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Harmonic maintains a set of policies and procedures to ensure that we are not only in compliance with local and federal laws governing business operations and supply chain management, but also taking a leadership position in global citizenship in the areas of supplier relationships, green practices—in product design, manufacturing and operations—and quality. These pages detail our efforts in these areas.
Supplier Code of Conduct, including Human Trafficking and Slavery
Harmonic is committed to responsible business practices and ensures that the conditions in the supply chain are safe, that workers are treated with dignity and respect, and the practices are environmentally friendly.
Harmonic suppliers are expected to operate in full compliance with the laws, rules, and regulations of the countries in which they operate. Additionally, the suppliers are expected to comply with the internationally recognized standards in order to advance social and environmental responsibility.
Harmonic endorses a Supplier Code of Conduct based on the guidelines set by the Electronics Industry Code of Conduct (EICC). The Harmonic Supplier Code of Conduct includes a prohibition on human trafficking and slavery outlined in the California Transparency in Supply Chains Act of 2010 or CA-SB-657.
Harmonic employees and management who are directly responsible for supply chain management are trained on the Supplier Code of Conduct and are involved in its implementation. Harmonic has defined internal accountability standards and procedures for employees, contractors and suppliers who fail to meet requirements of the Harmonic Supplier Code of Conduct.
Harmonic communicate requirements outlined in the Supplier Code of Conduct to its direct suppliers every 2 years since 2013. Harmonic also provides training material to employees, contractors & suppliers on the Harmonic Supplier Code of Conduct.
The Harmonic Supplier Code of Conduct requires direct suppliers to certify that the materials incorporated into Harmonic products comply with the laws regarding slavery and human trafficking of the countries in which they operate in.
Harmonic conducted assessments in year 2013 & 2015 of its primary suppliers to verify the actual or potential risks of slavery and human trafficking occurrences. Based on compliance score from assessment, Harmonic conducts audit & put improvement plan together with suppliers who fail to demonstrate satisfactory compliance level with Harmonic Supplier Code of Conduct. Harmonic has not yet engaged any independent third parties to verify these conclusions regarding its supply chain.
Harmonic intends to conduct the business only with those suppliers that commit to the compliance with the Harmonic Supplier Code of Conduct.
Please click on the PDF for details on the Harmonic code of conduct and ethics policy.
The electronics industry is continuing to embrace environmental initiatives that would aim to reduce and completely eliminate hazardous materials contained in electronic components and systems. As part of its commitment to comply with global environmental initiatives, Harmonic has adopted standards for hazardous materials that comply with European Union directives (RoHS and WEEE). Through Harmonic’s Green Policy, Harmonic will continue to actively work with its supply chain to ensure the ongoing compliance with EU directives as well as the procurement and utilization of reliable, environmentally responsible alternatives to hazardous substances.
Key aspects of Harmonic’s Green Policy include:
Establishment of a “Declaration for non-inclusion of hazardous materials.” This declaration would ensure that all products and materials supplied to Harmonic comply with EU directives
Provision of certificates of analysis concerning the content of the following materials in both products and the packaging materials (boxes, trays, tubes etc) that are being delivered to Harmonic:
Establishment of a monitoring program to perform sample analysis for Pb, Cd, Hg and CrVI on all products and packaging materials
All product and component part numbering to be appropriately modified to help define lead free products, their call-outs and ordering criteria
Validation that every subcontractor is registered to ISO 14001 or the equivalent, or is working to implement similar environmental concerns
Environmental Compliance Statement
Harmonic Inc. manufactures high quality and innovative IT and telecommunications equipment, video delivery infrastructure solutions and services for its customers worldwide. Harmonic is committed to providing our customers with safe and environmentally friendly products that are compliant with all relevant regulations, customer specifications, and environmental legislation, including the directives described below.
In July 2006, the European Union’s (EU) Directive (2002/95/EC) on the Restriction of the use of certain Hazardous Substances (RoHS) in Electrical and Electronic Equipment (EEE) went into effect, and in July, 2011, the European Union’s RoHS Recast Directive (2011/65/EU) also known as RoHS II entered into force.
Harmonic understands the environmental risks associated with the substances covered by the RoHS Directive and has committed to eliminating or reducing the use of these, as well as other environmentally sensitive substances in our products. Harmonic also continues to comply with the requirements under RoHS II.
For more information, please visit EU RoHS directive page at official EU website.
REACH (Registration, Evaluation, Authorization and restriction of Chemicals) (EC 1907/2006) is a European Union’s regulation on chemicals and their safe use which came into force in June, 2007.
Harmonic supports the basic aim of REACH in improving the protection of human health and environment through the better and earlier identification of intrinsic properties of chemical substances. Harmonic products are considered “articles” under REACH; therefore, we are required to provide recipients of our products with information on Substance of Very High Concern (SVHC) present in concentration above 0.1% (w/w).
Substances in our products are not intended to be released under normal or reasonably foreseeable conditions of use; therefore, the registration requirement in REACH Article 7(1) does not apply to our products.
For more information, please visit REACH regulation page at official EU website.
China’s regulation on restriction of the use of certain hazardous substances commonly (China RoHS), is applicable to all Electronic and Information Products (EIPs) and parts sold in China after March 01, 2007. China RoHS regulation restricts the use of the same six substances as the European Union’s ROHS, but has requirements for product labeling and regulated substance information disclosure.
Harmonic complies with China RoHS Phase I for labeling and information disclosure requirements and continues to monitor new developments in China RoHS Phase II towards substance restriction and certification program.
For more information, please visit China RoHS regulation page at official US export website.
Other RoHS and REACH type Regulations
Harmonic will comply with RoHS and REACH type regulations evolving in other countries, if they become relevant to our products or in markets where we sell our products.
Waste Electrical and Electronic Equipment (WEEE)
European Parliament and the Council of the European Union’s WEEE Directive (2002/96/EC) came into force on August, 2005 and, were more recently amended in July, 2012. This directive encourages the reuse, recycling, and recovery of WEEE and to improve the environmental performance of all operators involved in the life cycle of electrical and electronic equipment, especially those dealing with WEEE. Harmonic ensures that all requirements for registration, reporting, design and data tracking are complied with to meet the objectives of the WEEE directive.
The crossed-out wheeled bin symbol on a Harmonic-branded commercial product indicates that the product should not be disposed of along with municipal waste, but invites our customers to return the product to us under Harmonic’s WEEE Take-Back program for product disposal. Harmonic will pay for the costs of shipping and will provide a Certificate of Recycling or a Certificate of Destruction upon request. For more information on collection, reuse and recycling or to initiate the WEEE Take-Back process for please contact Harmonic through WEEE Take-Back Request Form
For more information, please visit WEEE directive page at official EU website.
In September 2006, the European Union’s Directive 2006/66/EC (Battery Directive) came into force with an aim to prohibit the sale of batteries and accumulators containing hazardous substances and to set rules and promote collection, treatment, recycling and disposal of waste batteries and accumulators. This directive applies to spent batteries collected together with WEEE and requires their removal and separate collection. Once removed from WEEE, spent batteries are governed by the Battery Directive. Harmonic uses lithium batteries in its products and our responsibility under the Battery Directive is taken care of under our WEEE Take-Back program.
For more information, please visit Batteries and Accumulators directive page at official EU website.
Harmonic is committed to manufacturing environmentally safe products for the community, and will make reasonable efforts and required adjustments to its practices, if necessary, to comply with various environmental directives and industry initiatives on the elimination of hazardous substances, labeling, marking, certification and registration as required in markets where we sell our products.
Click here to download Harmonic’s Environmental Compliance Statement.
WEEE Take-Back Request Program
In order to assist EU member states to preserve, protect and improve the quality of the environment, protect human health and utilize natural resources prudently and rationally, Harmonic strives to recycle in compliance with the WEEE Directive any of its products that cannot be re-used.
Harmonic’s customers should:
Not discard equipment in household or office garbage
Arrange proper recycling of unneeded equipment. For the take-back of Harmonic equipment, customers must:
Collect the information required to complete Harmonic’s WEEE Take-Back Request form
Complete and submit the online WEEE Take-Back Request form. Please note that forms must be fully completed in order to prevent process delays
Receive instant online confirmation indicating the reference number
Receive the End of Life (EOL) asset return authorization number and instruction for EOL asset return
Not ship EOL product to Harmonic without a Harmonic-provided EOL asset return authorization number
To initiate the WEEE take-back process, please complete the form below with the requested information or contact Harmonic Technical Assistance Center (TAC) or RMA Team.
Conflict Minerals Policy Statement
Harmonic is committed to ethical sourcing of minerals used in our products and supports the objectives of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), which aims to prevent the use of conflict minerals that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) and adjoining countries.
Our direct suppliers and contract manufacturers are required to comply with Harmonic’s Supplier Code of Conduct, which includes requirements relating to conflict minerals and responsible sourcing. We educate our suppliers on these matters and steps they can take to achieve increased transparency regarding the origin of minerals contained in the products they manufacture and sell to Harmonic. We require all suppliers in our supply chain to utilize materials that originate outside of the DRC or otherwise from DRC conflict-free smelters certified by the Electronics Industry Citizenship Coalition (EICC) or to otherwise certify to us as to their conflict-free status. We conduct periodic reviews with our suppliers to ensure that they are in compliance with this policy.
Harmonic, like many companies in the electronics industry, uses components in the manufacture of our products that include some of the minerals covered under the Dodd-Frank Act. However, we do not purchase these minerals directly from smelters or mines; therefore, we must rely on the source information provided by our suppliers in the Electronics Industry Citizenship Coalition–Global e-Sustainability Initiative’s (EICC–GeSI) Conflict Free Sourcing Initiative (CFSI) survey template. We make reasonable efforts in our supply chain to identify country or mine of origin of the subject minerals we use and expect that our suppliers make similar efforts in their supply chains.
Harmonic continues to work closely with its supply chain to trace newly mined minerals back to their origin in order to ensure responsible sourcing.
If you require specific conflict mineral sourcing information for Harmonic products or require more information on our policy, please contact the Harmonic Product Compliance Team at email@example.com.
In addition to this conflict minerals policy, we have established a conflict minerals compliance program that is designed to follow the framework established by the Organization for Economic Cooperation and Development (OECD).
For additional information about our commitment to responsible sourcing and other ethical practices, see our Harmonic_Code_Business_Conduct_Ethics.
Click here to download Harmonic’s Conflict Minerals Policy Statement.
Harmonic Inc. is compliant with the ISO 9001: 2015 quality standards.
A copy of the certificate of registration by DQS Inc. may be downloaded by clicking here.
Harmonic Contract Manufacturers have very robust business systems that comply to TL9000 and ISO14001 International Standards.
Frequently Asked Questions (FAQs)
Q. What is RoHS?
A. It is an acronym for the “Restriction of the use of certain Hazardous Substances” in EEE (Electrical and Electronic Equipment) that restricts the use of six substances which exceed certain levels in EEE placed on the EU market after 1st July 2006.
Q. Which substances are restricted under RoHS?
A. Lead (Pb), Cadmium (Cd), Mercury (Hg), Hexavalent Chromium (Cr(VI+)), Polybrominated Biphenyls (PBB) and Polybrominated Diphenyl Ethers (PBDE).
Q. What category of EEE applies to Harmonic products?
A. Harmonic manufactures products under two categories:
ANSI – The American National Standards Institute
IEEE – The Institute of Electrical and Electronics Engineers
IPC – Association Connecting Electronics Industries
SMTA – The Surface Mount Technology Association
Q. What are RoHS Exemptions?
A. Exemptions are given for defined applications for which the elimination of the prohibited substance is technically or scientifically impracticable or when the available substitution produces negative benefits to the environment, health, or consumer safety.
Q. Do any of the RoHS exemptions apply to Harmonic products?
A. There are number of RoHS exemptions applicable to Harmonic products, details of which can be obtained by contacting Harmonic Compliance Team.
Q. What is REACH?
A. REACH is an acronym for “Registration, Evaluation, Authorization and Restriction of Chemicals”. It is a legislation from the EU that applies to suppliers (inside and outside EU member states) who want to sell, import and manufacture certain chemicals in EU.
Q. Do Harmonic products contain REACH SVHC?
A. To date, we have not found a single occurrence of SVHC in our product >0.1% by weight. However, for up-to-date information on specific product, we request you to contact Harmonic Compliance Team.
Q. What should I do if SVHC are present in Harmonic product?
A. If you are notified that there is a SVHC present in the product that is provided to you, you should also receive safe use instructions. Follow the safe use instructions to ensure that handling of product do not cause unnecessary harm.
Q. Where can I find more information on REACH and Substances of Very High Concern?
A. More information can be found on the website of the European Chemicals Agency (ECHA).
Q. What minerals are considered “conflict minerals”?
A. “Conflict Minerals” currently include gold, tin, tantalum and tungsten, the derivatives of cassiterite, columbite-tantalite and wolframite, respectively. These conflict minerals are referred to as “3TG”.
Q. What is section 1502 of the Dodd-Frank Act?
A. Effective July 21, 2010, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires companies regulated by Securities and Exchange Commission (SEC) to inquire into the origin of the conflict minerals in their supply chain and report on the due diligence or reasonable inquiries to determine whether conflict minerals contained in their products are sourced from the DRC (Democratic Republic of Congo) or adjoining country or if they are from recycled or scrap sources.
Q. Does the Dodd-Frank Act make it illegal to use conflict minerals if they originate in the DRC or from the other covered countries?
A. No. The Dodd-Frank Act rule relates to disclosure only, and they do not prohibit the use of conflict minerals in products at this moment.
Q. Are there any standards being developed for electronically passing this data between tools (like the IPC1752A for hazardous substance information)?
A. The EICC/GeSI template is the essential form. It provides the ability to make one declaration for an entire company, division, product, or part.
Q. What are the expected fines and penalties for non-compliance?
A. SEC files only apply for false disclosures. Customers will have various responses, the most serious of which will be the loss of business and removal from the customers approved vender/supplier list.
Q. Where can I find conflict mineral legislative information and technical guidance?
A. You can find additional information about conflict mineral legislative and technical guidance from the below sources.
Global e-Sustainability Initiative (GeSI)
Organization for Economic Co-operation and Development (OECD)
U.S. Securities and Exchange Commission (SEC)
Electronic Industry Citizenship Coalition (EICC)
Conflict Free Smelters Program
Q. Are Tin, Tantalum, Tungsten and Gold present in Harmonic products?
A. All Harmonic products contain one or more of the 3TG minerals.
Q. Does Harmonic purchase any conflict minerals directly from suppliers or refiners or smelters?
A. Harmonic does not purchase conflict minerals or their derivatives, in any form, directly from any supplier, refiner, or smelter.
Q. Has Harmonic completed a Reasonable Country of Origin Inquiry (RCOI)?
A. Harmonic Inc. has completed a RCOI for its products. This inquiry was reasonably designed and was conducted in good faith with an effort to obtain reliable representations indicating all smelter or refiner facilities at which its conflict minerals were processed and that those conflict minerals did not originate in the DRC or adjoining country or come from recycler or scrap suppliers.
Q. Who do I contact if I have additional technical questions about Harmonic’s conflict mineral issues?
A. Please contact Harmonic Compliance team for conflict minerals compliance support.
Q. What is WEEE?
A. It is an acronym for “Waste Electrical and Electronic Equipment” directive of the EU member states that imposes obligations on producers of EEE on the reuse, collection (or “take-back”), recycling, and disposal of WEEE.
Q. How does Harmonic know for which products in the EU it has “take-back” obligations?
A. In accordance with the WEEE Directive, Harmonic places a “crossed-out wheeled bin” symbol on its products that are shipped into the EU.
Q. How can a Harmonic EU customer contact Harmonic to request “take-back” of EEE?
A. Harmonic’s EU customers can complete WEEE Take-Back Request Form or can contact Harmonic through its Technical Assistance Center (TAC) via telephone or email.
Q. What quality certifications do Harmonic have?
A. Harmonic is ISO 9001:2008 certified. Please visit our “Certification” section for more details.
Q. Does Harmonic have Environmental Management System or ISO 140001 certification?
A. Harmonic products are manufactured using full turnkey Electronic Manufacturing Services (EMS). Harmonic does not manufacture any products at any of its sites. The EMS used by Harmonic are ISO 9001, ISO 4001 and OHSAS 18001 certified. Please contact Harmonic Compliance Team for more details.
Q. How can I obtain additional regulatory compliance information about Harmonic products that are not covered in FAQs?
A. Regulatory compliance information and/or documents regarding Harmonic products can be obtained by contacting Harmonic Compliance Team.
Harmonic Compliance Team can be reached at firstname.lastname@example.org
These FAQs are intended for basic informational purpose and they shall not be construed as legal advice.