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On January 1, 2012, the California Transparency in Supply Chain 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 join or be represented by workers councils or labor 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 about the avoidance of child and forced labor.
Seagate’s supply chain management framework, which follows EICC guidelines, includes:
Procurement Staff Training
Supplier Capacity Building
Key suppliers* have been trained by Seagate Commodity Managers about Code requirements, using internally developed materials. These Suppliers are required to use the training in their organizations 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 programs related to Code conformance. Follow-up action is taken with these suppliers to develop corrective action plans to address gaps.
Supplier compliance is periodically validated 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 labor.
* 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 utilize foreign and migrant labor.