California Transparency in Supply Chains Act (SB 657)

Updated on July 1, 2016

The California Transparency in Supply Chains Act (SB 657) requires many companies to disclose on their websites the efforts they take to eradicate slavery and human trafficking from their direct supply chains for goods offered for sale. SB 657 requires disclosures regarding verification, auditing, certification, internal accountability and training.

Our core business philosophy is to conduct business under the principles of fairness, integrity and transparency. We strive to continuously improve our supply chain through our practices and our corporate social responsibility efforts.

We are proud to be a member of the Electronics Industry Citizenship Coalition (EICC). The EICC is comprised of leading electronics industry companies that have joined together to promote freely chosen employment, safe working conditions, ethical business practices, and environmental stewardship globally throughout the electronics industry supply chain. EICC members adhere to a common EICC Code of Conduct, which addresses supply chain performance expectations for labor, health and safety, environmental practices, ethics and management systems.

The statements below describe activities by SanDisk®, a Western Digital brand (“SanDisk”).

Verification

We provide manufacturing suppliers with a supplier survey, which, among other things, includes questions to help identify and assess risks of human trafficking and slavery in the supply chain. Survey responses are tracked, and upon request, relevant documents, procedures and records are reviewed.

In addition, manufacturing suppliers receive and must acknowledge adherence to SanDisk’s Supplier Code of Conduct, which among other things, does not permit human trafficking and slavery by the supplier or in the supplier’s supply chain.

Auditing

Our supplier supply chain audit program includes, among other things, evaluation of manufacturing suppliers’ compliance with respect to the prohibition of human trafficking and slavery set forth in the SanDisk Supplier Code of Conduct.

Non-conformance upon audit is recorded in our corrective and preventive action system and monitored for correction and closure.

The above mentioned audits are conducted either by us or an independent third party based on the human trafficking and slavery standards set forth in the SanDisk Supplier Code of Conduct. Audits are typically announced prior to being conducted.

Certification

Most of our manufacturing suppliers certify by contract or in terms and conditions that the materials and services incorporated into SanDisk products are made or provided in compliance with the relevant laws, including laws against slavery or human trafficking, of the country or countries in which they are doing business.

Internal Accountability

Our procurement and quality functions are responsible for administering the programs to ensure that manufacturing suppliers affirm compliance to the SanDisk Supplier Code of Conduct, including provisions regarding anti-trafficking and slavery.

In addition, our employees are required to annually acknowledge adherence to our code of conduct, requiring employees to comply with the applicable laws of the places where we do business. We also provides an anonymous hotline in which to report any actual or suspected violations regarding, among other things, slavery and human trafficking. Our policy is to not retaliate against persons bringing forward actual or suspected violations.

Training

We provide training on mitigating the risks of human trafficking and slavery in supply chains to our employees and management with direct responsibility for supply chain oversight. Such training is available as instructor-led sessions or online through our internal learning and development system.