Supply Chain Responsibility is a Journey

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At Dell, our customers are at the core of everything we do. We know it’s important to them that we drive social and environmental responsibility in our supply chain and across the industry. We’ve been working diligently to demonstrate full transparency of key issues within our supply chain and help our suppliers to mitigate risks in those areas. We’ve even made that goal one of the pillars of Dell’s 2020 Legacy of Good Plan.

As a founding member of the Electronics Industry Citizenship Coalition (EICC), driving social and environmental responsibility throughout our supply chain is a challenge we readily accept. The solutions often take time, resources, expertise and patience. We thought you would like a look into how we handle supply chain issues at Dell.

We mandate regular audits of multiple tiers of our supply chain and ensure that supplier facilities representing 95 percent of our total spend undergo an audit by an independent third party. Any allegations at a Dell supplier that are outside of our ongoing audit procedures are subjected to an immediate investigation.

How do we accomplish this? First, we verify the allegation’s veracity and determine if an additional audit is necessary. In some cases, we obtain a copy of a recent third-party audit and Corrective Action Plan (CAP) through the EICC Audit Sharing process. We then hold our suppliers accountable to executing their CAPs for all noncompliance issues identified in the audit and follow open findings through to closure. More serious situations may include Dell executives contacting a supplier’s CEO for further discussion, as well as an in-person investigation by Dell’s procurement teams.

Every process has opportunities for improvement, and we recognize that our process for responding to supply chain issues needs to evolve as our industry evolves. In the past year, we’ve implemented the following:

  • Creating a Social & Environmental Responsibility (SER) Executive Review board to evaluate our responses to supplier issues
  • Using only independent third-party supplier audits
  • Launching a new Vulnerable Workers Policy that provides special protections for workers, meeting the requirements of FAR Subpart 22.17 (Combating Trafficking in Persons)
  • Updating our Purchase Agreement to include the right to share audit data as needed
  • Working toward better working conditions through our co-chair position on the EICC Vulnerable Worker Working Group and a co-funded student worker survey with Apple
  • Training our suppliers on the new EICC 5.0 Code of Conduct

During this time allegations of misconduct have been made at Dell facilities and our suppliers. Some of these findings were accurate, others were not. Despite this, we understand our role in surfacing and resolving root causes of these issues in our own facilities, as well as our working with suppliers to do the same in their facilities. For example, if we find a case of excessive working hours, an ongoing issue for electronics manufacturers, we work to make improvements not only in our supply chain but also at the industry and multi-industry level.

Through our Legacy of Good plan, we have made a long-term commitment to a supply chain that’s socially and environmentally responsible. We want our customers to be confident that our products are responsibly sourced and manufactured, and that the people who work on Dell products are treated with dignity and respect.

You can see our long-term sustainability goals in our Legacy of Good at

About the Author: Mark Pringle

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