As a means of verifying our suppliers and our supply chains to identify, assess and manage the risk of human trafficking and slavery, in 2017, our company began using a third-party partner to assess the sustainability initiatives of our core group of direct suppliers that provide 80-85% of the purchasing volume of the materials and parts we use directly in our products. Our partner developed a comprehensive online self-assessment that attempts to identify various sustainability risks, including a supplier’s vulnerability to slavery or human trafficking in its product supply chain. Additionally, our company requires that all new production material suppliers submit to a site audit prior to us initiating any supply relationship with the supplier. This is carried out by company employees and not by a third-party verifier. If and when our company uncovers any suppliers, including contractors, failing to meet our company standards regarding slavery and trafficking, we will provide written notice and a specified period of time for suppliers to take corrective actions, provided however, our company is not obligated, under the Business Partner Code of Conduct, to provide a cure period, and may, depending on the severity of the non-compliance, terminate the business relationship. These practices help us to identify, assess and manage risks of human trafficking and slavery in our product supply chain.
Internal company auditors conduct announced on-site visits to evaluate a new production material supplier’s compliance with company standards, including prohibitions against human trafficking and slavery in the supply chain. Announced and unannounced audits at existing supplier locations may be scheduled based upon unsatisfactory self-assessment results.
Our company Business Partner Code of Conduct necessitates that our suppliers “comply with all applicable laws, rules and legal regulations prohibiting slavery and human trafficking in its own business as well as in its supply chain…” in the countries in which they maintain business operations. We do not currently require that all suppliers certify in any written form that they comply with anti-slavery and human trafficking laws specifically. However, production material suppliers strategic to our business do sign a supply contract that includes our current company Business Partner Code of Conduct or its prior version.
Our company maintains internal accountability practices for employees or contractors that do not meet our standards regarding slavery and human trafficking. If our company uncovers any employees failing to meet our company standards, we will provide written notice and a specified cure period.
Our company does not provide employees or contractors with training on human trafficking and slavery.