Supplier Principles
(rev. June 2016)
Dell is committed to responsible business practices and to high standards of
ethical behavior. We also hold our suppliers to high standards of excellence
defined in governing laws, recognized international standards and
conventions, and global best practices such as these.
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The United Nations (U.N.) Declaration of Human Rights
The U.N. Convention on the Rights of the Child
Fundamental conventions of the International Labor Organization (ILO)
Electronic Industry Code of Conduct (EICC)
International Organization for Standardization (ISO 14001)
Occupational Health and Safety Assessment Series (OHSAS 18001)
The Dell Code of Conduct
The Dell Vulnerable Worker Policy
The benchmark of other corporations and industries across the globe
The reporting standards of the Global Reporting Initiative
Meeting the Dell supplier principles is
a condition of doing business with
Dell. Dell implements these standards
through three primary means:
1. Reinforcing the general
requirement that Suppliers meet
or exceed all applicable laws and
recognized international
standards;
2. Ensuring adoption of Dell’s core
policy commitments by defining
and enforcing Supplier
requirements; and
3. Requiring active participation in
Dell’s Supplier Engagement,
Capability Building and Assessment
Programs.
1. Compliance with Laws and International Standards
Compliance with all Laws and Regulations
Critical to ensuring a socially and environmentally responsible supply chain is
our insistence that all persons, including Suppliers, Supplier employees and
Supplier contractors, behave in a legal and ethical manner. Dell and Dell's
Suppliers shall comply with all applicable laws and regulations where business
is conducted.
Certifications
All Suppliers that manufacture or assemble Dell-branded finished products
shall achieve and maintain certification on the International Organization for
Standardization (ISO) 14001 Environmental Management System Standards;
the ISO 9001 Quality Management Standard; and the Occupational Health and
Safety Assessment Series (OHSAS) 18001 Occupational Health and Safety
Management System Standard. Suppliers who have certifications to similar
standards or who are working to obtain initial certification must submit the
alternate certificate or a certification schedule, respectively, to Dell for
approval.
2. Dell’s Core Policy Commitments and Supplier Requirements
Dell imposes specific requirements on its Suppliers with respect to the
following issue areas:
Supplier Diversity and Non-Discrimination
Dell believes an ethical, diverse supply chain is a vital part of our business.
We partner with companies that share our vision of doing business the right
way. Also, just as we promote a diverse workforce, we believe that Suppliers
from various backgrounds help us to best serve our global customer base.
Learn more about this aspect of our standards on our Supplier Diversity
Standards Overview Page. Each Supplier must meet the following diversity
requirements: (1) comply with any applicable law and regulation targeted
towards suppliers to governmental entities; (2) use reasonable efforts to
engage minority owned businesses and women owned businesses if Supplier
engages subcontractors to provide any deliverables or to support the
Supplier’s overall business operations; (3) use commercially reasonable efforts
to engage small businesses as defined by the United States Small Business
Administration (including small business sub-categories such as small
disadvantaged businesses, small women-owned businesses, veteran owned
businesses, service disabled veteran owned businesses and HUB zone
businesses) if Supplier engages subcontractors in the United States to provide
any deliverables or to support the Supplier’s general business operations; (4)
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maintain accurate records of Supplier’s efforts under this provision; and (5)
report to Dell, on Dell’s request, Supplier’s spend with minority owned
businesses, women owned businesses and small businesses.
Federal Acquisition Regulations
If Dell is providing Supplier’s products or services under a United States
government prime contract or subcontract, Supplier shall comply with the
following provisions of the Federal Acquisition Regulations, published in Title
48 of the United States Code of Federal Regulations (CFR) at 52.244-6:
52.203-13, Contractor Code of Business Ethics and Conduct; 52.219-8,
Utilization of Small Business Concerns; 52.222-26, Equal Opportunity; 52.22235, Equal Opportunity for Veterans; 52.222-36, Affirmative Action for Workers
with Disabilities; 52.222-40, Notification of Employee Rights Under the
National Labor Relations Act; 52.222-50, Combating Trafficking in Persons;
52.232-40, Providing Accelerated Payments to Small Business Subcontractors
and 52.247-64, Preference for Privately Owned U.S.-Flag Commercial Vessels.
Supplier shall also comply with the requirements of 41 CFR §§ 60-l.4(a), 60300.5(a) and 60- 741.5(a), which prohibit discrimination against qualified
individuals based on their status as protected veterans or individuals with
disabilities, and prohibit discrimination against all individuals based on their
race, color, religion, sex, or national origin.
Counterfeit Mitigation and Supply Chain Security
Dell is committed to addressing present and emergent threats to its supply
chain by focusing on counterfeit mitigation and avoidance. As part of this
commitment, Dell relies on constructive engagement with our Suppliers.
Suppliers to Dell must (a) implement and maintain counterfeit mitigation
measures that substantially meet the system criteria specified in 48 CFR
252.246-7007 (Contractor Counterfeit Electronic Part Detection and Avoidance
System); (b) provide to Dell, on Dell’s request, information concerning such
counterfeit mitigation measures; and (c) address any material deficiencies in
such mitigation measures that may be identified by Dell or by Supplier.
Working Conditions, Forced Labor and Human Trafficking
Dell is committed to upholding the human rights of workers at any tier of its
supply chain, and to treating them with dignity and respect. Workers include
direct employees, temporary workers, migrant workers, student workers,
contract workers, and any other person(s) providing labor and employment
services to Supplier. Dell is working with leading electronics companies and
nongovernment organizations (NGOs) as part of the Dutch Sustainable Trade
Initiative, a program designed to improve working conditions at the Supplier
level by finding innovative ways to address nonconformance issues and
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focused initially on the half a million workers at more than 100 Suppliers in
China.
Prohibited Practices -- Forced, bonded (including debt bondage) or
indentured labor, involuntary prison labor, slavery or trafficking of persons of
any age shall not be used at any tier of the supply chain. This includes
transporting, harboring, recruiting, transferring or receiving persons by means
of threat, force, coercion, abduction or fraud for labor or services. Employers
or agents may not hold or destroy employees’ identification or immigration
documents, such as government-issued identification, passports or work
permits, unless the holding of work permits is required by law. Employers may
not restrict workers’ freedom of movement in the facility or entering or
exiting company-provided facilities. All work must be voluntary and workers
shall be free to terminate their employment and leave work at any time.
Employment Practices -- Employers and agents may not use misleading or
fraudulent practices during the recruitment of employees. As part of the
hiring process, workers must be provided with a written employment
agreement in their native language that contains a description of terms and
conditions of employment and the hazardous nature of the work, prior to the
worker departing from his or her country of origin. Any employer-provided
housing must meet the host country housing and safety standards.
Employer must pay return transportation costs upon the end of employment
for an employee who is not a national of the country in which the work is
taking place and who was brought into that country for the purpose of
working on a U.S. Government contract or subcontract, unless an employee
who is legally permitted to remain in the country of employment chooses to
do so; or an employee who is a victim of trafficking is seeking victim services
or legal redress in the country of employment, or an employee is a witness in
a trafficking-related enforcement action.
Child labor -- Child labor may not be used in any tier of the supply chain. The
term “child” refers to any person under the age of 18, under the age for
completing compulsory education, or under the minimum age for employment
in the country, whichever is greatest. Employers may, however, implement a
fully compliant workplace learning program for workers between the ages of
15 and 18. Workers under the age of 18 (Young Workers) shall not perform
work that is likely to jeopardize their health or safety, including night shifts
or overtime. In the absence of local law, the wage rate for Young Workers
shall be at least the same wage rate as other entry-level workers performing
equal or similar tasks. To enforce the policy prohibiting the utilization of
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forced or indentured child labor, Dell will conduct all due diligence to
determine whether forced or indentured child labor is utilized at any tier of
its supply chain.
Human Trafficking -- Dell joins the United States Government in its zero
tolerance policy regarding trafficking in persons. In addition to the above,
Dell’s suppliers at any tier in the supply chain shall not procure commercial
sex acts during the period of performance of the contract All Dell suppliers,
contractors and subcontractors shall include the substance of this policy in all
subcontracts in support of Dell business. Suppliers shall have a compliance
plan in place to ensure that human trafficking and forced labor are not used
and that risks of worker exploitation are mitigated. Supplier shall comply with
48 CFR 22.1705 and 52.222-50 regarding human trafficking. Suppliers shall
provide details relating to their compliance programs and their action plans to
Dell upon request.
Additional information about Trafficking in Persons and examples of
awareness programs can be found at the website for the United States
Department of State’s Office to Monitor and Combat Trafficking in Persons.
Minerals and Extractives
Dell is focused on multi-industry processes that help ensure that the minerals
tungsten, tantalum, tin and gold that we use in our products are obtained
from responsible global sources. The Democratic Republic of Congo has been a
global mineral provider for years, but human rights violations have been
reported in its mining industry. It is Dell policy to refrain from purchasing
minerals from the Suppliers that support these violations, and we advocate
that our Suppliers adhere to the same standards, which are more specifically
set out on our Addressing Conflict Minerals page. Suppliers must meet the
conflict minerals reporting requirements established by the Dodd-Frank Wall
Street Reform and Consumer Protection Act (Public Law 111-203 Section 1502)
and by the Securities and Exchange Commission (SEC) at 17 CFR 240 and 249b.
Regardless of whether or not Supplier is subject to SEC Rules (independent of
this section), Suppliers must also upload its data accurately into the
Electronics Industry Citizens Coalition (EICC) Conflict Minerals Reporting Tool,
and ensure smelter information is updated within one month if there is a
change in a sub-tier Supplier supporting Dell’s business. Suppliers must notify
the Dell Conflict Minerals team within 72 hours of discovering that a smelter
used by Supplier is known to utilize gold, tantalum, tin, or tungsten from a
conflict mine in the Democratic Republic of Congo.
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Sustainability Reporting
Unless exempted by Dell, each Supplier shall publish, at its own expense, (a)
a Global Reporting Initiative (GRI)-based sustainability reports on its
corporate website and update the report annually and (b) a 5-year responsible
water risk mitigation plan on its corporate website and update the report
annually. Suppliers must also provide information about social and
environmental responsibility, including compliance with Dell policies.
Anti-Corruption
Suppliers shall adhere to the Foreign Corrupt Practices Act (15 U.S.C. et seq.),
the United Kingdom Bribery Act of 2010, and all applicable local laws relating
to anti-corruption or anti-bribery (“Anti-Corruption Laws”) . Each Supplier
agrees not to violate the Anti-Corruption Laws with respect to sourcing,
licensing or delivery of products to Dell. Suppliers shall maintain anticorruption policies and procedures that are adequate to ensure that Supplier
and any person to whom Supplier subcontracts the provision of any element of
this Agreement, or who provides any services or receives any payment in
connection with Supplier’s performance of the Agreement comply with the
Anti-corruption Laws.
3. Supplier Engagement, Capability Building and Assessment Program
To help ensure that global standards and Dell policy commitments are
implemented and reinforced, Dell requires that Suppliers participate in
several programs in which we work with Suppliers to build capability to
exceed applicable international standards, and also to train Suppliers and
remedy areas of concern that may be revealed in our audits.
Training
Dell focuses on capability building and hosts multiple Supplier workshops each
year that address relevant areas affecting our Suppliers. Our Social and
Environmental Responsibility (SER) workshops offer those in our supply chain
the opportunity to learn and share best practices. Key topics include the
Carbon Disclosure Project, management of working hours and corporate
responsibility performance evaluation tools.
Continuous Improvement
Dell is committed to responsible sourcing. We invest our company’s resources
and time to drive improvements throughout our supply base. Suppliers must
meet the standards specified in this section, but we encourage Suppliers to
view social and environmental responsibility as a journey of continuous
improvement. With a focus on self-assessment, internal ownership and selfaccountability, Dell Suppliers can make changes that will bring long-lasting,
sustainable impact not only to their own facilities and operations, but also to
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those of their own providers.
Quarterly Business Reviews
To embed socially responsible behavior into business activities, key Suppliers
must undergo a Dell review of requirements and principles in quarterly
business reviews. Dell Suppliers are and shall be evaluated quarterly and our
purchasing decisions consider their scores. The reviews include specific
implementation plans for Suppliers’ own social and environmental
responsibility programs for compliance and environmental stewardship.
Transparency
Transparency is important to our relationship with stakeholders. We continue
to publicly disclose our list of top suppliers. In addition, we provide our
greenhouse gas (GHG) emissions on the Carbon Disclosure Project website. We
expect that all suppliers must provide GHG emissions as well.
Monitoring and Reporting
Suppliers are subject to audits by Dell or by third parties designated by Dell.
Through our audits, our team identifies suppliers that may present a higher
risk of non-conformance to the Electronic Industry Code of Conduct (EICC),
these Supplier Principles, or to other applicable standards, and engages with
these Suppliers to address gaps identified in their conformance to those
standards. This engagement includes development of sustainable corrective
action plans as well as on-site monitoring to establish that the Supplier has
systems in place to facilitate continued conformance. If Supplier becomes
aware of facts or circumstances which are likely to involve or lead to claims
relating to a violation of the EICC, these Supplier Principles, or other
applicable standards, the Supplier shall promptly inform Dell of such facts or
circumstances.
Remediation
Dell reserves the right to take any and all available actions against Suppliers
for any violations of its Vulnerable Worker Policy and for persistent and
unresolved violations of the EICC, Dell’s Supplier Principles, and applicable
social and environmental laws. Such actions may include without limitation
the termination or reduction of business with Supplier, required remediation
plans, frequent required onsite compliance auditing at suppliers expense,
employee compensation at supplier’s expense, and/or termination of Dell’s
contract with the supplier.
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