To ensure compliance with the high ethical standards we have set for our business, we have developed a number of policies that we expect our employees, partners, suppliers and others doing business with us to adopt or adhere to. The framework for these policies is established by our Code of Business Conduct, which is our guide to understanding how our core values are translated into consistent actions worldwide.
Our Code of Business Conduct
One of our most valuable assets is our integrity. Protecting this asset is the job of everyone at Cambium Networks. To that end, we have established a Code of Business Conduct and Ethics as our guide to understanding how our core values are translated into consistent actions worldwide. We believe that every organization should have a set of basic principles — a “code of conduct” — by which it conducts its business. Our Code provides guidelines for legal, regulatory, and ethical compliance and sets out our high standards of integrity. This Code is neither a comprehensive resource nor a substitute for sound judgment; it is a summary of standards intended to drive integrity throughout Cambium Networks.
Our Code of Business Conduct can be found here.
Our supplier Code of Conduct can be found here.
Our Anti-Bribery Policies
All of our employees, partners and suppliers are expected to conduct themselves with honesty, fairness and high ethical standards, and to abide by all applicable anti-corruption and anti-bribery laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other similar anti-corruption laws around the world. Consistent with these laws around the world, we do not promise, offer, give or authorize, directly or indirectly, a bribe or anything of value to anyone, and do not allow any of our partners to promise, offer, or give such a bribe or anything of value to anyone, in order to attempt to improperly influence any act or decision to obtain or retain business, or to secure any improper advantage for us. We have established our anti-corruption and anti-bribery policies, including our entertainment and gift policies, to govern the behavior of our employees and others acting on our behalf, and to provide guidance to ensure that our conduct always remains ethical.
Our Commitment to Anti-Boycott Principles
The United States has a policy of opposing restrictive trade practices or boycotts fostered or imposed by foreign countries against other countries friendly to the U.S. The anti-boycott laws were adopted to encourage, and in specified cases, require U.S. firms to refuse to participate in foreign boycotts that the U.S. does not sanction. Cambium Networks complies with US anti-boycott laws and we do not participate in foreign boycotts that are not sanctioned by the U.S.
Our Statement on Modern Slavery
At Cambium Network, we are committed to upholding fundamental human rights and believe that all human beings around the world should be treated with dignity, fairness, and respect. We will only engage suppliers and direct contractors who demonstrate a serious commitment to the health and safety of their workers, and who operate in compliance with human rights laws. Cambium does not use or condone the use of slave labor or human trafficking, and denounces any degrading treatment of individuals or unsafe working conditions.
At Cambium Networks, we always act with integrity – taking responsibility for our work, caring for our people and staying focused on safety and sustainability. We make investments in our clients, people and communities, so we can grow together. Guided by these values, this statement sets out the steps taken by Cambium Networks Ltd to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
This statement is made in connection with our 2024 financial year, ending December 31, 2024.
Our Corporate Structure and Business Operations
Cambium Networks is a global technology company that designs, develops, and manufactures fixed wireless and PON/XGSPON based broadband, Wi-Fi, and local area networking (LAN) switching infrastructure, and security gateway solutions for a wide range of applications, including broadband access, wireless backhaul, Internet of Things (IoT), public safety communications, and Wi-Fi access for commercial use cases.
Cambium’s products simplify and automate the design, deployment, optimization, and management of broadband and Wi-Fi access networks through intelligent automation. Cambium enables service providers, enterprises, industrial organizations, and governments to deliver exceptional digital experiences, and device connectivity, with compelling economics. The Company’s ONE Network platform simplifies management of Cambium’s wired and wireless broadband and network edge technologies. As a result, the Company’s customers can focus more resources on managing their business rather than the network.
Cambium Networks Corporation, organized under the laws of the Cayman Islands, is a holding company whose principal operating entities are Cambium Networks, Ltd. (UK), Cambium Networks, Inc. (USA), and Cambium Networks Private Limited (India). Its operations are conducted predominantly through its U.K. subsidiary Cambium Networks, Ltd., a corporation organized under the laws of England and Wales, with offices in Devon, England, together with its subsidiaries Cambium Networks, Inc., a Delaware corporation with its registered offices in Rolling Meadows, Illinois, and Cambium Networks Private Ltd., a corporation organized under the laws of India with offices in Bangalore, India. Cambium Networks operates research and development centers in the United States in Illinois and California, in Ashburton, England, and in Bangalore, India. As of June 30, 2025, we had approximately 480 full-time employees, of whom approximately 145 are located in the United States and 330 are located outside the United States, including XXX sales personnel operating in over 20 countries.
Our product lines fall into three broad, interrelated categories: Fixed Wireless and fiber Broadband (FWB), Enterprise Networking, and Subscription and Services. The FWB portfolio spans point-to-point (PTP) and point-to-multi-point (PMP) architectures over multiple standards and frequency bands, including licensed, unlicensed, and lightly licensed spectrum, and fiber products. During 2024, both our ePMP 4600 and PMP 450v platforms received FCC approval to operate in the recently released 6 GHz band in conjunction with our approved Automated Frequency Coordination (AFC) service.
The Enterprise portfolio includes a complete range of indoor and outdoor Wi-Fi access points, indoor and hardened copper and optical based ethernet switches, and security gateway and software-defined wide area network (SD-WAN) devices. During 2024, we introduced our first Wi-Fi 7 access point, the XV7-35X, a tri-band unit, which will be complemented with a broad range of indoor and outdoor Wi-Fi 7 solutions in the coming months as the industry transition to Wi-Fi 7 occurs.
We generate a substantial majority of our sales through our global channel distribution network, including, as of December 31, 2024, approximately 160 distributors that we sell to directly, together with thousands of value added resellers and system integrators supplied by these distributors. Our channel partners provide lead generation, pre-sales support and product fulfillment, along with professional services for network design, installation, commissioning and on-going field support. Although we fulfill sales almost exclusively through our channel partners, through our global sales team we engage directly with network operators in our key vertical markets including service providers, enterprises, industrials, defense and national security, and state and local governments. Our sales team responds to bids or requests for quotes, typically in collaboration with a channel partner.
We outsource production to third-party manufacturers, which are responsible for purchasing and maintaining inventory of components and raw materials and, in certain cases, we resell third-party products on a white-label basis. The majority of our products are delivered to us at one of three distribution hubs, where we have outsourced the warehousing and delivery of our products to a third-party logistics provider and from which we manage worldwide fulfillment.
Our Policies in relation to slavery and human trafficking
We have adopted the following policies designed to ensure our commitment to fundamental human rights. Cambium Networks continues to uphold our global code of conduct and expect our suppliers, subcontractors, distributors, resellers and other channel partners, consultants, agents and other parties with whom we do business to comply with these standards, which prohibit the use of any form of child or forced labor, slavery, or human trafficking.
- Code of Business Conduct. Cambium Networks prides itself on developing and maintaining a strong reputation for innovation and integrity. There are many aspects to this effort, but our first priority is ensuring that we each adhere to the highest standards of integrity and conduct; we believe that nothing that we do is more important. Our Code of Business Conduct is an essential tool to maintaining that trust by helping to guide our actions and is our guide to how our core values are translated into consistent actions worldwide. As part of our Code of Business Conduct, we prohibit the use of slave labor and human trafficking.
- Distributor and Other Channel Contracts. Our standard contracts with our distributors and other channel partners, including the terms and conditions of access to and use of our Connected Partner program portal and the benefits provided thereon, stipulate that our business partners comply with all applicable laws, rules and regulations including those related to human trafficking and worker welfare.
- Supplier Code of Conduct. We maintain a Supplier Code of Conduct, that is included as part of our corporate supply program and contracts that we enter into with our outsourced manufacturers and other suppliers. We expect all of our suppliers to adhere to this Supplier Code of Conduct, and uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community, including temporary, migrant, student, contract, direct employees and any other type of worker, as well as to uphold the highest standard of ethics.
- Conflict Minerals Policy. Our Conflicts Minerals Policy Cambium Networks fully supports industry-wide efforts to identify, reduce and hopefully eliminate the use of conflict minerals originating from the Democratic Republic of the Congo or adjoining countries to the extent believed to be financing or benefiting groups committing human rights violations.
OUR DUE DILIGENCE PROCESSES
Supporting our Code of Business Conduct, Supplier Code of Conduct, Conflicts Minerals Policy and other company policies and procedures, we conduct ongoing due diligence of our business partners based on international indices, media searches and other indicators of supplier risk.
Identifying, assessing and Managing the risks of slavery and human trafficking [in our business and supply chains]
We outsource manufacturing of our products, predominantly to suppliers in Taiwan, Vietnam, Thailand and other locations outside of the United States. Local law in these locations may not exist or be as robust as in the United Kingdom or the United States to protect populations vulnerable to forced labor or human trafficking risks. In addition, although we outsource all of our manufacturing and do not directly procure any minerals from mines or smelters or refiners ourselves, our products include a number of minerals necessary to their operation. Some mine operations can pose serious human rights risks and other risks for the workers and communities at the beginning of the electronics supply chain.
We expect our suppliers to adhere to our policies. In addition, we undertake a variety of actions designed to address and mitigate modern slavery risks:
- We regularly conduct third-party supplier visits and inspections when confirming a new supplier and periodically thereafter in connection with quality, yield and other reviews. Suppliers must agree to comply with the Supplier Code of Conduct as well as international standards and applicable laws and regulations when they enter into corporate supply agreements or equivalent terms and conditions with us. We require suppliers to acknowledge the Supplier Code of Conduct and their adherence to its terms and conditions, including the terms relating to ethical treatment of workers. It is our intention only to do business with companies that share our values around human rights, ethics and environmental responsibility.
- We conduct due diligence into the supply of minerals used in the manufacture of our products by requiring our suppliers to report on the status of their diligence into their supply chain and their use of components and materials originating from the Democratic Republic of the Congo or adjoining countries. We require reporting on the results of this diligence in accordance with generally accepted industry standards and reporting formats.
TRAINING
We conduct web-based training for employees to emphasize the importance of acting with integrity and in line with our Code of Business Conduct, including the adherence to ethical practices that we require under the Code. Training topics include issues of anti-bribery, compliance with environment and employment laws as well as ethical and fair treatment including provisions such as equal employment, safe working conditions and commitment to fundamental human rights, all designed to reinforce respect for each other as one of our core values.
MONITORING AND MEASURING OUR PERFORMANCE
We continuously monitor our compliance programs for improvements. Were we to find non-compliance with our core values by our suppliers, partners or employees, we would require timely remediation, potentially resulting in re-evaluation and possible termination of the relationship if remediation did not occur.
This statement has been made in accordance with the reporting requirements of Section 54 of the UK Modern Slavery Act 2015 and applies to our operations of Cambium Networks Ltd. The full statement can be viewed here.
Environmental Responsibility
Cambium Networks is subject to the Restriction of Hazardous Substances (RoHS), which impacts the electronics industry and many electrical products by restricting the use of and mandating maximum levels of certain hazardous materials in the manufacture of electrical and electronic products.
RoHS compliance dovetails into WEEE by reducing the amount of hazardous chemicals used in electronics manufacture. RoHS regulates the hazardous substances used in the manufacture of electrical and electronic equipment (EEE), while WEEE regulates the disposal of this same equipment. All applicable products for the EU market must pass WEEE compliance and carry the “Wheelie Bin” mark. So manufacturers of EEE must not only follow RoHS compliance but also WEEE compliance for end-of-life.
Cambium Networks complies with the European Union Directive Waste from Electrical and Electronic Equipment. The WEEE Directive mandates the treatment, recovery and recycling of electric and electronic equipment, enabling consumers to return electronic equipment covered by the WEEE directive free of charge.
The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is a European Union regulation that addresses the production and use of chemical substances, and their potential impact on both human health and the environment. it will require all companies manufacturing or importing chemical substances into the European Union in quantities of one ton or more per year to register these substances with a new European Chemicals Agency.