We Are Transparency Driven

Seagate requires all key suppliers to complete the Responsible Business Alliance’s (RBA) Self-Assessment Questionnaire (SAQ) through the organization's platform. The SAQ is meant to help suppliers and manufacturers understand and discuss risks and best practices related to corporate responsibility. We review our suppliers’ SAQ scores regularly and may require a supplier to undergo a Validated Audit Process (VAP) audit.

On January 1, 2012, the California Supply Chain Transparency Act of 2010 (SB 657) came into 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. Seagate is committed to a transparent supply chain in which any customer can access information about any supplier at any time. We require suppliers to complete and submit a Conflict Minerals Reporting Template and work toward sourcing from conflict–free validated smelters and refiners. We also have suppliers review relevant Responsible Business Alliance courses.

Seagate has two types of suppliers: direct suppliers, which provide components and parts for products, and indirect suppliers, who provide products and services to support operations. We have adopted the Responsible Business Alliance (RBA) Code of Conduct as our supplier Code of Conduct, and we have established long–term, stable relationships with our top suppliers to better align goals and standards, meeting regularly to communicate our expectations and evaluate their engagement. We also require that certain service providers that bring workers onto our sites (e.g., cleaning services, canteen providers, etc.) follow Seagate’s standard operating procedures and sign our Code of Conduct.

We require all suppliers to sign our Supplier Code of Conduct, which is fully in line with the RBA code. Aligning with this industry standard eliminates confusion among suppliers about expectations around compliance. Seagate requires key suppliers to train their employees on the RBA code. All suppliers have direct and free access to a third–party online manager, which includes software that details RBA expectations and supplier reports that track progress. Seagate compliance managers also are positioned across locations. Through in–person meetings, quarterly business reviews with key suppliers, and our Supplier Day held throughout Asia, we educate suppliers on the importance of global citizenship, sustainability and compliance with the RBA and our standards. In FY2022, Seagate delivered training via seven outsourced webinar sessions and two internally sourced webinar sessions, with approximately 600 supplier participants. These webinars included topics on responsible sourcing of minerals, RBA code version 7.0, greenhouse gas management, and forced labor. The webinars included implementing the RBA Code of Conduct, and developing effective corrective action plans for actual audit findings in these topic areas. We also held a session on COVID-19 response to ensure suppliers were managing their operations in line with RBA code expectations during the pandemic. We held no face-to-face sessions, as COVID-19 restrictions impacted our annual training plans.

Such business challenges should not be disruptive to our customers and stakeholders. Accordingly, Seagate continued to mature our BCMS throughout FY2022 to manage and mitigate the various known risks and threats to our business. Our BCMS encompasses four pillars of planning—business continuity planning, incident management, crisis management, and supply chain risk management with enterprise risk management program oversight—and complies with the ISO 22301 management system. Since transitioning our business continuity planning practices to comply with the requirements of ISO 22301:2019, Seagate continues to maintain a robust BCMS. Our commitment to continuous improvement of the system is guided by a business continuity performance scorecard, which sets the program framework for our HDD and component sites, as well as design centers across the enterprise. This commitment is also shown through program expansion to include our Lyve products. Our HDD manufacturing sites in China and Thailand were audited in CY2021 and re-certified to the second edition of the ISO 22301 standard, ISO 22301:2019. In addition, in FY2022 our supply chain risk management program continued to proactively monitor supplier risk with global event monitoring and completing assessments of our critical suppliers. We continued to deploy our enterprise business continuity software, which was further enhanced in FY2022 to align with our document management practices and the requirements of ISO 22301: 2019 and remains our central repository for all business continuity documents and assessments.