Compliance and Policies

Virtium engages only in good faith and fair dealing, avoids conflicts of interest, and encourages group-level problem solving when or if conflicts arise. Virtium also does not misuse confidential or proprietary information and follows careful procedures for the protection of such information and forbids the use of company assets—financial, physical or otherwise—in a manner that inures to the personal benefit of any officer or employee. Furthermore, Virtium does not engage in bribery, solicitation, collusion or other improper negotiations with any agency, regulatory, or governing body, or other branch of any domestic or foreign government, including any bureaucrat, agent, or individual a part thereof.

Virtium meets ISO-26000 Guidelines:

Human Rights and Labor Standards

It is never acceptable to engage or assist in behavior that is degrading to basic human rights, or any rights secured by law. Virtium does not condone, aid or participate in the use of illegal child labor; child abuse—physical, mental, sexual or otherwise; forced labor; harassment; or discrimination of any kind and in any form, and Virtium will not do business with any entity or individual engaging or complicit in the same. Not only are such practices against the law, but they circumvent Virtium’s commitment to conducting business ethically.

Virtium utilizes proactive procedures for insuring that each employee understands his or her rights and obligations attendant with employment; for monitoring changes in the labor law and standards; and for verifying that partners and suppliers meet and adhere to Virtium’s Partner Code of Conduct.

Customers, partners and suppliers can be confident that Virtium exceeds the international standards of conduct, including those in the U.N. Guiding Principles on Business and Human Rights, Universal Declaration of Human Rights and the International Labor Organization’s Declaration of Fundamental Principles and Rights at Work, and complies with applicable U.S. Federal and California State laws including but not limited to the California Occupational Safety and Health Act1, the Fair Labor Standards Act2, and the Family and Medical Leave Act3.

Quality Policy

Virtium LLC is committed to providing quality products that meet and exceed internal and external customer requirements through a process of continually improving the effectiveness of the quality management system.

Virtium’s worldwide facilities are certified to the latest ISO-9001 / AS9100 Rev D and ISO-14001 quality standards.

Environmental Policy

Virtium LLC is committed to providing an environmentally responsible culture and product portfolio that exceeds industry legal and ethical requirements to protect the environment. Virtium’s management team demonstrates environmental leadership through consideration and commitment to the following:

• Conduct business in a responsible manner, designed to protect the environment, prevent pollution and protect the health and safety of our employees, our customers, and the public.
• Assess, plan, construct, and operate facilities in compliance with all applicable legislation, regulations, and to all industrial codes of practice or programs to which the company subscribes.
• Set environmental objectives and targets to continually improve environmental performance and provide the management commitment and resources necessary to achieve the stated objectives.
• Strive for the eventual elimination of any persistent toxic emissions from our operations.
• Promote use of new technologies aimed at conserving, recycling, and renewing the resources that we use in our facilities.
• Implement programs and procedures to minimize the consequences of emergency events by ensuring prompt and effective response.
• Report regularly to our management team on our environmental status and perform audits to ensure conformance with our policies and guidelines.

Conflict Minerals Sourcing Policy

“Conflict minerals” originating from Democratic Republic of the Congo (DRC) are sometimes mined and sold by armed groups to “finance conflict characterized by extreme levels of violence”. Some of these minerals and the metals created from them (such as tantalum, tin, tungsten and gold) can make their way into the supply chains of the products used around the world, including those in the electronics industry.

Virtium is committed to sourcing components and materials from companies that share our values around human rights, ethics and environmental responsibility.

Virtium expects its suppliers to commit to the EICC Code of Conduct which includes a provision related to the responsible sourcing of minerals. Pursuant to that Code of Conduct, suppliers must have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture are DRC conflict free.

Virtium expects suppliers to establish their own due diligence program to ensure conflict-free supply chains. Suppliers must ensure that all parts used to manufacture products supplied to Virtium originated from certified conflict-free smelters validated as compliant to the EICC Conflict Free Smelter (CFS) protocol, using the CFS Compliant Smelter List.

RoHS, WEEE and REACH Compliance

Virtium manufactures halogen-free and lead-free memory module and solid state storage products in compliance with the European Union’s Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) directive, which bans the use of cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants. Virtium also meets all WEEE (Waste Electrical and Electronic Equipment) directive requirements as well as the new European REACH (Registration, Evaluation, Authorization and Restriction of Chemical substances) regulatory requirements.