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Responsible Business Policy

1. Purpose and Commitment

SawStreet, LLC (SawStreet) is a quick turn semiconductor backend service provider headquartered in Orlando, Florida. SawStreet conducts business ethically, treats its employees with dignity and respect, provides a safe and healthy workplace, and operates in an environmentally responsible manner.

SawStreet adopts the Responsible Business Alliance (RBA) Code of Conduct as the framework for its social, environmental, and ethical practices. Where this policy, the SawStreet Employee Handbook (MAN-EMP-04), and the RBA Code address the same subject, SawStreet applies the more protective standard. This policy applies to all SawStreet employees, and to temporary personnel, consultants, and contractors while performing work for SawStreet.

This policy supplements, and does not replace, the Employee Handbook. Existing handbook policies referenced below remain in force as written.

2. Labor

2.1 Freely Chosen Employment

All employment with SawStreet is voluntary. SawStreet prohibits the use of forced, bonded, indentured, or involuntary labor of any kind, and prohibits human trafficking. Employees are free to resign in accordance with the Employment Termination Policy (MAN-EMP-04). SawStreet does not hold or withhold employees' original government-issued identification, passports, or work permits; employees retain possession of their own documents. SawStreet does not charge employees recruitment fees or require monetary deposits as a condition of employment. Work eligibility is verified through the Form I-9 process (MAN-EMP-04, I-9 Immigration Reform Policy).

2.2 Young Workers

SawStreet prohibits the use of child labor. SawStreet does not employ any person under the age of 18. All hires are subject to identity and work-eligibility verification at the time of hire.

2.3 Working Hours

Working hours are recorded for all employees through the SawStreet time clock system (MAN-EMP-04, Time Tracking Policy). Except in emergencies or unusual situations, a workweek shall not exceed 60 hours including overtime, and employees shall have at least one day off in every seven-day period. Overtime for non-exempt employees is voluntary to the extent practicable, requires supervisor authorization, and is compensated in accordance with the Fair Labor Standards Act (MAN-EMP-04, Employee Classification Policy).

2.4 Freedom of Association

SawStreet respects the right of employees to form, join, or refrain from joining associations of their choosing and to bargain collectively, in accordance with applicable law. Employees may communicate openly with management regarding working conditions without fear of retaliation, consistent with the Open Door Policy and Complaint Policy (MAN-EMP-04).

3. Health and Safety

3.1 Occupational Safety

SawStreet maintains a safe and secure working environment as stated in the Safety Policy and Injury and Illness Reporting Policy (MAN-EMP-04). Hazards and potentially dangerous conditions must be corrected immediately or reported to a supervisor.

3.2 Emergency Preparedness

SawStreet maintains fire detection and suppression equipment, clearly marked exits, and posted evacuation routes at its facility. Emergency situations are assessed, and evacuation procedures are reviewed with employees. Evacuation drills are conducted and documented at least annually.

3.3 Industrial Hygiene and Chemical Safety

Chemicals in use at SawStreet, including isopropyl alcohol, acetone, and photoresist, are identified, labeled, and stored in accordance with their Safety Data Sheets (SDS). SDS are maintained and accessible to employees. Exposure is controlled through ventilation, limited quantities at point of use, and personal protective equipment appropriate to the task.

3.4 Physically Demanding Work

SawStreet identifies tasks involving manual material handling or prolonged standing and controls exposure through workstation design, task rotation, and mechanical assistance where appropriate.

3.5 Machine Safeguarding

Production equipment, including dicing saws, grinders, and pick and place systems, is operated with manufacturer-provided physical guards and interlocks in place. Guards shall not be bypassed or removed during operation. Equipment is maintained per manufacturer requirements.

3.6 Health and Safety Communication

Employees receive workplace health and safety training during onboarding and on an ongoing basis through the SawStreet learning management system. Training completion records are retained. Safety information is communicated in a language employees understand.

4. Environment

4.1 Permits and Reporting

SawStreet identifies and complies with applicable environmental permits, registrations, and reporting requirements, and monitors its waste streams against applicable local limits.

4.2 Pollution Prevention and Resource Reduction

SawStreet seeks to reduce waste generation and resource consumption at the source through process efficiency, material substitution where practical, and recycling of eligible materials.

4.3 Hazardous Substances

Hazardous materials, including solvent and photoresist waste, are identified, labeled, stored in appropriate containment, and disposed of through licensed disposal contractors. Disposal manifests are retained.

4.4 Solid Waste

SawStreet characterizes its process waste streams. Grinding and dicing slurry is laboratory tested against applicable county limits; test reports are retained. Non-hazardous solid waste is disposed of through licensed haulers.

4.5 Air Emissions

SawStreet's operations generate minimal air emissions, limited to laboratory-scale fume hood exhaust. SawStreet confirms that no air emission permit is required for its current operations and will reassess if processes change.

4.6 Materials Restrictions

As a backend services provider, SawStreet processes customer-supplied substrates and does not select product materials. SawStreet complies with customer requirements regarding restricted substances, including RoHS and REACH obligations, as they apply to materials SawStreet introduces during processing.

4.7 Water Management

Process wastewater from grinding and dicing operations is monitored against applicable county discharge limits. Monitoring records are retained.

4.8 Energy and Greenhouse Gas

SawStreet tracks facility energy consumption annually from utility records as its baseline for identifying reduction opportunities. As a single-site services provider, SawStreet's Scope 1 and Scope 2 footprint is limited; SawStreet responds to customer greenhouse gas inquiries based on utility data.

5. Ethics

SawStreet's ethics standards are established in the Code of Ethics Policy and the Improper Payments and Gifts Policy (MAN-EMP-04), which prohibit bribery, kickbacks, and improper payments and set antitrust compliance rules. The following provisions supplement those policies.

5.1 Accurate Books and Records

All SawStreet business records, including financial records, quality records, and time records, shall be accurate and complete. Falsification of records is grounds for termination (MAN-EMP-04, Standards of Conduct Policy).

5.2 Reporting Concerns; Protection of Identity

Employees may raise concerns through the Complaint Policy, the Open Door Policy, or anonymously through the confidential reporting channel designated by Human Resources. SawStreet protects the confidentiality of reporters to the extent practicable and prohibits retaliation against any person who reports a concern in good faith or cooperates in an investigation.

5.3 Responsible Sourcing of Minerals

SawStreet is a services provider and does not purchase tantalum, tin, tungsten, gold, or cobalt for incorporation into products. Where SawStreet supplies incidental materials in the course of its services, SawStreet will cooperate with customer due diligence inquiries regarding the source of such materials consistent with the OECD Due Diligence Guidance.

5.4 Privacy

SawStreet protects the personal information of employees (MAN-EMP-04, Personnel Records Policy), customers, and suppliers, and limits collection, use, and disclosure of personal information to legitimate business purposes.

6. Management System

6.1 Accountability

The President and CEO is the executive responsible for this policy and for SawStreet social, environmental, and ethical performance. Day-to-day administration is delegated to Human Resources. This policy is reviewed at least every two years and upon significant regulatory or business change.

6.2 Legal and Customer Requirements

SawStreet identifies and monitors applicable laws, regulations, and customer requirements, including through its ISO-certified quality management system, its ITAR registration processes, and customer compliance requests tracked in the SawStreet compliance database.

6.3 Risk Assessment

SawStreet assesses labor, health and safety, environmental, and ethics risks associated with its operations, using its quality management system risk practices and periodic self-assessment questionnaires as inputs.

6.4 Improvement Objectives

SawStreet establishes written objectives for social and environmental performance and reviews progress annually. Initial objectives: (1) establish the facility energy consumption baseline from utility records; (2) document and conduct the annual evacuation drill; (3) implement the anonymous reporting channel.

6.5 Communication

This policy is communicated to all employees upon adoption and during onboarding, and is available on the SawStreet intranet. Suppliers and customers may request a copy.

6.6 Assessments

SawStreet periodically evaluates its conformance to this policy through internal review, ISO audits, and customer self-assessment questionnaires, and retains submission records.

6.7 Corrective Action

Deficiencies identified through assessments, audits, or reports are corrected in a timely manner using the SawStreet corrective action process.

6.8 Supplier Responsibility

SawStreet communicates the expectations of this policy to its suppliers and subcontractors and expects them to conduct business ethically, lawfully, and consistent with the principles of the RBA Code of Conduct.

7. References

  • Responsible Business Alliance (RBA) Code of Conduct, current version
  • SawStreet Employee Handbook, MAN-EMP-04
  • SawStreet Quality Management System documentation (ISO)
  • Safety Data Sheets, waste disposal manifests, and wastewater test records
Document Control
DocumentSS-POL-011 RevisionA Effective2026-07-29
RevEffectiveDescription of Change
A 2026-07-29 Initial release under document control

This document is controlled when viewed on sawstreet.com. Printed or downloaded copies are uncontrolled.