Apple Supplier Code of

Conduct and Supplier

Responsibility Standards

Effective November 11, 2025

Version 5

Table of Contents

Apple Supplier Code of Conduct

Our Expectations

1. Labor and Human Rights

1.1 Anti-Discrimination

1.2 Anti-Harassment and Abuse

1.3 Prevention of Forced Labor and Human Trafficking

1.4 Third Party Employment Agencies

1.5 Prohibitions on Child Labor and Juvenile Worker Protection

1.6 Working Hours

1.7 Wages and Benefits

1.8 Freedom of Association and Collective Bargaining

2. Health and Safety

2.1 Safe Workplace

2.2 Health and Safety Permits

2.3 Occupational Health and Safety Management

2.4 Emergency Preparedness and Response

2.5 Incident Management

2.6 Working and Living Conditions

2.7 Health and Safety Communication

3. Nature, Climate, and Environment

3.1 Environmental Permits and Reporting

3.2 Regulated Substances

3.3 Waste Management

3.4 Water Management

3.5 Air Emissions Management

3.6 Greenhouse Gas Emissions Management

4. Responsible Materials Sourcing

4.1 Materials Due Diligence

4.2 Materials Supply Chain Traceability

5. Community and Rightsholder Engagement

5.1 Affected Stakeholder Engagement

5.2 Worker Engagement and Grievance Management

5.3 Whistleblowing and Non-Retaliation

6. Business Conduct

6.1 Business Integrity

6.2 Confidentiality and Intellectual Property

6.3 Anti-Corruption

6.4 Fair Business Practices

Apple Supplier Responsibility Standards

Management Systems

Anti-Discrimination

Anti-Harassment and Abuse

Prevention of Forced Labor

Third Party Employment Agencies

Foreign Contract Worker Protections

Underage Labor and Juvenile Worker Protection

Educational Program Management

Working Hours Management

Wages, Benefits and Contracts

Freedom of Association and Collective Bargaining

Worker Engagement and Grievance Management

Occupational Health and Safety Management

Apple Supplier Code of Conduct Handbook — page 3

Chemical Management

Fire Safety Management

Emergency Preparedness and Response

Infectious Disease Preparedness and Response

Incident Management

Dormitories and Dining

Machine Safety

Waste Management

Water and Wastewater Management

Stormwater Management

Air Emissions Management

Greenhouse Gas Emissions Management

Boundary Noise Management

Responsible Sourcing of Primary, Recycled, and Renewable Materials

Facility Siting, Energy and Environmental Investments

Glossary

Annex

APPLE

1. Labor and Human Rights

Apple's supply chain requirements are designed to protect workers and uphold internationally recognized principles of labor

and human rights.

Employment must be freely chosen

Suppliers must not use forced labor, bonded labor, indentured labor, involuntary prison labor or human trafficking. Workers

must be free to leave employment in accordance with applicable requirements and must not be subject to coercion, threats or

unlawful restrictions on movement.

Responsible recruitment

• Workers must not be charged recruitment fees or related costs to secure employment.

• Suppliers are responsible for ensuring recruitment practices comply with Apple's requirements and applicable law.

• Where recruitment fees or related prohibited charges have been imposed, suppliers must take appropriate corrective action and

provide repayment where required.

• Employment terms must be communicated accurately and in a language workers can understand.

Working hours and rest

Apple's supplier requirements establish limits on working hours and require regular rest. Suppliers must manage schedules so

workers receive required days of rest and overtime is voluntary except where applicable law or emergency requirements

provide otherwise.

Young workers and child labor

Suppliers must not employ workers below the applicable minimum legal age and must comply with requirements protecting

young workers from hazardous or prohibited work.

APPLE

2. Health and Safety

Suppliers must provide a safe and healthy workplace and take systematic steps to identify, prevent and control occupational

risks.

Workplace safety

• Identify workplace hazards and implement controls to prevent injury and illness.

• Provide appropriate personal protective equipment where engineering or administrative controls are insufficient.

• Maintain safe machinery, equipment, electrical systems and workplace conditions.

• Provide emergency preparedness, evacuation and response procedures.

• Provide workers with appropriate safety information, instruction and training.

Industrial hygiene and ergonomics

Suppliers must assess exposure to chemical, biological, physical and ergonomic hazards and implement appropriate controls.

Chemical handling, storage, labeling and disposal must be managed to protect workers and the environment.

Housing and basic services

Where suppliers provide worker housing or other facilities, those facilities must meet applicable requirements for safety,

sanitation, emergency access, living conditions and basic services.

Safety from the start

Health and safety requirements apply across manufacturing, logistics, repair, service and other supplier activities. Suppliers are

responsible for identifying risks before work begins and for correcting unsafe conditions.

APPLE

3. Environmental Responsibility

Apple requires suppliers to manage environmental impacts responsibly and to support continuous improvement in

environmental performance.

Environmental management

• Comply with applicable environmental laws, regulations and permits.

• Identify and manage environmental risks associated with operations and products.

• Control emissions, wastewater, waste and hazardous substances.

• Use resources efficiently and reduce avoidable environmental impacts.

• Maintain required records and environmental management controls.

Climate and energy

Apple's current supply-chain program emphasizes reducing greenhouse-gas emissions and increasing renewable electricity

across supplier operations. Suppliers are expected to measure relevant emissions, establish reduction plans and participate in

applicable Apple environmental programs.

Waste and circularity

Suppliers should prioritize prevention, reduction, reuse and recycling of materials and manage waste responsibly. Materials

and processes must comply with Apple's applicable substance and environmental specifications.

Water and chemicals

Suppliers must manage water responsibly and maintain appropriate controls for chemicals used in manufacturing. Apple

requires detailed chemical information from suppliers through its Chemical Safety Disclosure program.

APPLE

4. Ethics and Business Integrity

Apple requires suppliers to conduct business honestly, ethically and transparently.

Anti-corruption

Suppliers must comply with applicable anti-corruption and anti-bribery laws and must not offer, promise, authorize or provide

improper payments, benefits or anything of value to influence a business decision.

Gifts and entertainment

Business gifts, meals, entertainment and other benefits must be consistent with applicable law and Apple's requirements.

Suppliers must not use benefits to improperly influence Apple employees or other parties.

Accurate records

Business records, payroll records, working-hour records, environmental data, audit materials and other required

documentation must be accurate, complete and maintained appropriately. Suppliers must not falsify or conceal information.

Intellectual property and confidentiality

Suppliers must respect intellectual property rights and protect confidential information received from Apple and other business

partners. Information may only be used and disclosed as authorized.

Responsible sourcing

Suppliers must conduct appropriate due diligence for relevant minerals and materials and maintain systems for identifying,

assessing and mitigating supply-chain risks.

APPLE

5. Management Systems

Suppliers must maintain management systems capable of implementing the requirements of this Code and the associated

standards.

System element

Expected practice

Policies and accountability

Establish policies, responsibilities and controls covering applicable Code requirements.

Risk assessment

Identify labor, human-rights, safety, environmental and ethics risks and prioritize corrective action.

Training

Provide workers and relevant managers with training appropriate to their responsibilities.

Worker feedback

Maintain mechanisms through which workers can raise concerns without fear of retaliation.

Documentation

Maintain accurate records demonstrating compliance and corrective actions.

Corrective action

Investigate nonconformities, establish corrective plans and verify completion.

Supply-chain oversight

Extend appropriate requirements and due diligence to relevant subcontractors and next-tier suppliers.

Worker grievance mechanisms

Suppliers must provide workers with accessible mechanisms for raising workplace concerns. Workers should be able to raise

concerns without intimidation or retaliation, and suppliers must respond appropriately to reported issues.

Training and communication

Workers must receive information about workplace rights and relevant requirements. Suppliers are responsible for

communicating applicable policies and procedures in a manner workers can understand.

APPLE

6. Supplier Assessments and Accountability

Apple evaluates supplier performance through assessments, worker engagement, documentation reviews and other

verification activities.

Assessment process

Supplier assessments may include physical facility inspections, management and worker interviews, review of records and

evaluation of management systems. Apple also conducts unannounced visits as part of its monitoring approach.

Corrective action

When a violation is identified, suppliers are expected to promptly implement corrective action and strengthen policies and

procedures to prevent recurrence. Apple may verify corrective action before considering an issue resolved.

Core violations

Apple identifies the most serious nonconformities as Core Violations. Public Apple materials state that a Core Violation can

result in immediate probation, notification of the supplier's CEO and restrictions on receiving new business while the violation

is remedied.

Escalation and removal

Suppliers that fail to meet Apple's requirements or do not adequately address serious issues may face restrictions or removal

from Apple's supply chain.

Accountability

Compliance is an ongoing responsibility. Passing an assessment does not remove the supplier's obligation to maintain controls

and continuously improve performance.

APPLE

7. Responsible Recruitment and Worker Welfare

Worker dignity is central to Apple's supply-chain requirements, particularly for migrant and contract workers who may face

elevated recruitment risks.

Zero-fees principle

Apple's public supply-chain materials state that workers should not have to pay to secure a job. Suppliers are required to

maintain responsible recruitment practices and address prohibited recruitment fees when identified.

Worker documentation

Workers should retain control of their personal identity documents except where limited, lawful practices apply. Suppliers must

not use document retention or other practices to restrict workers' freedom of movement or ability to leave employment.

Freedom from retaliation

Workers must be able to raise concerns about working conditions without intimidation or retaliation. Apple publicly states that

supplier retaliation against employees for raising concerns can result in serious consequences.

Worker engagement

Apple uses worker interviews, anonymous surveys and direct feedback to understand workplace experiences and identify

opportunities for improvement.

APPLE

8. Responsible Materials and Supply Chain Due Diligence

Responsible sourcing requirements extend beyond a supplier's own facility to relevant materials and supply-chain

relationships.

Minerals and materials

Suppliers must conduct appropriate due diligence for relevant minerals and materials and identify risks associated with

sourcing. Apple standards reference internationally recognized due-diligence frameworks for relevant materials.

Traceability and documentation

Suppliers should maintain appropriate records identifying relevant sources, processors and other supply-chain participants

and provide information required by Apple's applicable standards.

Regulated substances

Products, accessories, packaging and manufacturing processes must comply with Apple's applicable restrictions on regulated

substances and materials.

Risk mitigation

When risks are identified, suppliers are expected to establish mitigation measures, monitor effectiveness and maintain

evidence of actions taken.

APPLE

9. Worker Rights and Workplace Standards

Suppliers are expected to respect workers and provide conditions consistent with applicable law and Apple's requirements.

Freedom of association

Suppliers must respect applicable rights concerning freedom of association and collective bargaining and must not unlawfully

interfere with workers exercising those rights.

Non-discrimination

Suppliers must provide equal opportunity and must not discriminate unlawfully in hiring, compensation, advancement,

discipline or other employment decisions.

Harassment and abuse

Suppliers must maintain a workplace free from harsh or inhumane treatment, including physical abuse, threats, sexual

harassment and other prohibited forms of harassment or intimidation.

Wages and benefits

Suppliers must provide wages and benefits that meet applicable legal requirements and communicate compensation terms

accurately to workers.

Working hours

Suppliers must manage working hours, overtime and rest periods in accordance with applicable law and Apple's supplier

requirements.

APPLE

10. Environmental and Resource Controls

Environmental performance requires operational controls, measurement and continuous improvement.

Area

Supplier responsibility

Energy

Monitor energy use and pursue efficiency and renewable-energy opportunities where applicable.

Greenhouse gases

Measure relevant emissions and implement reduction initiatives consistent with applicable Apple requirements.

Water

Manage water withdrawal, use, treatment and discharge responsibly.

Waste

Reduce waste generation and maximize appropriate reuse and recycling.

Chemicals

Inventory, store, handle and use chemicals under appropriate safety and environmental controls.

Biodiversity and land

Consider environmental risks associated with operations and sourcing and apply appropriate controls.

Continuous improvement

Suppliers should use measurement, targets, corrective actions and management review to improve environmental

performance and address identified risks.

APPLE

11. Implementation Checklist

Supplier management should use the following operational checklist to maintain readiness and demonstrate compliance.

Control

Management check

Labor

Are hiring, contracts, working hours, wages and worker treatment compliant and documented?

Recruitment

Are workers protected from recruitment fees, trafficking and coercion?

Safety

Are hazards identified, controlled, documented and communicated to workers?

Environment

Are emissions, waste, water, chemicals and permits appropriately managed?

Ethics

Are anti-bribery, conflicts, gifts and recordkeeping controls operating effectively?

Responsible sourcing

Are relevant materials and minerals subject to appropriate due diligence?

Worker voice

Can workers raise concerns safely and confidentially without retaliation?

Records

Are required records accurate, complete, accessible and protected from falsification?

Corrective action

Are findings assigned, remediated and verified on time?

Management responsibility

Supplier leadership is responsible for establishing effective controls, assigning accountable owners, providing resources and

ensuring that corrective actions are completed and sustained.

APPLE

12. Code of Conduct Principles at a Glance

Apple's supplier requirements bring together labor and human rights, health and safety, environmental responsibility, ethics,

responsible sourcing and management systems.

Principle

Expected outcome

Labor & Human Rights

Workers are treated with dignity, employment is freely chosen and fundamental rights are respected.

Health & Safety

Workplaces are safe, hazards are controlled and workers receive appropriate training and protection.

Environment

Operations manage environmental impacts and pursue measurable improvement.

Ethics

Business is conducted honestly, transparently and without corruption.

Responsible Sourcing

Relevant materials are sourced with appropriate due diligence and risk controls.

Management Systems

Policies, training, records, worker feedback and corrective-action systems support ongoing compliance.

Supplier commitment

Suppliers are expected to understand these requirements, communicate them to relevant personnel and maintain systems that

support compliance throughout their operations and applicable supply chains.

High standards at every step

The Supplier Code of Conduct establishes requirements intended to protect people, support responsible business conduct and

reduce environmental impacts throughout Apple's global supply chain.

Apple Supplier Code of Conduct Handbook

Prompt to Clone This Apple Supplier Code of Conduct Handbook

Apply this example's core structure, strategic pacing, and structural hierarchy directly to your own topic.

What are you generating today?