Supply Chain

California Supply Chain Transparency Act Disclosure

On 1 January 2012, the California Supply Chain Transparency Act of 2010 (SB 657) will be in effect in California. The law increases the amount and visibility of information available to consumers, from manufacturers and retailers, about efforts to address slavery and human trafficking across their supply chains.

We believe that all workers have the right to voluntary employment, a workplace free of harassment and unlawful discrimination, and to join or be represented by workers councils or labour unions in accordance with local laws. Our established policies, including our Human Rights policy and Code of Business Conduct and Ethics, communicate the Company's position and expectations for conformance to Seagate employees and other stakeholders. Employee conformance with the Seagate Code of Business Conduct and other Company policies is enforced by our global Human Resources l Coaching and Discipline Policy.

We work with a worldwide network of companies supplying products, materials and services. Seagate is committed to the tenets of the Electronic Industry Citizenship Coalition (EICC) Code of Conduct (Code) and has adopted the Code as its supplier code of conduct. Over the past five years, we have engaged with suppliers to drive responsible, sustainable business practices that align with Code standards on the avoidance of child and forced labour.

Seagate’s supply chain management framework, which follows EICC guidelines, includes:

Procurement Staff Training

• We continuously educate employees involved in Supply Chain Management about the Code, using internally developed material and an EICC course, which includes content on child and forced labour, and slavery.
• Recently, we introduced an e-learning course created by the United Nations Global Initiative to Fight Human Trafficking (UN.GIFT) and End Human Trafficking Now (EHTN!) on Human Trafficking.

Supplier Agreements

• Suppliers are required to acknowledge and operate within Code requirements, which prohibit child and forced labour.
• We require suppliers to certify compliance with Seagate’s Conflict-Free Minerals Policy, which prohibits the use of tin, tungsten, tantalum or gold from any source whose supply chain -- back to the mines of origin of the minerals used to produce these metals -- contributes to human rights abuses in the Democratic Republic of Congo or adjoining countries.

Supplier Capacity Building

Key suppliers^* have been trained by Seagate Commodity Managers in Code requirements, using internally developed materials. These Suppliers are required to use the training in their organisations to drive awareness and conformance with the Code. Completion of the training is tracked by the Compliance Manager tool.

Supplier Risk Assessments

Key suppliers^* are required to complete the EICC Self-Assessment Questionnaire, which serves as a risk-assessment tool to identify gaps in supplier programmes related to Code conformance. Follow-up action is taken with these suppliers to develop corrective action plans to address gaps.

Supplier Audits

Supplier compliance is validated periodically using the EICC’s third-party audit Validated Audit Process (VAP). These announced, prearranged audits review compliance with the Code and local regulations, and include an assessment of child and forced labour.

^* Key suppliers are defined using an internal matrix. After applying our criteria, the list includes 80% of direct suppliers by spend; suppliers contracted to provide services or material input for Seagate finished goods or services; and others who use foreign and migrant labour

Seagate Policy Statement on Conflict-Free Minerals

As part of its commitment to global social responsibility and in accordance with Section 1602 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of the 2010 United States Congress, Seagate prohibits the use in its products of tin, tungsten, tantalum or gold from any source whose supply chain, back to the mines of origin of the minerals used to produce these metals, contributes to human rights abuses in the Democratic Republic of Congo or adjoining countries.

Seagate expects its suppliers to use due diligence to implement policies and procedures throughout the supply chain that are consistent with this policy statement. Due diligence, as used in this policy, generally follows the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (available here: http://www.oecd.org/dataoecd/62/30/46740847.pdf). Seagate adopts, and incorporates into this policy, Annex II of this OECD document, which provides substantial policy detail.

Supplier Diversity

With major operations in six countries spanning North America, Asia and Europe, Seagate has great diversity among its employees worldwide, its local communities and its global customer base.

Seagate is committed to having a diverse workforce that reflects its external stakeholders. The Company is committed to providing an inclusive and supportive environment where all employees are valued and participate fully in the Seagate employment experience.

Similarly, Seagate encourages diversity in its supplier base as well. Seagate recognises the value of, and buying power generated through, minority owned businesses and firms. Diverse suppliers in the United States are welcome to participate in Seagate’s competitive bidding process, including businesses owned and operated by minorities, women, gays and lesbians, and veterans, or small businesses located in historically underutilised business areas.

Seagate contracts with diverse suppliers who qualify and compete successfully for Seagate’s business. Seagate gains access to solutions that meet its customers’ requirements and provide additional sources of high quality goods and services. Diverse suppliers are provided opportunities to grow their businesses and create jobs, which in turn strengthen the communities where Seagate operates.

Seagate also recommends that its US suppliers use a diverse supply base in their procurement process.