On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB657) went into effect in the State of California. Aimed at eliminating slavery and human trafficking from product supply chains, this act requires retail and manufacturing companies to disclose their efforts to ensure that their supply chains are free from slavery and human trafficking.

Oracle is committed to a work environment that is free from human trafficking, forced labor and unlawful child labor. We respect and support international principles aimed at protecting and promoting human rights. These issues will not disappear in the short term and will require long term systemic changes in the laws, policies and practices of impacted countries and industries. Through our partnerships and industry collaborations, we will strive to make effective changes in labor practices.

Oracle requires its hardware supply chain suppliers to observe the law and conduct business in an ethical and responsible manner. Oracle has adopted the Electronic Industry Citizenship Coalition (EICC) Code of Conduct, which prohibits the use of forced, bonded, indentured or involuntary prison labor. In addition, Oracle is also participating in an EICC Freely Chosen Employment task force to share best practices among members and make recommendations on industry wide tools and training.

Oracle verifies, evaluates, promotes awareness about, and addresses risks associated with forced labor and human trafficking. Examples of our efforts include the following:

Evaluating and addressing supply chain risks:

• We have incorporated by reference the EICC Code of Conduct into our standard hardware supply chain supplier agreements.
• We participate in industry efforts to increase awareness of this issue and to implement EICC programs.

Auditing suppliers: Oracle audits its hardware supply chain suppliers based on the EICC Code of Conduct, and also reviews EICC audit results for these suppliers.

Supplier certification: Oracle has initiated a supplier certification process, which requires our direct hardware supply chain suppliers to certify to the best of their knowledge that the materials they incorporate into products were generated in compliance with applicable slavery and human trafficking laws.

Accountability standards: Oracle upholds accountability standards and procedures for employees and hardware supply chain suppliers who fail to meet our business conduct requirements.

Training: Oracle provides training on human trafficking and slavery issues, including but not limited to mitigating risks, to employees and managers who directly manage our hardware supply chain.