Seagate has two types of suppliers: direct suppliers, which provide components and parts for products, and indirect suppliers, who provide products and services to support operations. We have adopted the Electronic Industry Citizenship Coalition (EICC) Code of Conduct as our supplier code of conduct, and we have established long–term, stable relationships with our top suppliers to better align goals and standards We meet regularly with suppliers to communicate our expectations and evaluate their engagement.

We also require that certain service providers (e.g., janitorial service, canteen providers, etc.) that bring workers onto our sites to follow our Standard Operating Procedure, which details specific steps for supplier engagement, including signing the Code of Conduct, training and completing the EICC Self–Assessment Questionnaire (SAQ) and the Validated Audit Process (VAP).

We see healthy and proactive supplier engagement as an ongoing and important goal as we continue to grow. As long as we rely on suppliers to source our product, we will prioritize the right kind of relationships with these companies.

Supplier Education
We require all suppliers to sign our Supplier Code of Conduct, which is fully in line with the EICC code. Aligning with this industry standard eliminates confusion among suppliers about expectations around compliance. Seagate requires key suppliers to train their employees on the EICC code. All suppliers have direct and free access to a third–party online manager, which includes software that details EICC expectations and supplier reports that track progress. Seagate compliance managers also are positioned across locations. Through in–person meetings, quarterly business reviews with key suppliers, and our Supplier Day held throughout Asia, we educate suppliers on the importance of global citizenship, sustainability and compliance with the EICC and our standards.

Supplier Management
Seagate requires all key suppliers to complete EICC’s SAQ through the organization’s platform. The SAQ is meant to help suppliers and manufacturers alike understand and discuss risks and best practices related to corporate responsibility. We review suppliers’ SAQ scores regularly; depending on the score, we may require a supplier to undergo a VAP audit.

When we find instances of non–compliance, we work with suppliers to issue a corrective action plan and we expect them to undergo a closure verification audit. Seagate‘s in–house management platform, Compliance Manager, helps us and our suppliers assess compliance and risks. Some of the things we track include acknowledgment of the Code of Conduct, completion of the EICC SAQ, training milestones and audits. We currently are working to migrate long–term suppliers to this platform.

Indirect Suppliers
Seagate has been increasing engagement with indirect suppliers, particularly labor agents, by working with the EICC to pilot VAP methodologies in this area. These activities with indirect suppliers have been considered leading practice among EICC members.

A Transparent Supply Chain
On January 1, 2012, the California Supply Chain Transparency Act of 2010 (SB 657) came in effect in California. The law increases the amount and visibility of information available to consumers from manufacturers and retailers about efforts to address slavery and human trafficking across their supply chains.

Seagate is committed to a transparent supply chain in which any customer can access information about any supplier at any time. To facilitate this, we introduced an e–learning course for Seagate’s commodity managers on preventing human trafficking, developed by the United Nations Global Initiative to Fight Human Trafficking and End Trafficking Now. We also require suppliers to complete and submit a Conflict Minerals Reporting Template and work toward sourcing from conflict–free validated smelters and refiners.

Seagate’s Policy Statement on Conflict–Free Minerals
Product Stewardship section on conflict minerals

Supplier Diversity
Seagate is a global company with a diverse workforce spanning 15 countries on five continents. We encourage diversity in our supplier base. This promotes jobs creation, stronger small businesses and a more inclusive economy, all of which strengthen local communities.

Specifically, we believe that working with minority–owned businesses creates both significant value and formidable buying power, and we implement programs to encourage suppliers in the U.S. to participate in our competitive bidding process. These suppliers include businesses owned and operated by minorities, women, gays and lesbians and veterans, as well as small businesses located in historically underutilized business zones.