Compliance Statement for UK Modern Slavery Act and California Transparency in Supply Chains Act


This statement describes the program that Western Digital Corporation, as well as its subsidiaries, including, but not limited to, Western Digital (UK) Limited, HGST Europe Ltd., and SanDisk UK Ltd., have established to comply with the U.K. Modern Slavery Act of 2015 and the California Transparency in Supply Chain Act, both of which require many companies to disclose on their websites the efforts they have taken to ensure that slavery and human trafficking is not taking place in their supply chains.

Our Organization
Western Digital is an industry-leading provider of storage technologies and solutions that enable people to create, leverage, experience and preserve data. The Company addresses ever-changing market needs by providing a full portfolio of compelling, high-quality storage solutions with customer-focused innovation, high efficiency, flexibility and speed. Our products are marketed under the HGST, SanDisk and WD brands to OEMs, distributors, resellers, cloud infrastructure providers and consumers. Our products include hard drives for large data centers, portable storage devices, and internal and external hard drives.

Our Policies
Western Digital is committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Western Digital does not tolerate the use of slavery, forced or compelled labor or human trafficking by our employees, contractors, business partners, or suppliers. To that end, Western Digital has a Global Code of Conduct (found here), which sets forth our expectations for all employees. Each year, Western Digital trains its employees on its Global Code of Conduct and other policies relevant to their jobs.

As detailed below, we have policies and processes to ensure that we conduct our business in an ethical manner consistent with our values.

Supply Chain Verification and Auditing
Western Digital's commitment to global citizenship is strengthened by its commitment to the Responsible Business Alliance (RBA) and its adherence to the 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 adhere to the RBA Code of Conduct, perform periodic self­-assessments, and, in some cases, undergo independent RBA audits. Suppliers are also required to authorize Western Digital to have access to their completed self-assessment questionnaires (SAQs), as well as any completed RBA audit reports.

Western Digital Corporation believes that our participation in the RBA and our suppliers' compliance with the RBA Code reduces the risks of human trafficking and slavery in ours (and the electronic industry's) supply chain. Western Digital and its subsidiaries expect suppliers to comply with the RBA 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 RBA and to view the RBA Code of Conduct, visit

Compliance with Slavery and Human Trafficking Laws
Western Digital's suppliers are required to comply with all laws applicable to their business operations. Suppliers are also required to make a commitment to the RBA Code of Conduct, which includes multiple provisions directed at preventing any form of slavery and human trafficking.

Verification. We require annual self-assessments and periodic RBA audits of our suppliers, selecting those that cumulatively comprise approximately 80% of our annual supplier spend, to verify that they are meeting legal and RBA requirements. The Code includes provisions directed at preventing slavery and human trafficking. This program primarily relies on RBA's validated audit process (VAP) audits and sometimes includes using third-party verifiers or our own staff to conduct audits of key suppliers and contract manufacturers.

Auditing. Western Digital audits suppliers that cumulatively comprise 80% of our supply chain purchases on an annual basis. We require those suppliers to arrange with the RBA to conduct an independent RBA VAP audit every two years. RBA will assign a qualified third party to audit those suppliers. We receive the RBA's official audit report based on the RBA's standard VAP soon after the supplier has undergone the audit.

In addition, we engage with and conduct periodic audits of labor brokers, as well as providers of on-site services, such as cafeteria, janitorial cleaning, and security.

Noncompliance with our company standards and/or the RBA Code of Conduct results in a requirement that suppliers develop and implement corrective action plans (CAPs). When non-conformances are identified, we follow standard RBA procedures to assure suppliers correct such non-conformance on a timely basis.

Internal Accountability. As noted herein, we require our employees to comply with the Western Digital Global Code of Conduct and our suppliers to comply with the RBA Code of Conduct.

Certification. Most of our manufacturing suppliers certify by contract or in terms and conditions that the materials and services incorporated into Western Digital products are made or provided in compliance with the relevant laws, including laws against slavery or human trafficking, of the country or countries in which they are doing business.

Training. As noted elsewhere, we train our employees on our Global Code of Conduct and key employees on the RBA Code of Conduct.

Internal Accountability
Western Digital requires employees to follow the Western Digital Global Code of Conduct. Violations of the Western Digital Global Code of Conduct may be the grounds for employee discipline, up to and including termination of employment.

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 RBA Code compliance requirements. Western Digital also encourages suppliers, contract manufactures, labor brokers, and on-site service suppliers to avail themselves of the resources available on the RBA's website, including training their employees on RBA related issues. Western Digital also occasionally conducts periodic training for these vendors.

Stephen D. Milligan
Chief Executive Officer
Western Digital Corporation

A copy of this compliance statement that includes our CEO's signature will be provided upon request.

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