SUPPLY CHAIN SOCIAL AND ENVIRONMENTAL RESPONSIBILITY
EMC’s Supply Chain Social & Environmental Responsibility (SER) program focuses on mitigating risk, identifying and building opportunity, and increasing the resiliency of our supply chain. We seek to achieve these objectives by collaborating with our suppliers and industry peers to create and use common standards and tools. We continually refine and improve our approach based on what we learn.
Our strategy centers on three pillars:
- Setting expectations, using the industry-standard Electronic Industry Citizenship Coalition (EICC) Code of Conduct;
- Monitoring and assessing supplier performance to that standard, using a combination of industry-standard tools and our own tools and requirements; and
- Engaging continually with our suppliers and with the industry to enable and incent improvement.
In 2015, EMC expanded our training program, increased integration into the business and continued our targeted outreach to suppliers using a multi-variable risk assessment. In 2016, we will continue to mature the programs we have in place while also beginning to integrate indirect suppliers into our Supply Chain Social & Environmental Responsibility program.
Monitoring and Assessment
- Completed 25 spot checks in 5 countries
- Saw a 55 percent reduction in the number of audit findings from initial audits to closure or full re-audits
- Received environmental reporting from suppliers representing 99 percent of spend
- Collected Conflict Minerals Reporting Templates from suppliers representing more than 98 percent of spend
Engaging to Improve
- Extended the functionality and use of our tool, built on EMC’s Archer Governance Risk and Compliance platform, to track and convey supplier performance, communicate required actions, and connect suppliers to targeted resources and information
- Added 10 new training modules in English and Chinese to our SMaRT Library, an online training resource, and translated the entire library into Spanish
- Expanded our training program, with 435 internal and supplier users completing 871 training courses
- Performed targeted risk mitigation with suppliers showing high risk factors related to water management, vulnerable workers and conflict minerals
- Engaged smelters in our supply chain to request that they become compliant with the Conflict-Free Smelter Program
MONITORING AND ASSESSMENT
EMC joined the EICC in 2008. Since then, we have collaborated with the organization on its common standards, tools and questionnaires, which we use to monitor our own suppliers. In 2015, this collaboration included continued leadership in the EICC, particularly through EMC’s lead position in the Environmental Sustainability Workgroup and participation in the Conflict-Free Sourcing Initiative. EMC also serves on the EICC Board of Directors for the 2015-2017 term.
Collaborating to Set Standards and Monitor Suppliers
In accordance with our commitment to shared standards, we use the following suite of EICC tools as the core of our supply chain responsibility monitoring and assessment activity:
- EMC Supplier (EICC) Code of Conduct: Covering labor, ethics, environment, health and safety, and management systems, the EICC Code sets our expectations for our suppliers and of EMC. Code of Conduct acknowledgements are collected from our top 99 percent spend Tier 1 and Tier 2 direct materials suppliers (in-scope suppliers), and compliance to the Code is part of our standard contract language for all vendors. We refreshed our Code acknowledgements in 2015, corresponding to the update of the EICC Code of Conduct, and received acknowledgements from 100 percent of the suppliers in scope.
- EICC Self-Assessment Questionnaire (SAQ): This risk assessment tool evaluates the presence of policies and procedures needed to support compliance with the Code of Conduct, as well as risk factors and associated controls. EMC collects SAQs from strategic Tier 1 and Tier 2 suppliers.
- EICC Environmental Reporting: This shared EICC questionnaire collects information about suppliers’ volumes, goals and initiatives for carbon, water and waste, and is aligned with CDP and Global Reporting Initiative (GRI) reporting. In 2015, we collected reporting from suppliers representing 99 percent of EMC’s total direct materials spend.
- EICC Audits: Audits evaluate conditions and practices at supplier manufacturing facilities. EMC uses EICC- Validated Audit Program (VAP) audits wherever possible. A supplier can share the results of this rigorous audit with multiple customers, thereby reducing the overall volume of audits. VAPs are conducted by third-party auditors and are valid for two years. In the rare cases where EMC does not use a VAP audit, we still follow EICC standard audit protocol and use certified third-party auditors.
- Conflict Minerals Reporting Template (CMRT): The CMRT is a widely-used standard form developed by the Conflict-Free Sourcing Initiative (CFSI) to collect due diligence information through the supply chain, including the names of smelters and refiners of tantalum, tin, tungsten and gold (3TG). EMC collects CMRTs from Tier 1 and Tier 2+ direct material suppliers whose products contain 3TG.
Reporting associated with these EICC tools is conducted through EICC-ON, the EICC’s online platform for easily and confidentially sharing data between suppliers and customers.
We complement these industry-standard tools with internally-developed assessments and requirements, including the following:
- Risk Assessment Process: EMC’s internally-developed risk analysis determines which sites we consider to be high risk. We prioritize these sites for audits and spot checks over the course of the year (see graphic "Evaluating Supplier Site Risk").
- Spot Checks: These assessments of key social and environmental indicators at supplier sites are conducted by in-region EMC supply chain technical and commercial staff. Spot checks identify and remedy small problems before they become significant issues. They also give us a view of on-the-ground conditions at suppliers we might not otherwise visit, complementing the formal auditing process. EMC staff completed 25 spot checks in 5 countries in 2015.
- Institute of Public & Environmental Affairs database: EMC regularly checks the database of pollution violations maintained by the Institute of Public & Environmental Affairs in China. Any concerns identified through its data are corrected using direct supplier discussion and Corrective Action Plans (CAPs) where relevant.
- Public Sustainability Reporting: EMC’s strategic direct materials suppliers are required to publish a sustainability report using a recognized framework such as the GRI guidelines. As of the end of 2015, 80 percent of our top 80 percent of suppliers by total direct materials spend published public sustainability reports, all of which followed the GRI guidelines. See the Engaging to Improve section below for more on this topic.
- Conflict Minerals Risk Assessment: EMC reviews suppliers’ CMRTs to assess their conflict minerals policies, smelter lists and due diligence practices. Suppliers are sent targeted communications to help them improve their due diligence practices and assigned corrective actions as needed.
Metrics and Results
We view audits as a mechanism for performing due diligence, establishing baselines of supplier site performance and evaluating the effectiveness and longevity of improvements over time. We also employ them to help raise awareness and to drive conversations and improvement. In 2015, sites undergoing full re-audits outnumbered those completing initial audits for the first time. This is a reflection of the growth of VAPs as well the evolution of EMC’s audit program.
A CAP is developed for every audit that produces findings. EMC works directly with our suppliers to understand underlying causes, review plans and evaluate evidence demonstrating completion of all corrective actions. A supplier may also undergo a closure or follow-up audit after CAP completion to validate the results of their actions.
Taken in aggregate, our suppliers show a 55 percent reduction in the number of findings from initial audits to closure audits or full re-audits. Moreover, we saw a 31 percent reduction in the total number of findings in 2015 versus 2013 when normalized for the number of full audits taking place each year, indicating that although the distribution of finding categories is fairly consistent, the volume of actual issues is declining. We have also seen significant reductions in the number of findings within most categories over the same period, such as a 28 percent reduction in the number of labor findings. Although the two years of data are not consistent with regards to the specific sites being audited and so are not perfectly comparable, the data provides a hopeful sign that audits, and our corresponding corrective actions, are driving improvement as well as enabling us to assess the social and environmental performance of our suppliers.
For more information on how we analyze different factors to identify patterns and prioritize training, incentives and any required policy changes related to supplier performance management, see the Engaging to Improve section below.
Spot checks are conducted by in-region EMC supply chain technical and commercial staff who visit supplier sites to assess a set of key social and environmental indicators. In 2015, we updated the questions to reflect the revised EICC Code as well as to include indicators of business continuity. The staff conducting these visits receive regular training to build their knowledge of the specialized issues they evaluate. In 2015, all of the employees on teams completing spot checks completed a minimum of 6 and a median of 12 online training modules on a variety of topics.
In 2015, EMC staff completed 25 spot checks in 5 countries, bringing our total to 56 sites spot checked over the last two years. The 2015 spot checks identified more than 40 issues requiring corrective action, and in one case identified concerns severe enough to immediately prioritize the site for a full audit. The issues identified in a spot check are addressed with the same expectations of corrective action closure as findings from the more comprehensive EICC-VAP audits.
Human trafficking received continued attention in 2015 from national governments, nonprofit organizations and corporations. It is a challenge that is much bigger than any single company, or even any single industry. However, as described in our Statement Against Slavery and Human Trafficking, EMC has taken multiple actions to monitor for risks of human trafficking in our supply chain, remedy any issues identified, and educate our employees and suppliers about this important subject. We will continue this focus in 2016.
In 2015, our activities included:
- Audit Corrective Actions: Through audits and on-site visits, EMC identified gaps and outdated practices in suppliers’ management systems and worked with those suppliers to implement corrective actions. For example, one supplier discovered through an audit that, while they had strong practices in place for their own workers, some of their on-site service providers were withholding passports, charging excessive fees and not issuing contracts to workers. Through the Corrective Action process, the site did extensive work with its service providers to change these practices, including instituting its own governance to ensure that the new practices would be monitored and maintained.
- Targeted Outreach: To go beyond audits and address risks more proactively, we used several indicators of forced labor risk to analyze and prioritize suppliers for targeted outreach. Based on that analysis, we reached out to the suppliers showing greatest risk to collect additional detail about their management practices and to identify gaps. Most suppliers we contacted were already in the process of adjusting their policies and procedures, particularly with respect to the new Federal Acquisition Regulation (FAR) and EICC requirements to refrain from charging workers any employer or agent recruitment fees or other related fees of their employment. In cases where their existing actions did not fully address the gaps, we worked with the supplier to put appropriate corrective actions in place.
- Internal Training: 100 percent of our supply chain commercial management team as well as the teams completing supplier spot checks completed training to help them better understand and identify risks of human trafficking. In addition, 100 percent of our teams responsible for supplier management – both commercial and technical – completed training on the EICC Code of Conduct, which includes freely chosen employment as one of its key provisions.
- Supplier Training: In partnership with two other companies and the nonprofit organization Verité, EMC hosted two in-depth human trafficking workshops in Malaysia directed at suppliers as well as their labor agents and service providers. Participants used case studies, hands-on training, and tools to draft action plans to assess and control for potential human trafficking risks. More than 60 people attended the two sessions.
As part of our global approach to the protection of human rights, EMC is committed to the ethical sourcing of minerals. In the Democratic Republic of the Congo (DRC), some mines are controlled by armed militia who use the proceeds from the sale of minerals to fund ongoing conflict in the region. EMC’s Conflict Minerals Policy states our goal to be conflict-free and our expectations of our suppliers to exercise due diligence on the source and chain of custody of the 3TG used in components or products they supply to us.
We do not purchase minerals directly from mines, smelters or refiners and therefore must collaborate with suppliers, industry peers and other stakeholders to meet our goal of being conflict-free. EMC is an active member of EICC’s Conflict-Free Sourcing Initiative (CFSI) and works to advance its Conflict-Free Smelter Program (CFSP) and other initiatives.
EMC has a three-pronged strategy which aims to:
- Engage suppliers in due diligence and conflict-free sourcing
- Increase the number of Conflict-Free smelters and refiners
- Encourage responsible sourcing from the DRC and adjoining countries (the “Covered Countries”)
Supplier requirements for conflict minerals due diligence are integrated in EMC’s supply chain business processes. Our Supplier Code of Conduct requires direct material suppliers to have a conflict minerals policy, conduct due diligence on the 3TG in their products and report the results to customers upon request. Our standard contracts and purchase agreements include the same requirements.
In 2015, EMC collected Conflict Minerals Reporting Templates from suppliers representing more than 98 percent of spend. From these CMRTs we derived a list of smelters and refiners in our supply chain. As of April 2016, 70 percent of those smelters and refiners were CFSP-compliant, including some that source responsibly from Covered Countries, and 13 percent were Active1 and preparing to become CFSP-compliant.
While collecting information, we take action to address potential risks of purchasing product materials containing minerals whose sale financed armed conflict in the DRC. In 2015, we reviewed suppliers’ CMRTs to assess their conflict minerals policies, smelter and refiner lists and due diligence practices. We also issued targeted communications to help our suppliers improve their due diligence and reporting, and contacted those whose responses indicated potential risk in order to obtain more information and request additional due diligence.
We also work to increase the number of CFSP-compliant smelters and refiners. We actively participated in a CFSI workgroup that encourages 3TG smelters to undergo CFSP audits, and contributed to the Initial Audit Fund which pays the costs of a smelter or refiner’s first CFSP audit as an incentive to participate. As the number of CFSP-compliant smelters and refiners grows, we can more effectively engage our suppliers to shift their purchasing to those smelters and refiners.
EMC also recognizes that the issue of responsible mineral sourcing extends beyond DRC Conflict-Free. In 2016, we are reviewing our due diligence program to assess how best to address other risks in our mineral supply chain. To this end, we support CFSI’s expansion of CFSP audit protocols to address risks beyond conflict in the DRC, in alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
Our most recent Conflict Minerals Report is published on EMC.com
Environmental Risk and Performance
Our 2015 data shows our suppliers’ continued commitment to environmental reporting and goal-setting. As in previous years, suppliers representing 99 percent of our total direct materials spend submitted reports. Of those suppliers, the percentage of those reporting environmental goals remained fairly consistent with 2014. However, the total number of suppliers submitting reports increased in 2015. The chart below shows both sets of data.
We also continue to regularly review and follow up with suppliers regarding issues identified in the Institute for Public & Environmental Affairs (IPE) database. We identified 5 reported violations at supplier sites in 2015. To date, all of the issues identified in the database have been satisfactorily addressed by our suppliers. We also use violations in IPE as an input into our audit planning, prioritizing sites for audit that have demonstrated previous environmental compliance concerns.
Greenhouse Gas Spotlight
The greenhouse gas emissions (GHG) associated with EMC’s direct material supply chain totaled 211,809 metric tons CO2e in 2015. This reflects Scope 1 and Scope 2 GHG emissions data reported by direct Tier 1 suppliers. Using economic allocation, we use their data to calculate our share of their GHG emissions. This involves determining the ratio of our spend to each company’s revenue and applying that ratio to their reported emissions. This methodology follows the WRI GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard and is currently the best available option given the level of data tracked and reported. Because this allocation approach requires access to supplier revenues, a small number of private companies are excluded from the analysis. The total reported metric tons of CO2e is extrapolated to provide an estimated figure for 100 percent of our direct materials supplier emissions.
While it is difficult for us to normalize the data enough to state what this means for supplier performance overall, 71 percent of suppliers reporting goals in 2015 had also demonstrated improvement against their goals within the last year. We continue to incent our suppliers to identify and meet their commitments around reduced GHG emissions through our Scorecard (see the Business Integration section below).
Over the last five years, there has been a 61 percentage point increase in the number of suppliers reporting their water use, a 22 percentage point increase in the number of suppliers who have goals to reduce their water use, and a 45 percentage point increase in the number of suppliers who treat their production wastewater according to best management practices. This is important progress. See the Targeted Supplier Outreach section below for information on our initiative to work more deeply with our suppliers on this issue.
We continued to see high percentages of waste reporting in 2015, continuing the trend since we began collecting standard waste management data from our suppliers in 2013. A total of 97 percent of those asked reported, up 4 percent from 2014 and 9 percent from 2013. The data show our suppliers’ continued commitment to recycling and reusing material, with 84 percent of non-hazardous waste by weight recycled or reused.
ENGAGING TO IMPROVE
Collaboration and continuous improvement are core to EMC’s Supply Chain SER program. In 2015, we continued our work in supplier education, training and incentives. Our quarterly newsletter “SER Link” announces new resources and training opportunities, and spotlights case studies of suppliers who have made advances in SER. Our annual Blue Sky Supplier Sustainability Award recognizes suppliers with strong commitment and innovative approaches to sustainability. In 2015, we changed the award’s methodology to reflect supplier performance more holistically across all of their sustainability and compliance activities, expanding it to include materials compliance, conflict minerals and business continuity as well as SER. We also continued one-on-one mentoring for suppliers that are early in the development of their sustainability programs.
For more formal training, we encouraged suppliers to leverage our SMaRT Library (see section below for more detail), make use of the EICC e-Learning Academy’s online training modules and attend local in-person trainings. We leverage these courses for our own teams as well. In 2015, 400 internal and supplier users completed 870 training courses in the SMaRT Library and the EICC e-Learning Academy. We also partnered to hold an in-person training course on human trafficking in Malaysia, attended by more than 60 participants, 35 of whom represented companies that supply EMC.
In addition to the training and communications described above, 2015 saw continued growth in our activities in business integration, supplier sustainability reporting and targeted supplier outreach.
A supplier’s social and environmental responsibility is part of its overall business performance. EMC has scored our strategic suppliers on their sustainability performance since 2009. This information feeds into our overall Supplier Scorecard, which also includes other business metrics such as quality, cost and availability, and provides a key input into sourcing decisions. The sustainability section of the Scorecard – which evaluates SER, Business Continuity Planning (BCP), Material Content, Conflict Minerals and Product Security – continues to be one of the most heavily weighted sections, making up more than 20 percent of the score for most suppliers.
We use EMC’s Archer GRC platform to facilitate management of, and visibility into, supplier risk and performance across our supply chain sustainability programs. This tool helps our commodity teams and our suppliers to better track suppliers’ action items and to access training and resources, while also raising the visibility of suppliers’ relative status and performance to senior leadership.
In 2015, we added to this Archer tool an easy-to-intuit grading system highlighting supplier sustainability and compliance performance. The goal of this new system is to make it easier for our commodity teams to include this information when making sourcing decisions, highlight poor performers to management and clarify how suppliers can improve. We piloted this approach in partnership with the New Product Introduction (NPI) team as a way to incorporate risk considerations earlier in their sourcing process. We plan to expand the use of this new approach across multiple forums in 2016.
100 percent of our supplier management teams – both commercial and technical – completed updated training on the EICC Code of Conduct in 2015. These courses help our teams to better manage supplier performance on social and environmental responsibility, and put them in a stronger position to identify risks as well as opportunities. All of our supply chain commercial management team also completed more in-depth training on human trafficking.
Public Sustainability Reporting
We believe that public sustainability reporting advances transparency and accountability in our supply chain. In 2013, we formalized our requirement for EMC’s strategic direct materials suppliers (both Tier 1 and Tier 2) to publish a sustainability report using a standard framework like the GRI guidelines, and started scoring suppliers in 2014. To help prepare and incent suppliers who are not already reporting publicly, we continue to offer individual assistance, as well as case studies and a Q&A resource guide posted in our SMaRT Library.
We are pleased to have seen the percentage of suppliers issuing public sustainability reports nearly double from 2013 to 2015. While there was not significant change from 2014 to 2015, we did see a significant increase in suppliers reporting to GRI. In addition, we recognize the time and effort involved in a company issuing their first report, and survey results from 2015 suggest that we will see another significant step forward in 2016.
EMC’s suppliers have a wide range of expertise and challenges, as well as varied operations, worker demographics, and locations. In 2014, we launched an online resource library for suppliers, dubbed the SMaRT Library (Sustainability Management and Resource Training Library), based on a range of information indicating the areas of greatest interest and need. The resource contains short training modules on different topics and at different levels, including best practices, case studies, and hundreds of references to publicly available resources. In 2015, we added ten new modules in both English and Chinese on a range of topics and levels, from a beginner’s course on ethics risk management to intermediate health & safety courses to an advanced course on environmental management. We also translated the entire library into Spanish, recognizing the need for resources in that language.
During its first full year in operation, the SMaRT Library enabled 121 individual internal and supplier users globally to complete 417 courses. In 2016, we will continue to leverage the SMaRT Library, expanding the types of content available as well as continuing to require and offer training to our suppliers and employees. We are also continuing to institute a more robust mechanism for impact assessment to evaluate the effectiveness and longer-term results of what we provide.
Targeted Supplier Outreach
In 2014, we began to integrate our data from across sustainability functions and sources to support targeted, risk-based supplier outreach. Our intent is to identify the suppliers and facilities that may demonstrate higher risk in specific areas, and to target specific discussions, corrective actions and/or capability building where it will be most effective.
We began to implement this approach with a focus on water, grouping supplier sites based on a combination of water risk factors that include water availability and quality in-region, process water use, and/or lack of water management controls. In 2015, we reached out to those suppliers with the greatest risk to clarify individual situations and provide education as applicable. We also completed analysis using the same approach focused on indirect and temporary workers, migrant workers, young workers (including students) and gender. Based on risk factors found primarily through past audit and self-assessment questionnaires, we reached out to those suppliers whose data suggested the highest risk, and worked with them one-on-one to better understand their current status and to close gaps as relevant.
In 2016, we will continue to use this approach in other areas of particular concern or risk towards our goal of combining our monitoring and assessment activities with effective and impactful engagement.
1Active smelters and refiners are defined by CFSP as those that have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewellry Program Chain of Custody Certification.