Legal Policies and Agreements

May 8, 2025

Trend Micro Incorporated (“Trend Micro”), is committed to making its vision of upholding the human rights of all workers and treating all workers with respect and dignity both internally within Trend Micro and in its supply chain.  Our approach and strategy in relation to human rights and modern slavery are corporate wide.  The below statement sets out the steps that Trend Micro has taken and is continuing to take to ensure that child labour; forced labour; any form of modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery is a crime and a violation of fundamental human rights and encompasses slavery, servitude, human trafficking and forced labour (including child labour) all of which have in common one person depriving another of their liberty to exploit them for personal or commercial gain. Trend Micro has a zero- tolerance approach to any form of child labour; forced labour human trafficking and/or modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. We expect the same high standards from all our contractors, suppliers and other business partners expecting that our suppliers will hold their own suppliers to the same high standards also. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, contractors, external consultants, third-party representatives and business partners. Respect for all human rights across our operations, products, services and relationships is fundamental to this approach.

Trend Micro is a listed Japanese corporation and was co-founded by Steve Chang, Jenny Chang, and Eva Chen in 1988 to develop antivirus software, and is now a leader in hybrid cloud, network, and endpoint security and supplies cybersecurity products and services for hybrid cloud, endpoint and network security solutions and automated solutions for secure data sharing. Find out more at: https://www.trendmicro.com/en_gb/about.html.

Trend Micro is a global cybersecurity leader, helping to make the world safe for exchanging digital information. Trend Micro has over 7000 employees in 65 countries all utilising the worlds most advanced global threat research to provide its software, hardware and services which are fuelled by decades of security expertise, and continuous innovation. Trend Micro’s cybersecurity platform protects 500,000+ organizations and 250+ million individuals across clouds, networks, devices, and endpoints.  Trend Micro primarily supplies software, integrated software within its hardware products and services to its customers.  Trend Micro’s operations also include research and development, sales, marketing, administrative functions and customer support.

This statement was prepared by Trend Micro to show the importance of modern slavery and human trafficking protections to Trend Micro.  Trend Micro is an integrated global business and as such the core ethics, compliance, and policies stated here have been communicated and apply to all of its global entities.

The software is developed by the global R&D groups of Trend Micro with hardware manufacturing being outsourced to various manufacturing partners who procure components and assemble our hardware products based on our forecasts. Trend Micro collaborates with channel partners to fulfil product and service distribution and delivery. We rely on multiple third-party suppliers and outsourcing arrangements for the supply of goods. Trend Micro and its operating affiliated companies take steps to verify, evaluate and address risks of slavery and human trafficking in our supply chain.

We routinely undertake risk assessments of child labour; forced labour; modern slavery and human trafficking risks in our operations and supply chains to consider if we are directly or indirectly linked to child labour; forced labour; modern slavery and or human trafficking practices.  We used a number of factors to assess the potential risk in our supply chains, including geographic risks from where we source materials, products and services that we source, the sectors that we operate in and the supply chain model involved taking into account also our regulatory obligations world-wide, including but not limited to those in the United Kingdom and Australia (sec. 54 of the UK Modern Slavery Act 2015 and Modern Slavery Act 2018 (Cth) hereinafter “Modern Slavery Acts”).

In undertaking our assessment, we have reviewed our supplier engagement processes and principles; updated our due diligence processes; and begun a process of requiring key suppliers to acknowledge compliance with the Modern Slavery Acts and any other relevant legislation to support Trend Micro’s compliance initiatives.

Trend Micro is not aware of any conduct in its supply chains that would permit forced labour of any kind (including child labour) modern slavery or human trafficking. The full extent of slavery risks that exist in all supply chains and in all the supply chains of our suppliers are being investigated and will continue to be investigated over time.

Due to the nature of our business, Trend Micro deems itself to have a low risk of any kind of forced labour or modern slavery in our business and supply chain.