Responsible Sourcing

• Clarify T-Mobile’s expectations regarding responsible sourcing,

• Advance T-Mobile’s sustainability goals and commitments,

• Support T-Mobile’s internal sustainable procurement policies and procedures,

• Complement T‑Mobile’s Supplier Code of Conduct, Supplier Policies, Environmental Policy and Human Rights statement,

•  Maintain compliance with legal requirements, and 

• Guide suppliers to improve their sourcing practices and internal due diligence where necessary. 

This Policy further recognizes that certain materials, particularly ones derived from natural resources, may pose severe risks to human rights and the environment resulting from their extraction, transportation, and trade. We therefore expect our suppliers to exercise additional due diligence on the source and chain of custody of these materials and operate in a manner that:

• Protects the environment, 

• Aligns with T-Mobile’s commitment to human rights, equal opportunity, fair labor standards, and a safe and healthy workplace, and

• Includes participation in multi-stakeholder initiatives towards responsible sourcing.

This Policy applies to all suppliers of materials, components, products, or services procured by any authorized T Mobile employee, agent, or third party acting on behalf of T Mobile. Specific areas of focus include responsible sourcing of minerals, plastics, paper and packaging, and electronics, as well as climate change, water protection, and environmental, social, and ethical performance.

T-Mobile is committed to the responsible sourcing of minerals, including but not limited to minerals used in manufacturing electronic products and components. T Mobile is especially concerned about the human rights abuses and risks associated with the extraction, transportation, and trade of certain minerals from conflict-affected or high-risk areas (CAHRAs), including the Democratic Republic of the Congo (DRC) and adjoining countries. These minerals, referred to as “conflict minerals,” are defined by the U.S. Securities and Exchange Commission (SEC) as gold and columbite-tantalite (coltan), cassiterite, wolframite, and their derivatives, including tantalum, tin, and tungsten. For the purposes of this Policy, the term “conflict minerals” means tin, tantalum, tungsten, and gold, as well as any other minerals that T-Mobile may designate.

U.S. law requires companies to conduct due diligence on the source and chain of custody of conflict minerals necessary to the functionality or production of products that they manufacture or contract to manufacture. To maintain compliance with this legal requirement and support T-Mobile’s commitment to responsible sourcing, we expect and rely upon our suppliers to conduct due diligence into their supply chains and provide us with accurate and complete information regarding the source and chain of custody of the conflict minerals contained in any materials or products supplied to T Mobile.

T-Mobile is a member of the Global e-Sustainability Initiative (GeSI) and Responsible Minerals Initiative (RMI). We strongly encourage our suppliers to utilize RMI tools for ensuring responsible resource procurement.

Suppliers shall adhere to the following requirements when sourcing any conflict mineral or product or component that contains any conflict mineral:

• Source conflict minerals only from: 
  • recycled or scrap sources; or 
  • smelters or refiners that have successfully completed (or demonstrated progress toward completing) an audit by a recognized third-party verification program. 

• Conduct their own due diligence into the source and chain of custody of any conflict mineral used in any product or component supplied to T Mobile. 

• Provide full transparency of the mineral supply chain – at a minimum back to the smelter, refiner, recycler, or scrap processor -- using a robust and verifiable traceability system such as the RMI Conflict Minerals Reporting Template (CMRT). 

• Respond to T Mobile’s inquiries related to conflict minerals in a timely manner and verify the source and chain of custody of any conflict minerals used in any materials or products supplied to T Mobile, including but not limited to requests for information about: 
  • the identity of smelters, refiners, recyclers, or scrap processors; 
  • the country of origin; 
  • supplier’s due diligence and risk management procedures regarding conflict mineral sourcing and traceability of data; and 
  • T Mobile’s supplier audits and disclosure obligations, including any reports or information required by the SEC or other government agency. 

• Adopt a conflict minerals policy and supplier due diligence practices, and require the same of their suppliers, consistent with U.S. law, the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas by the Organisation for Economic Co-operation and Development (OECD), and the United Nations Guiding Principles on Business and Human Rights. 

• Develop and implement the systems and tools to comply with this Policy as quickly as possible and prior to sourcing any conflict mineral or product or component that contains any conflict mineral.
  

If not managed properly, plastics can accumulate in the environment for centuries, defragmenting into micro dimensions, causing major environmental problems and ultimately harming biodiversity and human health.

Suppliers shall:

• Reduce the volume and weight of plastic materials in products and packaging supplied to T-Mobile and incorporate more environmentally sustainable material alternatives.

•  Prioritize certified recycled content and/or salvaged material. 

• Avoid the use of Polyvinyl Chloride (PVC), Low-Density Polyethylene (LDPE), Polystyrene (PS) and Styrofoam, and any other plastics known for their harmful environmental and health impacts, toxic ingredients, and/or non-recyclability. 

• If plastic in products or packaging cannot be avoided, prioritize plastic materials that can be recycled at the end-of-life, such as Polypropylene (PP) and High-Density Polyethylene (HDPE). 

• If packaging is necessary and cannot be avoided, use fully recyclable or biodegradable packaging, and reusable packaging when practical. Mobile Wireless Suppliers are encouraged to look to the CTIA Guidelines for Device and Accessory Packaging

T-Mobile has an important role to play in the responsible sourcing of wood fiber-based products, including paper and paperboard packaging material. This Policy seeks to ensure responsible sourcing of wood fiber paper and paperboard packaging

Suppliers shall:

• Use wood fiber in the most efficient and optimal manner possible.

• Maximize the use of recycled fibers where technical specifications and availability allow for their use.

• Work with upstream suppliers to identify paper products and paperboard packaging that make the most efficient use of fiber inputs.

• Minimize the use of paper-based records.

• Participate in the Directed Paper Buy Program and either purchase from stocks selected by T Mobile that meet the requirements above or provide fully transparent reports on the paper or paperboard used.

• For non-recycled products and materials, suppliers shall ensure that all virgin wood, pulp, and fibers used in the manufacture of paper products and paperboard packaging are procured from sources that:
  • Comply with T Mobile’s Supplier Code of Conduct;
  • Comply with all applicable laws and regulations of the countries in which they operate, especially those pertaining to wood harvesting, production, and transport processes; and
  • Avoid sourcing from a region impacted or associated with human rights violations included in the World Bank’s Harmonized List of Fragile Situations.

• Also for non-recycled products and materials, suppliers shall obtain certifications from independent organizations such as the Forest Stewardship Council to ensure that all virgin wood, pulp, and fibers used in the manufacture of paper products and paperboard packaging are procured from sources that:
  • Do not engage in deforestation, defined as the conversion of natural forests to plantation or non-forest use such as agriculture or development.
  • Protect source forests that are known to contain or are suspected of containing High Conservation Values, as defined by the HCV Resource Network.
  • Respect land tenure rights and the rights of indigenous and local communities to give or withhold their free, prior, and informed consent to operations on lands to which they hold legal, communal, or customary rights. New or existing conflicts, including conflicts resulting from a lack of free, prior, and informed consent should be managed and resolved through a transparent, balanced, and accessible dispute resolution process.
  • Provide full transparency of the fiber supply chain back to the forest source, using a robust and verifiable traceability system.

Additionally, T-Mobile will show preference to suppliers who demonstrate industry leadership in the following areas:

• Mill and printer environmental performance, including but not limited to energy usage (amount and type), ink usage (amount and type), air and water emissions, bleaching processes (use of chlorine), and chemical waste disposal.

• Responsible forest management, including but not limited to good forest planning, minimization of impacts from road building and logging, protection of riparian and wetland areas, support for local communities, and responsible chemical usage.

• Inclusion and support of small landholders in the supply chain.

• Increasing energy efficiency and reducing water use.

• Carbon footprint reduction, including direct and indirect emissions.

Suppliers shall incorporate principles of design for sustainability and circularity in the design and manufacturing of electronic components and products to facilitate reusability, reparability, and recyclability. In addition, Suppliers shall avoid materials containing toxic chemicals such mercury, cadmium, brominated flame retardants, PVC, and other enlisted in the European REACH Restricted Chemical List. All applicable electronic components and products shall be accompanied with the European Restriction of Hazardous Substances (RoHS) Certificate of Compliance.

T-Mobile recognizes the urgency to act collaboratively to keep global temperature rise to 1.5°C or less. Accordingly, T-Mobile expects our Suppliers to drive positive change. T-Mobile and its Suppliers shall work collectively, in good faith, toward the goal of achieving a significant year-on-year decline in greenhouse gas emissions.

Supplier shall set and achieve science-based targets determined by the Science Based Targets initiative (SBTi):

• If Supplier has not already set science-based targets, then within ninety (90) days of the effective date of its agreement with T-Mobile, Supplier shall submit a letter to the SBTi establishing Supplier’s commitment to set science-based targets that are aligned with reduction pathways to limit global warming to 1.5°C or less. Supplier shall obtain SBTi approval of its targets and provide evidence of SBTi’s approval to T-Mobile.

• Develop and implement a plan of continuous improvement to reach the targets. 

• Consider going further and setting a net-zero target in line with a 1.5°C.

Rising water consumption, climate change, and water pollution are increasing stresses on global water quality and supply. Companies are expected to identify any commodities, materials, components, products, services, and activities that impact water quality and supply and conduct due diligence on the source, supply chain, and geographic locations. In addition, companies shall understand how they impact and depend on water and take the necessary action for sustainable water use. Suppliers are encouraged to look to the Science Based Targets Network (SBTN), Alliance for Water Stewardship, and CEO Water Mandate for guidance.

We expect our Suppliers to commit to integrating economic, social, and environmental sustainability into their operations as a way of doing business. T-Mobile intends to conduct or ask a third party to conduct an Environmental, Social, and Ethical Performance assessment (Sustainability Assessment) of the operations of major Suppliers.

Supplier shall:

• Agree to accept, pay for, and complete the Sustainability Assessment in a reasonable timeline and to collaborate with T-Mobile and/or the third party during this assessment.

• Require its suppliers to complete a Sustainability Assessment as well, in a reasonable period of time, and share results with T-Mobile.

• Require its suppliers to attest to and agree to follow T-Mobile’s Supplier Code of Conduct.

• Make good faith efforts to continuously improve its assessment results year over year.

Compliance

T-Mobile uses an industry-leading third-party scorecard system to monitor Supplier risk, performance, and compliance related to this Policy. Periodic audits and assessments will evaluate Suppliers’ policies and programs against applicable laws, regulations, industry best practices, and NGO standards. Any deficiencies identified must be corrected promptly. Any violations of this Policy may jeopardize the Supplier’s business relationship with T Mobile, including termination of that relationship.

Suppliers must notify T-Mobile Procurement about any concerns or suspected violations pertaining to this Policy.

T-Mobile employees shall notify their manager, the Compliance and Ethics Office, or the T-Mobile Integrity Line about any concerns or suspected violations of this Policy.

Questions regarding this Policy should be directed to Sustainability@T-Mobile.com.