As part of our comprehensive responsible sourcing program, we also conduct supplier audits which serve as a starting point to understand suppliers’ compliance infrastructure. Issues such as human trafficking, slavery, forced/prison labor and child labor are zero tolerance violations.
We require all suppliers review and acknowledge our Supplier Code of Conduct before entering into business with us. Our supply chain team also receives training on conflict minerals, responsible sourcing and human rights to raise and maintain their awareness and diligence of ESG-related risks.
As part of our effort to manage potential ESG-related risks in our supply chain, we maintain a process and systems to preemptively screen potential counterparties, including suppliers, vendors, customers, distributors, agents, consultants and other business partners of the company, prior to any transactions. This screening process was implemented on a global basis in the context of our Foreign Corrupt Practices Act (FCPA) / Anti-Corruption Policy and related internal “Third Party Due Diligence and Contracting Guidelines” as well as our Business Conduct and Ethics Policy. We also screen certain third parties against a worldwide database, including the Specially Designated Nationals and Blocked Person List of the Department of the Treasury’s Office of Foreign Asset Control (OFAC). We review all third parties with potentially high- or medium-level of ethical and compliance risks factors against this database.