concerns and needs are adequately addressed. The supplier must also ensure that an effective grievance mechanism remains in place after the project is concluded, enabling workers to continue to provide input and share concerns regarding the issue, if needed, and ensuring ongoing monitoring and follow-up. We provide suppliers with guidance and resources, including sample surveys and root cause analysis tools, and set regular meetings with sites to support effective worker engagement.

Building Suppliers' Capabilities and Training

Through capability building, we aim to train suppliers and site managers in best practices to address social and environmental risks. We continuously develop trainings based on identified supplier needs and trends. In fiscal 2025, we delivered trainings to address the following frequent fiscal 2024 audit nonconformances:

  • Supplier Management: How to cascade Code requirements and monitor sub-supplier compliance
  • Emergency Preparedness: How to maintain effective and safe emergency exits
  • RBA Management Systems: How to maintain robust management systems to meet RBA requirements for labor, health and safety, environment, and ethics

510 attendees from 178 supplier facilities took these trainings. Based on pre- and post-training assessment results, attendees’ awareness improved on average by 14% and as much as 48% on specific topics. We also provided trainings to suppliers on key environmental issues.

To improve working conditions, we also build supplier capabilities through tailored coaching, especially for suppliers undergoing an RBA audit for the first time or those who received a low audit score. To help them build more effective CAPs, we may offer suppliers a CAP kickoff meeting to share best practices and provide guidance on how to address nonconformances.

Visit the Data and Assurance page for more information on our capability building efforts.

Conducting Due Diligence on Indirect Suppliers

Since fiscal 2020, we have required our indirect suppliers to abide by our Supplier Code of Conduct. These are suppliers that do not contribute to the manufacturing of Cisco products, but rather provide goods and services that support Cisco’s operations.

  • Annually, we risk-assess global preferred indirect suppliers (based on spend) by reviewing risk management data, including data obtained during the supplier onboarding process, open ethics cases, denied parties list, and geographic supply chain risk considerations. In fiscal 2025, this process identified 21 suppliers in 15 countries with potential risks to conduct further due diligence on.
  • To conduct further due diligence, we utilize the RBA Indirect Spend SAQ to help better understand the unique human rights and worker well-being risks posed by indirect suppliers' operations. The RBA provides a risk rating for submitted SAQs to help companies determine appropriate actions to address identified risks.
  • During fiscal 2025, RBA Indirect Spend SAQ results did not indicate any high-risk ratings.

Assessing Our Effectiveness

In fiscal 2025, we launched quarterly effectiveness reviews to evaluate both process- and impact-oriented metrics across our due diligence areas. We prioritized these metrics based on the significance of their impact, giving particular consideration to representing the effects on rightsholders and each metric's ability to drive actionable improvements. Our approach reflects a strong commitment to continuous improvement, as we regularly refine our reviews to capture the most meaningful and effective indicators across a spectrum of due diligence areas.