Supply Chain Management and Audits

We expect our business partners to adhere to the same goals that Western Digital subscribes to in the manufacturing of our products.  Accordingly, WD works with its business partners to drive the goals set forth in the EICC Code of Conduct through our supply chain. We provide the training and necessary tools to our suppliers to enable them to comply with the EICC Code of Conduct, as well as to make sure they understand the goals of the EICC and why adherence to the Code of Conduct is important.

To ensure that the Code is being enforced at the supplier level, we perform EICC audits on our suppliers on a regular basis. We also request that our key suppliers use the EICC-validated Audit Process to ensure the effectiveness of the implementation of the EICC Code of Conduct at their sites.  WD will partner with its suppliers to address any gaps in compliance with the Code.

We have additionally provided capability training to our first-tier suppliers, performed supplier site audits, and tied adherence to the EICC Code of Conduct in our QBR measurement process. Our first-tier suppliers are responsible for the following tiers, with WD involved immediately to help resolve any issues.

Policy Regarding Conflict-Free Minerals

As a member of the EICC, WD supports the EICC goals of eradicating conflict metals from its products.  The EICC has been working with various NGOs to identify the mines from which various conflict metals have been sourced.  We support this project. 
In furtherance of this goal and accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of the 2010 United States Congress, Western Digital prohibits using in its products 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.  We also expect our partners to support this policy throughout the supply chain.

California Transparency in Supply Chains Act (SB 657)
The California Transparency in Supply Chains Act (SB 657) requires many companies, including Western Digital, to disclose on their websites the efforts they take to eradicate slavery and human trafficking from their direct supply chains.  SB 657 requires disclosures regarding verification, auditing, certification, internal accountability and training.

1.  Supply Chain Verification and Auditing
Western Digital’s commitment to global citizenship is strengthened by its commitment to the Electronics Industry Citizenship Coalition (EICC) and its adherence to the EICC Code of Conduct.  This Code of Conduct addresses supply chain performance expectations for labor, health and safety, environmental practices, ethics and management systems.  
 
Western Digital requires that its suppliers make a commitment to adhering to the EICC Code of Conduct and requires that suppliers perform periodic self-assessments.  Western Digital also performs periodic audits of key suppliers.  These audits are coordinated with these suppliers.  While Western Digital does not engage third parties to conduct these audits, some suppliers have been audited by third parties retained by other EICC member companies.

We believe that our suppliers' compliance with the EICC code reduces the risks of human trafficking and slavery in our supply chain. Western Digital and its subsidiaries expect suppliers to comply with the EICC code regardless of local business practices or social customs, and as may be requested by Western Digital, to demonstrate adherence to those codes.

For more information on the EICC and to view the EICC Code of Conduct, visit http://www.eicc.info/.

2.  Compliance with Slavery and Human Trafficking Laws
Suppliers contracted to Western Digital are required to comply with all laws applicable to their business operations.  Suppliers are also required to make a commitment to the EICC Code of Conduct.

3.  Internal Accountability
Western Digital requires employees to follow its Global Code of Conduct and Code of Business Ethics.  Violations of the Code of Conduct or Code of Business Ethics may be the grounds for employee discipline, up to and including termination of employment.  Contractors are also expected to conduct themselves in a manner consisted with these principles.  Contractors who fail to comply may be dropped from Western Digital’s supply chain.

4.  Training
Western Digital provides managers and its employees who have direct responsibility for supply chain management with knowledge and information regarding Western Digital’s requirements, including EICC compliance.  Western Digital also regularly conducts training for suppliers on EICC related issues. 

Other Supply Chain Initiatives

WD is working with its suppliers to support participation in the EICC Carbon reporting system survey.

We also work with business partners to prepare them for early ISO 14064 Certification and have partnered with local universities to further this goal.