California Transparency in Supply Chains Act of 2010
The California Transparency in Supply Chains Act of 2010 (the “Act”) became
effective on 1 January 2012. The Act requires retailers and manufacturers who do
business in the state of California and have gross worldwide sales of more than
$100 million, to be transparent about the efforts (if any) they have undertaken
to eradicate slavery and human trafficking in their supply chain.
Xyratex describes below the extent to which it engages in each of the five activities
specified under the Act to help identify and mitigate the risk of slavery and human
trafficking in our supply chain:
1. Verification of product supply chains
- Xyratex has an established Corporate Social Responsibility (“CSR”) policy and requests
that suppliers sign a standard CSR letter, which requires compliance with the principles
of the Electronic Industry Code of Conduct (the “EICC Code”) in its entirety. The
EICC Code specifically states: “Forced, bonded or indentured labor or involuntary prison labor shall not be used.
All work will be voluntary, and workers shall be free to leave upon reasonable notice
[…]”.
- In 2011 Xyratex established an on site audit process to verify the commitments we
have received from our suppliers pursuant to the Xyratex CSR Letter. Xyratex auditors
perform the audits, and results are recorded.
2. Auditing suppliers
- As described above, Xyratex has an established on site audit process in place to
evaluate suppliers’ compliance with the EICC.
- Audit failures are recorded and follow-up is performed by Xyratex’s procurement
teams in order to ensure corrective actions are received and implemented by the
relevant suppliers.
- Xyratex audits are announced but specific audit content is not shared prior to visits.
3. Requires direct suppliers to certify that materials comply
with laws regarding slavery and human trafficking
- As described above, Xyratex’s direct suppliers are asked to sign the CSR Letter,
and the on site audit process is used to mitigate any risk of forced labour and
child labour being used in producing the components used in Xyratex products.
4. Maintains internal accountability standards and procedures
- Xyratex has set specific objectives for its Supply Chain Corporate Social Responsibility
("SCCSR") policy which are published and presented to the Xyratex CSR committee. These
objectives include:
- increasing the percentage of suppliers who commit to comply with the principles
of the EICC Code to greater than 95%, (such percentage being measured against Xyratex’s
direct material spend);
- increasing the number of onsite audits carried out to greater than 50% (in terms
of value of Xyratex’s direct material spend) and to greater than 30% of Xyratex
suppliers; and
- ensuring the appropriate focus is placed on Xyratex’s SCCSR principles. The above
objectives are to be incorporated into procurement employees’ annual personal objectives.
5. Provides company employees and management training on human
trafficking and slavery
- Xyratex provides periodic training on our CSR principles, including the EICC Code,
to our worldwide procurement teams and such teams are familiar with the terms of
this policy.
- Together with this policy document, the primary guidance for Xyratex’s CSR principles
in the supply chain comprises the following documents:
- Xyratex’s Corporate Social Responsibility policy - Click here to view
- The EICC Code.