RESOLVED. Shareholders request the Board of Directors to report, at reasonable cost and omitting proprietary information, on the Company’s process for identifying and analyzing potential and actual human rights risks of its operations and supply chain. This report should be prepared at reasonable cost, omit proprietary information, and be made available to shareholders by December 2020.

SUPPORTING STATEMENT. In developing the report, the Company could consider:

• Human rights principles used to frame the assessment,
• Frequency of assessment,
• Methodology used to track and measure performance on forced labor risks, and
• How results of the assessment are incorporated into company policies and decision‐making.

WHEREAS, an estimated 16 million people1 are trapped in conditions of forced labor in extended private sector supply chains, generating over $150 billion in profits for illegal labor recruiters and employers through underpayment of wages.2

Migrant workers globally are prime targets for exploitation3 including discrimination, retaliation, debt bondage, illegal wage deductions, and confiscated or restricted access to personal documents that limits workers’ freedom of movement and leads to forced labor and human trafficking. The U.S. Department of Labor lists China and Malaysia as particularly at risk of forced labor in the electronics sector.4 A 2014 study by Verité found that nearly a third of migrant workers in Malaysia’s electronics sector are in situations of forced labor.

Raw materials used in electronics products – including tin, tungsten, tantalum and gold – are produced with forced labor.5

According to the UN Guiding Principles on Business and Human Rights, companies have the corporate responsibility to respect human rights within their operations and supply chains. Any company directly or indirectly employing migrant workers must carry out human rights due diligence to assess, identify, prevent and mitigate the risk to workers and to remediate resulting negative impacts. . The OECD Guidelines for Multinational Enterprises similarly state that companies should respect human rights by adopting internal policies, carrying out due diligence, and seeking to prevent, mitigate, and remediate human rights impacts linked to their business operations.6 The State of California and the United Kingdom passed laws requiring companies to report on their actions to eradicate human trafficking and slavery.

In 2018, KnowTheChain released a Benchmarking Report on Forced Labor in the ICT Sector based on data publicly available at that time; Broadcom received an overall score of only 6 out of 100 and ranked 37th out of the 40 included companies.7 The Company’s more recent disclosures8, including its compliance with relevant laws since redomiciling to the US, still fail to provide investors with enough information to evaluate how thoroughly the Company assesses and addresses these serious risks enterprise‐wide.

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1 https://www.ilo.org/wcmsp5/groups/public/‐‐‐dgreports/‐‐‐dcomm/documents/publication/wcms_575479.pdf
2 http://www.ilo.org/wcmsp5/groups/public/‐‐‐ed_norm/‐‐‐declaration/documents/publication/wcms_243391.pdf
3 https://www.ilo.org/global/topics/fair‐recruitment/lang‐‐en/index.htm
4 https://www.dol.gov/agencies/ilab/reports/child‐labor/list‐of‐goods
5 id.
6 http://www.oecd.org/daf/inv/mne/48004323.pdf
7 https://knowthechain.org/wp‐content/uploads/KTC‐ICT‐May2018‐Final.pdf
8 https://www.broadcom.com/company/citizenship/supplier‐responsibility and https://investors.broadcom.com/static‐files/3fae5e73‐6bcd‐438d‐83cc‐29d62c01830d