On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) will go into effect in the State of California. This law was designed to increase the amount of information made available by manufacturers and retailers regarding their efforts (if any) to address the issue of slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support.
HP's Electronic Industry Code of Conduct (EICC) is underpinned by international labor and human rights standards. We believe that workers at supplier facilities have the right to freely choose employment, the right to associate freely and join or be represented by worker councils or labor unions on a voluntary basis, and the right to bargain collectively as they choose. Workers also have the right to a workplace free of harassment and unlawful discrimination.
Slavery and human trafficking can take many forms, including forced labor and child labor. Since we began our supply chain social and environment responsibility (SER) program in 2000, HP has undertaken efforts to ensure and verify the absence of forced labor and child labor in our supply chain.
These efforts include:
- Risk-based supplier assessments HP performs assessments of potential suppliers according to our risk-based approach. This approach includes preliminary risk assessments and supplier assessment questionnaires.
- Supplier audits Our audit program (see Audit strategy) evaluates suppliers' compliance with HP's EICC, which prohibits forced labor and child labor. Various types of announced audits are conducted under this program, including onsite audits attended by HP, collaborative audits, and third-party on-site audits of practices and underlying management systems. A finding of nonconformance with HP's EICC relating to the issue of forced or child labor does not necessarily indicate that forced or child labor has occurred. For example, in 2010, we found a total of three major supplier audit nonconformances with HP's EICC related to EICC policy safeguards against forced labor. The three nonconformances included suppliers' lack of an explicit policy prohibiting forced labor, an absence of supplier records reflecting work permits or employee contracts, and payment by an employee of recruitment fees. Following audits, suppliers are required to produce corrective action plans, which HP reviews and approves. The corrective action plans outline how a supplier will resolve issues uncovered in audits. HP has a zero-tolerance policy for the presence of forced and child labor. If any zero-tolerance items are uncovered in audits, we require suppliers to rectify the problem within 30 days, and we return to the facility between 30 and 90 days after the audit to confirm resolution of the issue.
- Supplier agreements HP has purchasing agreements or purchase order terms and conditions in place with all our direct suppliers and ODM (original design and manufacturing) suppliers, requiring them to comply with international standards and applicable laws and regulations regarding forced labor and child labor as specified in HP's EICC.
- Capability building programs HP partners with a number of nongovernmental organizations (NGOs) and training partners to raise awareness of HP's EICC, which includes provisions related to forced labor and child labor. The programs also build capability among suppliers to reduce the risks of nonconformances with HP's EICC. Our capability building programs have included worker-management communications training, which provides employees access to mechanisms to raise grievances with management or superiors. (See Capability building for more information).
- Procurement professionals training HP trains employees responsible for supply chain management on how to identify and respond to supply chain issues, such as forced labor or child labor. We require all HP employees and contractors to comply with our Standards of Business Conduct (SBC), which includes provisions aimed to ensure that child, prison, or forced labor are not permitted at any HP business partner or supplier operations. HP's SBC is enforced through the HP Global Misconduct Policy, and we train employees on these standards annually. HP's SBC has also been adapted for contingent workers in the HP Contingent Worker Code of Conduct, which is enforced through labor contracts.
Minerals mining in Democratic Republic of Congo conflict zones is an area of particular concern, and HP is working with industry partners to address these issues. (See Conflict minerals for more information.)
For full details of our supply chain SER program and specific audit findings, see Supply chain responsibility.