1. Ethics in the ICT Manufacturing Supply Chain
Balan Shanmuganathan
26 June 2014
© Seagate Technology LLC

2. Introduction

3. Seagate: Storage Leader
Seagate is the world's leading provider of storage devices
Provides storage for enterprise, desktop, mobile computing, consumer electronics and retail markets
Owns and vertically integrates critical technologies: heads and media
Approximately 51,000** employees worldwide
*For third fiscal quarter ended March 31, 2014, **Includes interns and agency temps

4. Seagate Global Presence
Kitchener, Ontario, Canada
Toronto, Ontario, Canada 
Cupertino, CA, USA

Fremont, CA, USA
Sacramento, CA, USA
San Francisco, CA, USA
Scotts Valley, CA, USA
Valencia, CA, USA
Longmont, CO, USA

Heathrow, FL, USA
Chicago, IL, USA
Shrewsbury, MA, USA
Shakopee, MN, USA
Bloomington, MN, USA
Oklahoma City, OK USA
Tigard, OR, USA
Guadalajara, Mexico
Manaus, Brazil
São Paulo, Brazil 
Danderyd, Sweden

Amsterdam, Netherlands
Brussels, Belgium 
Dublin, Ireland
Springtown, N. Ireland
Havant, UK
London, UK
Maidenhead, UK
Massy, France
Paris, France
Basel, Switzerland
Madrid, Spain
Munchen, Germany
Milan, Italy
Cairo, Egypt 
Korat, Thailand
Teparuk, Thailand
Johor, Malaysia

Penang, Malaysia

Petaling, Jaya, Malaysia 
Seremban, Malaysia
Ang Mo Kio, Singapore
Science Park, Singapore
Woodlands, Singapore
Delhi, India 
Beijing, China
Dongguan, China 
Hong Kong, China

Suzhou, China
Wuxi, China
Gwanggyo, South Korea

Tokyo, Japan
Taiwan
Calamba City, Philippines
Navankorn, Thailand
Matraville, Australia
Sydney, Australia
Legend:
Lacie
Xyratex
HQs, Admin/Sales
Design
Drive and Component MFG
Customer Support

5. Seagate Products, Customers and Markets
Internal Storage
Safe and Smart Surveillance
Cloud, Kinetic and Open
Mobile and Client
Enterprise
NAS
Branded Products
Wireless Storage
SMB Storage
Personal Storage
Services
Consumer Electronics
Personal Cloud Storage

6. Supply Chain Code of Conduct

7. Evolution of the Code of Conduct
Prior to 2004, individual companies had their own supplier code of conduct
In 2004 a number of companies got together and developed a common supply chain code of conduct. The EICC code v1 was released in October 2004
To support the code implementation, the companies formed a coalition and started developing common assessment questionnaires and audit tools
The coalition has now grown to over 90 companies, reviewing thousands of assessment questionnaire and completing hundreds of audits
The code has undergone multiple revisions and is currently in version 4 with the next version scheduled to be released in January 2015

8. The EICC has grown over the years

9. Management system approach drives sustainable solutions
EICC Code of Conduct
Environment
Protect the
Labor
Treat employees with dignity & respect
Ethics
Uphold the highest
standards
Health & Safety
Evaluate & control
Exposure to hazards
Management Systems
Management system approach drives sustainable solutions

10. What are the drivers for an Ethics code?
Environment
Protect the
Labor
Treat employees with dignity & respect
Ethics
Uphold the
highest
standards
Health & Safety
Evaluate & control
Exposure to
hazards
Management Systems
Management system approach drives sustainable solutions
Creating a level playing field
Setting minimum standards
Complementing company values
Meeting stakeholder expectation
Meeting legal obligation
Brand reputation

11. Management system approach drives sustainable solutions
EICC Code of Conduct
The Ethics section of the code covers,
Business Integrity
No Improper Advantage
Disclosure of Information
Intellectual Property
Fair Business, Advertising & Competition
Protection of Identity
Responsible Sourcing of Minerals
Privacy
Non-Retaliation
Environment
Protect the
Labor
Treat employees with dignity & respect
Ethics
Uphold the highest
standards
Health & Safety
Evaluate & control
Exposure to hazards
Management Systems
Management system approach drives sustainable solutions

12. Management system approach drives sustainable solutions
EICC Code of Conduct
The Ethics Management System section of the code covers,
Company Commitment
Mgmt. Accountability & Responsibility
Legal & Customer Requirements
Risk Assessment & Risk Mgmt.
Improvement Objectives
Training
Communication
Worker Feedback & Participation
Audits & Assessments
Corrective Action Process
Documentation & Records
Environment
Protect the
Labor
Treat employees with dignity & respect
Ethics
Uphold the highest
standards
Health & Safety
Evaluate & control
Exposure to hazards
Management Systems
Management system approach drives sustainable solutions

13. Ethics and Human Rights
In most Human Right violations there is an element of corruption thus making Human Rights violation an Ethics concern
In recent years stakeholders have approached Human Rights violation as an Ethics violation tying it to the US Foreign Corrupt Practices Act (FCPA) and the UK Anti Bribery Act
These legislation don’t only apply to the company’s practices but also to the supply chain, thus requiring a more comprehensive approach
Soon the Federal Acquisition Regulation (FAR) will be released in support of the Executive Order Against Trafficking in Persons in Federal Contracts requiring additional disclosures in how migrant workers are cared for in the Supply Chain
Companies are now collaborating on various programs and activities to address Human Rights violations in the Supply Chain, e.g. conducting joint training, enhancing audits and verifications

14. Established Code of Conduct Questionnaire Assessment
In Summary
ETHICS
HUMAN RIGHTS
Capacity Building
WATCH THIS SPACE IT IS EVOLVING
Supply Chain
Migrant Workers
Human Trafficking
Bonded
Labor
Established Code of Conduct
Questionnaire Assessment
Audit Verification
Corrective Action

15. Thank you for your attention