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Pegatron

Pegatron Corporation is a Taiwanese specializing in and services, encompassing original equipment manufacturing (OEM) and original design manufacturing (ODM) for computing, communications, and consumer electronic products. Founded on January 1, 2008, as a from ASUSTeK Computer Inc. through a corporate restructuring that separated branded operations from , the company is headquartered in and maintains production facilities across , , and the . Its product portfolio includes notebook and desktop computers, motherboards, smartphones, game consoles, and smart home devices, serving major clients in the technology sector. Pegatron has encountered notable controversies, particularly regarding labor practices at its factories, where investigations revealed misuse of student interns for work, falsified records, and excessive overtime in violation of supplier codes, leading Apple to suspend new business with the firm in .

Founding and Early History

Spin-off from Asus and Initial Operations (2007-2010)

Pegatron Corporation was established on June 27, 2007, as part of ASUSTeK Computer's restructuring to separate its original design manufacturing (ODM) operations from its consumer branding activities, aiming to improve operational efficiency and client trust in its contract manufacturing capabilities. The new entity assumed ASUSTeK's ODM system business, focusing on the production of computing hardware such as notebook computers, desktop PCs, and motherboards, while a separate spin-off, Unihan Technology, handled chassis and non-PC components. This division allowed Pegatron to specialize in electronics manufacturing services (EMS) and original equipment manufacturing (OEM), leveraging inherited design expertise from ASUSTeK to serve initial clients including the parent company itself. From 2008 onward, Pegatron commenced independent operations, emphasizing vertically integrated manufacturing for PC-related products and expanding its OEM/ODM portfolio to compete with established players like and . The company maintained facilities primarily in , with early efforts centered on cost-efficient production and design services derived from ASUSTeK's legacy teams. By late , ASUSTeK's board approved a full of Pegatron's and (GPU) divisions, reducing its stake through an 85% share issuance adjustment to facilitate independent growth. In January 2010, Pegatron merged with its Pegatron International Investment Co., Ltd., to streamline resources ahead of its public listing. The company achieved its on the on June 24, 2010, marking the completion of the process. During this period, Pegatron received recognition for design innovation, including the 2010 iF Communication Design Gold Award and red dot Communication Design Award, underscoring its early focus on product development alongside manufacturing. Operations remained concentrated on high-volume assembly for , with an emphasis on building client relationships in the competitive ODM market.

Growth in Electronics Manufacturing (2011-2015)

During 2011, Pegatron secured initial contracts to assemble Apple units, targeting production of approximately one in seven devices and raising estimates for CDMA output to 12-15 million units for the year. This marked Pegatron's entry into high-volume manufacturing, complementing its existing focus on , motherboards, and communications equipment. Quarterly revenues reflected ramp-up, with Q3 reaching NT$156 billion and Q4 NT$154 billion, contributing to annual consolidated revenue of approximately NT$500 billion. Revenue surged 47% to NT$881.9 billion in 2012, driven by expanded Apple partnerships including assembly and sustained production. Pegatron's design and manufacturing services (DMS) segment grew through improved product mix and in . Facility expansions in , particularly and , supported increased output, with workforce scaling to handle rising orders. By mid-decade, these sites became key for Apple supply, though reports noted operational challenges like labor-intensive assembly lines. In 2013, Pegatron was selected as primary assembler for Apple's lower-cost iPhone model, further diversifying from and boosting smartphone revenue share. Annual revenue rose 7.8% to $949.75 billion, with Q4 DMS revenue at $242 billion. Expansion continued with capital investments in operations, employing over 70,000 workers by year-end to meet demand for iPhones and related components. By 2014-2015, Pegatron's electronics manufacturing scaled amid series production, with facilities outputting millions of units including . Consolidated 2015 revenue hit NT$1,213.7 billion, up from prior years via enhanced efficiency and client diversification beyond Apple into automotive and communications. Growth was attributed to operational improvements and facility optimizations in , solidifying Pegatron's position as a top (ODM).

Corporate Structure and Global Operations

Business Segments and Key Facilities

Pegatron operates in three primary business segments: computing, communications, and consumer electronics. The computing segment encompasses the design, manufacturing, and assembly of notebook PCs, desktop PCs, motherboards, and servers, serving original equipment manufacturers (OEMs) and original design manufacturers (ODMs) with a focus on high-volume production. The communications segment includes smartphones, cable modems, set-top boxes, and 5G-related infrastructure components, driven by demand for wireless devices and network equipment. The consumer electronics segment covers gaming consoles, smart home devices, and other multimedia products, with recent expansions into automotive electronics and AI-enabled hardware to diversify beyond traditional markets. These segments collectively account for Pegatron's revenue, with communications often contributing the largest share due to partnerships with major smartphone vendors, though computing and consumer areas have shown variable growth influenced by seasonal demand and product mix shifts. Key facilities are distributed globally to optimize supply chains, mitigate geopolitical risks, and serve regional markets. Headquarters and primary R&D operations are based in , , overseeing design and strategic functions. In , major plants operate in , , , and , handling high-volume assembly for electronics and communications products, though these sites have faced scrutiny over labor practices and U.S. tariffs prompting diversification. European production centers in , , focus on and for the EMEA , benefiting from proximity to clients and skilled labor. In , facilities in support automotive and assembly, aligning with nearshoring trends to reduce dependency on Asian supply chains. Additional sites include , , where a new AI- and 5G-enabled smart factory was inaugurated on April 29, 2025, emphasizing advanced for Southeast Asian markets; , , for mobile and production; and for emerging capacity expansions. Service and distribution centers in the United States and handle repairs, , and . This network enables Pegatron to produce over 100 million units annually across segments while adapting to trade policies and technological shifts.

Subsidiaries and Strategic Acquisitions

Pegatron Corporation consolidates operations through a diverse array of subsidiaries spanning , investment, and specialized components, as detailed in its financial reports. Major subsidiaries include ASRock Inc., which focuses on motherboards, graphics cards, and server solutions; Casetek Holdings Limited, a Cayman Islands-based entity specializing in metal and precision components with 100% ownership; and Pegavision Corporation, engaged in digital and technologies. Manufacturing arms such as Maintek Computer (Suzhou) Co., Ltd. and Pegaglobe (Kunshan) Co., Ltd. handle assembly and electronics production in , while international units like Pegatron Technology Vietnam Company Limited (established March 2020) and Pegatron Mexico, S.A. de C.V. support regional supply chains. Investment subsidiaries, including Pegatron Investment Co., Ltd. and ASUS Investment (both 100% owned), manage capital allocation and holdings. In January 2025, Tata Electronics acquired a 60% controlling stake in Pegatron Technology India Private Limited, Pegatron's assembly unit established in July 2020, leaving Pegatron with 40% ownership to facilitate localized amid 's electronics incentives. This divestiture reflects strategic adjustments to geopolitical and market demands, though Pegatron retains influence through minority shares and . Pegatron has pursued acquisitions to vertically integrate and counter competition from firms like Luxshare Precision. In June 2008, it acquired 100% of Unihan Corporation from ASUSTeK for chassis manufacturing expertise, merging it fully in December 2013 under Taiwan's Business Mergers and Acquisitions Act. July 2009 saw the full acquisition of Powtek (Shanghai) Ltd., enhancing power-related components. In August 2020, Pegatron absorbed Casetek Holdings in a NT$14.5 billion (US$492.8 million) cash deal at NT$87.5 per share—a 21.4% premium—via reverse triangular merger, securing 100% control to strengthen structural parts supply amid rising Chinese rivalry. May 2025 marked the purchase of HTC Corporation's Taoyuan factories for NT$6 billion (US$186 million), expanding Taiwan-based capacity for consumer electronics assembly.

Research and Development Focus

Pegatron invests significantly in to enhance its capabilities in design and manufacturing, with a primary emphasis on such as (AI), communications, , and (IoT) devices. The company's R&D efforts are structured around product development segments including computing, AI applications, communication devices, automotive systems, and smart appliances, aiming to integrate innovative solutions into client products. This focus supports Pegatron's strategy to build a robust patent portfolio through sustained innovation, as evidenced by its design and manufacturing of specialized hardware like long-range autonomous driving systems, marking Taiwan's first such achievement in this domain. In AI and high-performance computing, Pegatron's R&D initiatives include developing on-premises solutions for agentic AI, physical AI, and high-performance computing (HPC) workloads, leveraging platforms like NVIDIA's Blackwell architecture to enable enterprise deployment of advanced AI systems. The company also advances 5G technologies, particularly open radio access network (O-RAN)-compliant solutions for private networks, including radio units and user equipment designed for industrial applications, with collaborations ensuring scalable testing and production. Automotive R&D emphasizes safe autonomous driving technologies and energy-efficient electronics, aligning with broader sustainability goals by prioritizing low-power designs from the initial development phase. Pegatron demonstrates its R&D prowess through public showcases, such as at 2025, where it positioned itself as a "TECH MAKER" by highlighting -driven , innovations, and consumer devices like the PRIIö home product, underscoring cross-disciplinary applications from industrial to personal . These efforts extend to smart factories and digital resilience, integrating R&D with operational to support global demands. Strategic partnerships, including with entities like Zettabyte for data centers, further amplify Pegatron's innovation in high-density and ecosystem integration. Overall, Pegatron's R&D allocation prioritizes competitive differentiation in , , and sustainable hardware, driving long-term advancements in electronics manufacturing.

Products, Services, and Innovations

Major Product Lines and Client Partnerships

Pegatron operates in three primary business segments: computer and communication products, , and electronic manufacturing services for components. Its computing product line includes notebook PCs, desktop PCs, all-in-one PCs, 2-in-1 devices, rugged computers, servers, and enterprise storage systems, with recent expansions into high-density GPU servers and AI server racks powered by GB200 chips delivered as early as March 2025. Communication products encompass smartphones, infrastructure such as (CPE), dongles, cameras, Open Radio Access Network (O-RAN) components including remote radio units (RRUs), distributed units (DUs), and central units (CUs), as well as disaggregated switches. Consumer electronics offerings feature game consoles, wearable devices, motherboards, and video cards, supporting integrated smart home solutions like and wireless networking. The company's client partnerships center on original design manufacturing (ODM) and original equipment manufacturing (OEM) for major technology firms, with as a cornerstone partner since 2011, handling assembly of iPhones and other devices that accounted for a substantial portion of Pegatron's output through 2025. Other key clients include , , and for personal computers, servers, and peripherals, enabling Pegatron to maintain diversified revenue streams amid supply chain shifts. Strategic alliances have grown in and , such as a January 2025 joint venture with Tata Electronics acquiring a 60% stake in Pegatron's operations to bolster and production. In infrastructure, partnerships with for purpose-built servers announced in January 2025 and Zettabyte for solutions in December 2024 position Pegatron in high-growth markets. Security-focused collaborations, like with Axiado for hardware-anchored -driven protections in GB200 and GH200 superchip servers demonstrated in November 2024, further enhance its server offerings.

Technological Advancements and Market Expansions

Pegatron has advanced its manufacturing capabilities through the integration of and , notably deploying visual agents in partnership with to simulate and optimize factory operations, achieving a 7% reduction in labor costs per and a 67% decrease in defect rates. The company developed the PEGAVERSE cloud-native platform, which facilitates Inception AI, Generative AI applications, and digital twins, built upon infrastructure, high-performance servers, and proprietary PEGAAI tools to enhance product development and . In the realm of , Pegatron established a dedicated division in 2018 to deliver Open RAN-compliant solutions, including remote radio units, , and tailored for private networks and industrial use, with demonstrations at events like the India Mobile Congress in 2025 emphasizing integration. At 2025, Pegatron independently exhibited progress in AI-driven , autonomous driving hardware design, and advanced , positioning itself as a key player in vehicle electrification and . These innovations support market expansions into high-growth sectors like servers and , where Pegatron anticipates substantial shipment increases in 2025 through enhanced production of AI-optimized modules and partnerships, such as with NXP for software-defined and Rebellions for specialized hardware. To diversify from amid geopolitical tensions, Pegatron inaugurated an - and 5G-enabled smart factory in , , in April 2025, incorporating advanced automation for regional assembly and collaboration with local telecoms like . In , Pegatron opened a Santa Clara office in June 2024 to strengthen client proximity and support server deployments, followed by board approval in March and June 2025 for a new U.S. subsidiary and manufacturing facility—likely in —for tariff-resilient production of servers and client-specified products, building on prior diversification into since 2018. This expansion aligns with broader strategies to capture demand in AI infrastructure and electric vehicles, reducing reliance on any single region while leveraging technological edges for competitive scaling.

Financial Performance and Market Position

Pegatron's revenue experienced rapid expansion following its spin-off from Asus in June 2008, driven by contracts in consumer electronics manufacturing, particularly for smartphones and computing devices. In 2009, consolidated revenue reached NT$538.1 billion, reflecting initial consolidation of operations including the acquisition of Unihan Corporation. This was followed by a slight dip to NT$530.5 billion in 2010 amid market adjustments post-IPO, with gross margins at approximately 4%. Revenue then accelerated, surging 47% to NT$599.9 billion in 2011 and NT$881.9 billion in 2012, fueled by increased production for major clients like Apple Inc. in the burgeoning smartphone sector. By the mid-2010s, revenue continued upward, hitting NT$1,019.7 billion in and NT$1,213.7 billion in 2015, marking a historic high driven by diversification into and , though profitability remained pressured by thin gross margins typical of (EMS), averaging 3.8-4.8%. Growth moderated into the late as market saturation in PCs and smartphones set in, with revenue stabilizing around NT$1.2-1.3 trillion by 2021 (NT$1,261 billion) before peaking at NT$1,318 billion in 2022 amid pandemic-related demand for devices. Net income fluctuated correspondingly, reaching NT$20.5 billion in 2021 but declining to NT$15.1 billion in 2022 due to rising costs and disruptions. From 2023 onward, trended downward amid softening global demand for , geopolitical tensions affecting supply chains, and intensified competition from peers like . In 2023, fell to NT$1,257 billion with at NT$15.7 billion; this continued into with NT$1,125 billion in (a 10.5% year-over-year decline) and of NT$16.9 billion, reflecting cost controls but persistent low margins of about 1.1%. For 2025, through September, cumulative stood at NT$797.6 billion, projecting a full-year figure below 2024 levels, with first-half net profit sharply reduced by foreign exchange losses and subdued sales in communications segments. Overall, Pegatron's profitability has been characterized by low single-digit net margins (averaging 1-2% in recent years) and vulnerability to cyclical demand, with around 7% as of mid-2025.
YearRevenue (NT$ billion)Net Income (NT$ billion)Notes
2009538.1N/APost-spin-off consolidation.
2010530.5N/ASlight decline post-IPO.
2011599.9N/A12% growth from smartphone ramp-up.
2012881.9N/A47% YoY surge.
20141,019.7N/AMilestone exceeding $1T.
20151,213.7N/AContinued expansion.
20211,26120.5Pandemic demand peak.
20221,31815.1Record revenue.
20231,25715.7Initial post-peak decline.
20241,12516.910.5% YoY revenue drop.

Competitive Landscape and Economic Impact

Pegatron competes in the electronics manufacturing services (EMS) sector against dominant players such as Hon Hai Precision Industry Co., Ltd. (Foxconn), which leads the industry with revenues exceeding $190 billion annually, while Pegatron ranks second globally among EMS providers. Other principal rivals include Wistron Corporation, Luxshare Precision Industry Co., Ltd., Jabil Inc., and Flex Ltd., all contending for high-volume contracts in smartphone assembly, computing devices, and consumer electronics, particularly from shared clients like Apple Inc. This competition is intensified by customer concentration risks, with Pegatron deriving approximately 61% of its sales from its largest client in recent years, mirroring Foxconn's heavy reliance on similar partnerships but exposing both to shifts in demand from tech giants. The broader EMS market, estimated at $597 billion in 2024, favors cost-efficient Asian manufacturers, where Pegatron differentiates through original design manufacturing (ODM) capabilities and , though it faces pressure from lower-cost entrants like Electronics and disruptions affecting profitability across the sector. Economically, Pegatron bolsters Taiwan's export-oriented economy as a key high-tech firm, posting consolidated revenues of (approximately $34.5 billion USD) in , down 10.5% from the previous year amid softening demand and inventory adjustments. Its operations sustain Taiwan's position as a global electronics hub, contributing to the island's merchandise exports—valued at over collectively for listed firms in —through facilities that emphasize precision manufacturing and innovation in semiconductors and assemblies. In the global , Pegatron's assembly of iPhones and other devices for Apple influences flows, prompting diversification into markets like via partnerships and potential U.S. facilities to mitigate risks and geopolitical tensions with , thereby enhancing resilience but also highlighting dependencies on concentrated production in . This positioning supports downstream in and wearables while exposing economies to upstream vulnerabilities, such as sourcing and labor costs in partner regions.

Corporate Social Responsibility Initiatives

Sustainability and Environmental Efforts

Pegatron maintains ISO 14001 certification and IECQ QC 080000 for hazardous substance process management across its global facilities, supporting systematic environmental risk assessment and compliance. The company has published annual sustainability reports since 2009, with the 2023 edition approved by its board of directors on August 13, 2024, outlining commitments aligned with global standards like the UN . To address greenhouse gas emissions, primarily from electricity consumption in manufacturing, Pegatron set a target for a 42% absolute reduction in Scope 1 and Scope 2 emissions by 2030 relative to a 2020 baseline, alongside a long-term goal of net-zero emissions by 2050. Measures include annual 4.2% emissions intensity reductions, energy-efficient equipment upgrades, and renewable energy procurement; in 2024, it consumed 98.6 million kWh of self-generated renewables and purchased 196.8 million kWh via certificates, achieving a 56% renewable electricity ratio. From 2009 to 2020, per-unit revenue emissions fell 33.85%, with ongoing efforts yielding about 665 tons of annual CO2e savings through efficiency gains. Waste management emphasizes source reduction, , and , with on conflict minerals to minimize environmental impacts from s. In 2025, Pegatron reduced 14,200 tonnes of carbon emissions via low-carbon initiatives and secured certification for further cuts of 15,000 tonnes over two years. Despite these steps, advocacy analyses, such as Greenpeace's 2025 assessment, ranked Pegatron last among key Apple suppliers for progress, citing 47% sourcing at 2023's end and insufficient acceleration toward supplier benchmarks like 100% renewables by 2030.

Workforce Development and Ethical Supply Chain Practices

Pegatron maintains a global workforce of approximately 56,938 employees as of December 31, 2024, with initiatives focused on enhancement through structured programs. These include orientation for new hires, core competency development, and management , alongside Individual Development Plan (IDP) participation rates of 80% in and 79% in . Average hours per employee in 2024 varied by region and gender, reaching 26.9 hours for males and 22.6 hours for females in , and 19.0 hours for males and 17.0 hours for females in . The company also conducts health promotion activities, such as 68 events in 2024 engaging 39,582 participants across regions, emphasizing occupational safety and well-being under ISO 45001:2018 certification covering 100% of employees. In , Pegatron enforces policies aligned with standards and reports 100% compliance with its zero child labor policy in 2024, alongside zero involuntary grievances and no work stoppages. is supported, with 85.9% of employees covered by group agreements, and communication channels address harassment and discrimination concerns. For ethical supply chain practices, Pegatron, a member of the Responsible Business Alliance (RBA), requires all new suppliers—numbering over 3,000 globally, with 90% in —to sign the RBA , achieving a 100% acknowledgment rate. In 2024, the company audited 118 suppliers for CSR compliance (100% completion rate) and conducted Responsible Business Alliance Validated (RBA VAP) audits on 17% of its facilities and 27% of suppliers, resolving all non-conformances through corrective actions. Supplier conferences engaged 528 participants to promote RBA standards and , while 1,668 suppliers completed responsible minerals surveys at 100% rate, excluding minerals from supply chains. Pegatron mandates ISO 14001 for suppliers and performs annual risk to enforce , environmental, and ethical standards throughout its operations.

Controversies and Responses

Allegations of Labor Violations in

In July 2013, China Labor Watch published an undercover investigation into three Pegatron factories in and —Riteng Computer () Ltd., AVY Technology Ltd., and AVX Electronics Ltd.—revealing 15 categories of labor violations, including of underage workers under 18 years old, excessive exceeding 60 hours per week without full compensation, and base wages as low as 1,700 RMB (approximately $278 USD at the time) per month that failed to meet local minimum standards without supplements. Workers reported being coerced into unpaid and facing poor conditions with up to 12 occupants per room lacking adequate or , alongside hazards such as insufficient fire escapes and chemical exposure without proper . Pegatron denied systematic underage but acknowledged isolated cases and committed to rectifying and recruitment issues following Apple's subsequent , which confirmed some breaches of its supplier code. Subsequent investigations highlighted persistent issues. A 2015 China Labor Watch report on Pegatron's facility documented 23 violations, including reliance on temporary dispatch workers comprising over 50% of the workforce—far exceeding 's legal 10% limit—and mandatory overtime that workers felt compelled to accept due to base pay insufficient for , often totaling 11-hour daily shifts six or seven days a week. In 2016, analysis of 1,261 pay stubs from the same facility showed routine overtime exceeding legal caps of 36 hours monthly, with workers averaging 70-80 hours weekly during peak production for Apple products. Apple's 2014 supplier audit corroborated breaches in working hours, dormitory standards, and juvenile worker protections at Pegatron sites, though the company emphasized corrective actions like enhanced monitoring. By 2020, Apple suspended new business allocations to Pegatron after discovering violations involving improper use of vocational student interns in its Chinese factories, leading to the dismissal of a Pegatron executive; no evidence of forced or underage labor was found in that probe, but it underscored ongoing compliance gaps. A 2023 China Labor Watch investigation at Pegatron's Kunshan factory identified continued excessive dispatch labor, forced overtime during iPhone assembly rushes, workplace bullying by supervisors, and recruitment fees charged to workers in violation of Chinese law, with base salaries remaining inadequate to cover living expenses without overtime. These reports, based on worker interviews and document reviews, indicate that while Pegatron implemented some reforms such as third-party audits, systemic pressures from high-volume production demands contributed to recurring non-compliance with both Chinese labor regulations and client codes of conduct.

Factory Incidents and Safety Concerns

In December 2011, an occurred at a Pegatron , Riteng Computer Accessory Co., in , , which was producing aluminum metal casings for Apple's 2. The blast originated in dust collection equipment handling combustible aluminum , injuring 61 workers and hospitalizing 23, though no fatalities were reported. The facility had not yet begun full production at the time, limiting broader disruptions, but the incident highlighted risks from inadequate dust management in metal polishing operations. Apple later confirmed in 2012 that the Pegatron , along with a similar one at , stemmed from ignited aluminum , prompting supplier audits on combustible dust hazards. In September 2023, a fire erupted at Pegatron's manufacturing facility in , , halting iPhone assembly operations temporarily. No injuries or significant asset damage occurred, and production resumed within days after the cause was identified as a short-circuit from an electrical switch left on post-testing. Local authorities investigated the incident, attributing it to procedural lapses rather than systemic equipment failure. These events underscore recurring safety vulnerabilities in Pegatron's high-volume electronics assembly, including risks in processes and electrical gaps in operational protocols. Independent investigations, such as those by China Labor Watch, have documented related concerns like insufficient —averaging eight hours versus China's mandated 24—and exposure to hazards without adequate protective measures, though these have not directly caused additional major incidents since 2011. Pegatron has responded by implementing enhanced dust control systems and audit compliance, but critics note that such measures often follow rather than prevent accidents in fast-paced manufacturing environments.

Company Reforms and Third-Party Audits

In response to a July 2013 Labor Watch investigation documenting 86 violations at Pegatron's facilities, including excessive exceeding 80 hours per month, recruitment fees charged to workers, and inadequate , the company collaborated with Apple to implement . These included enhanced worker —though independent evaluations found sessions abbreviated to one-third of required durations—and reductions in following a 2014 exposé, which prompted Pegatron to align more closely with 's 36-hour monthly limit. A more stringent response occurred after Apple's November 2020 discovery of Supplier breaches at Pegatron's operations, involving over 6,000 student interns compelled to perform assembly-line tasks unrelated to their vocational studies, alongside falsified age and documentation records. Apple halted new awards, placing Pegatron on pending remediation; Pegatron acknowledged the issues, augmented internal monitoring, and engaged external auditors to verify compliance restoration, enabling resumption of select contracts by mid-2021. Pegatron participates in third-party auditing frameworks, primarily through Apple's Responsible Supply Chain program, which deploys firms for semi-annual assessments of labor, , and environmental standards across supplier sites. Since 2007, Apple has executed over 15 such comprehensive audits at Pegatron facilities, covering more than 23,000 employees by 2013, with reported compliance rates for 60-hour workweek caps reaching 97% industry-wide by 2015. Pegatron's annual reports, published since 2009, affirm ongoing adherence to local labor laws and international norms, including direct contract issuance to employees and zero tolerance for forced labor, though 2023 investigations by China Labor Watch at the plant identified enduring deficiencies in wage transparency and dormitory conditions despite prior audit-mandated fixes.

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