Key Elements:

• Procurement Values and Ethical Dealings
• Conflicts of Interest and Business Integrity
• Supply Chain Security
• Human Rights
• Responsible Business Alliance
• Employment Agencies
• Climate Change
• Environmental Aspects
• Responsible Sourcing of Raw Materials
• Non-Discrimination and Non-Retaliation
• Supplier Diversity
• Sustainability Reports, Assessments and Product Certifications
• Supply Chain Due Diligence
• Reporting Questions or Concerns

We expect our suppliers to meet the highest standards of responsible and ethical conduct regarding how they treat their workers and the environment, and how they do business. This expectation is supported by contractual requirements.

Lenovo’s standard purchase order (PO), PO Terms and Conditions, and contracts stipulate supplier compliance with our comprehensive Supplier Code of Conduct. This code upholds our values and includes provisions that prohibit human trafficking, discrimination, retaliation to worker complaints, bribery, and corruption. It also requires our suppliers to have formal grievance mechanisms in place. We will assess conformance to these requirements in making procurement decisions.

Lenovo works with the electronics industry on supply chain issues through our Responsible Business Alliance (RBA) (formerly the Electronics Industry Citizenship Coalition (EICC)) membership. Lenovo contractually applies the RBA Code of Conduct and associated audit requirements.

Lenovo requires suppliers to adhere to the RBA Code of Conduct. Regardless of their RBA self-assessment risk level, Lenovo requires 95 percent of suppliers by spend to conduct an RBA audit (including both Validated Audit Program (VAP) and equivalent independent, third-party audit (non-VAP audit) by RBA-approved auditors) every two years. Lenovo started an effort to require its suppliers to commit to achieving RBA VAP) Recognition and Factory of Choice (FOC) designations to demonstrate leadership in ESG since FY 2020/21. This requires significantly higher VAP audit scores with all Priority findings closed, site personnel to be formally trained on the RBA VAP process, and proof of functional grievance systems.

The table below provides an overview of Lenovo’s suppliers’ annual RBA audit performance.

Supplier RBA assessments historical average scores¹

1. Scores are based on calendar year.
2. The average number of findings is calculated based on the total number of findings and total number of reports per calendar year.

In FY 2024/25, there were no violations reported related to forced labor or child labor by Lenovo’s suppliers who completed the RBA VAP assessments. The most common supplier assessment findings were related to industry-wide problems of excessive working hours and insufficient time off for their employees. To address this, Lenovo requires its outsourced manufacturers to report their employees’ working hours, time off performance, and the number of vulnerable workers monthly via an online tool so that it can take action to resolve identified issues. Agreements for improvement were reached with suppliers, as a result, no relationships were terminated due to aforementioned labor findings. Lenovo follows applicable policies and complies with relevant laws and regulations relating to working hours and rest periods.

Lenovo is committed to eradicating forced labor in all its forms including slavery and human trafficking at every stage of business operations. It holds a firm position that there is zero tolerance for forced labor and any documented instances will be met with immediate action, including discontinuing the business relationship with any suppliers that overlook this practice. To better detect and mitigate the forced labor risks, Lenovo adopts and implements preventive measures, including:

• Engaged employment agencies as needed to submit RBA indirect Self-Assessment Questionnaires (SAQ)^
• Implemented a third-party ESG risk assessment tool (EcoVadis) to screen suppliers throughout the supply chain
• Provided training to buyers on preventing and mitigating forced labor, and potential red flags related to forced labor
• Provided training to suppliers on the topic of Labor Compliance Management
• Invested in a third-party supply chain risk management platform (Everstream Analytics)
• Conducted verification through RBA assessments and participated in regular RBA Responsible Labor Initiative

* RBA indirect SAQs are for service providers that are not directly involved in the manufacturing of an end product. In FY 2024/25, no violations related to forced labor were reported by Lenovo’s suppliers who completed the RBA VAP assessments.

Currently, we ask our suppliers to report their environmental impact data (GHG emissions, water, waste, renewable energy) formally via the RBA or the CDP reporting methodologies in addition to responding to the Institute of Public and Environmental Affairs (IPE).

The FY 2024/25 Program performance as below:

• Lenovo is engaging and incentivizing its suppliers to also commit to the Science-Based Target initiative (SBTi).
• During the reporting period, 51 percent of its suppliers by spend have committed to set or have set SBTs. It is the Lenovo’s goal to achieve 95 percent of suppliers by procurement spend to implement SBTs.

• During the last data collection period, 86 percent of procurement spend was with suppliers with quantified water reduction goals.
• Water risks within Lenovo’s operational footprint and supply chain are assessed annually using publicly available water risk tools (World Resources Institute’s Aqueduct and WWF’s Water Risk Filter Tool).

• The 2024 Sedex Supply Chain Awards were announced in August at the 2024 Sedex Sustainable and Responsible Supply Chain Conference. Lenovo won the Excellence Award and was also nominated for the Driving Changes Award. The Sedex Supply Chain Awards annually recognize businesses for their efforts to drive social and environmental sustainability in global supply chains. Lenovo stood out from more than three hundred companies to receive the Excellence Award, demonstrating its commitment to and leadership in sustainability and ethical practices within its supply chain.
• In April 2024, CDP’s annual report titled “Chinese Companies’ 2023 CDP Disclosure Report” included an analysis of corporate participation in CDP Disclosure, key findings on responses from Chinese companies to CDP questionnaires, and corporate case studies. Lenovo was selected as one of three companies whose climate-related efforts were recognized. Lenovo’s initiatives were discussed as an example of how strong governance, implementing a climate strategy, climate target setting, and seizing climate-related opportunities may strengthen a company’s supply chain ESG management. Lenovo’s collaborative efforts were also discussed including promoting carbon reduction practices among suppliers to help build a low carbon supply chain. Inclusion in this report as a corporate case study is a testament to Lenovo’s performance in supply chain ESG management.

Lenovo is committed to ensuring that minerals used to manufacture products do not contribute to human rights abuse and environmental degradation, and requires its production procurement and ODM suppliers to do the same. Lenovo supports the efforts of the RBA Responsible Minerals Initiative (RMI) to address materials beyond the conflict minerals of tin, tantalum, tungsten and gold (3TG). In FY 2024/25, Lenovo conducted extensive due diligence for its supply chain using the RMI program’s Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) and the RMI Responsible Minerals Assurance Process (RMAP). Lenovo will coordinate with the RMI as RMI performs risk profiles on other materials, assess the content in its products, and further develop due diligence efforts to mitigate supply chain risk. For more information, please visit the Lenovo Responsible Sourcing webpage.

In FY 2024/25, Lenovo continued to expand the scope of ESG assessments from key Tier 1 suppliers to strategic Tier N and non-production procurement suppliers with the EcoVadis platform. The EcoVadis platform aims to enable a large base of suppliers to assess and manage ESG risks. Lenovo has implemented the EcoVadis IQ tool to screen suppliers’ overall ESG risk, based on their inherent sustainability risks and procurement information. In FY 2024/25, over 2,300 production and non-production procurement suppliers were processed through the EcoVadis IQ tool, those assessed as high risk are further screened to help Lenovo ESG team decide whether the suppliers need to be invited to conduct an EcoVadis ESG assessment.                
Lenovo continues to ensure that all strategically important suppliers participate in the EcoVadis ESG assessment and achieve at least 45 of 100 points or a comparable audit result. Suppliers scoring less than 45 must implement a CAP and the findings are expected to be closed within 90 days. Suppliers can leverage EcoVadis online training resources to facilitate better understanding of the assessment process and improvement areas that they can prioritize.                
The 360 Watch feature of the EcoVadis platform is another monitoring measure taken to minimize the risk of child and forced labor, and other ESG risks. Negative media coverage in these areas related to a supplier will be highlighted to Lenovo’s management, requiring the supplier to respond within one week and develop a CAP. The 360 Watch, in addition to other indicators, enables Lenovo to monitor and assess its suppliers on a timely basis across a range of ESG focus areas, helping it to continually improve the supply base.                

The following are Lenovo’s practices for supplier ESG performance evaluation: Suppliers are evaluated based on key indicators across RBA, environmental impact, responsible sourcing of raw materials, sustainability reporting, EcoVadis, and other ESG factors. Leveraging an advanced ESG digital platform, Lenovo has increased the visibility of ESG performance. Suppliers representing 99 percent of production procurement spending have been monitored. Lenovo is committed to expanding the coverage. This digital platform automatically sends ESG questionnaires to Lenovo’s suppliers each quarter, requesting them to report on their latest sustainability initiatives. Upon receiving the completed questionnaires, the platform automatically calculates ESG scores based on preset scoring criteria, reflecting each supplier’s ESG performance quarterly. This innovative approach not only streamlines the process of monitoring and evaluating Lenovo’s suppliers’ commitment to ESG standards but also promotes continuous improvement by providing timely feedback.
The ESG score is then applied as an overall penalty or credit multiplier across approximately 200 suppliers’ quarterly comprehensive performance evaluation report cards that consider factors beyond ESG.

• Lenovo has an enhanced ESG digital platform with a supplier training module. This module offers a comprehensive suite of ESG training courses, ranging from detailed explanations of its ESG project requirements to sessions on the latest developments and best practices in ESG-related issues.
• Lenovo provides semi-annual communications on topics including the RBA, environmental impact, Responsible Sourcing of Raw Materials, forced labor, key ISO certifications, ESG reporting, and Supplier Code of Conduct expectations.
• Lenovo created and promoted education material on its ESG requirements to approximately 1,200 suppliers at the 2024 Lenovo Supplier Standards and Certification Conference.
• In FY 2024/25, Lenovo GSC ESG team successfully held the 2024 Lenovo Supplier ESG Day online event. The event introduced Lenovo’s supply chain ESG Programs and new initiatives, and also shared best practice in supply chain carbon reduction and climate action
• In FY 2024/25, an onsite workshop was held in Shenzhen, China, focusing on Labor Compliance and Carbon Reduction.

Three suppliers, Acbel, Bison and Simplo received the ESG Award at the 2025 Supplier Conference in recognition of their outstanding ESG performance and support for Lenovo Procurement ESG Initiatives.