Public Workspaces

Comment 12180
New (Unresolved)
DRAFT_GEC_ESG Criteria Document_1Dec2023_Redline Changes for Public Comment_v2.pdf (Revision 1)
Comment Submitted by
Kazuhito Oosumi
2024-01-15 00:58:24

Part C of 7.1.3 should be reverted to be in 7.1.4 as Optional criteria as mentioned above.

Submitter Proposed Solution

[ADD: Part A: A Summary of Audit and Corrective Action Reports

For all facilities in scope of Part B, manufacturer shall annually conduct, and make publicly available on the manufacturer’s website, a summary of audit and corrective action report that details labor and OHS supply chain issues. The report shall be based either on a full audit report provided by each supplier in scope or a summary created by a manufacturer or a third party. If the third party that provides the summary is not the entity that conducted the audit, the qualifications of the third party must be demonstrated.

Manufacturer may choose the initial 12-month period covered by the audit and corrective action report and must use the same 12-month period every year. The report shall include the following for all facilities audited in Part B of 7.1.3:

a) Explanation of the process to identify Prioritized Supplier Facilities owned or operated facilities that demonstrates conformity.

b) Overview of social audits from the past year, including:

i. The number of audits conducted and the percentage of the supply chain it represents;

ii. A breakdown of the percentage of supply chain audits, by contract manufacturers, final assembly, and component suppliers, and

iii. A summary of results identifying the top three most frequent audit findings by region.

c) Summary of non-conformance issues in 2 above. The summary shall be organized by contract manufacturers, final assembly, and component suppliers, and by geographic region, and include an assessment of the root causes of persistent nonconformances. The assessment of persistent nonconformances from the past year shall be based on consultation with a local, national, regional and/or international industry–independent organization(s) to monitored sites (e.g., community groups, worker organizations, non-governmental organizations (NGOs) and/or labor experts). The assessment shall include a description of who was consulted, what issues were raised, and how this influenced the corrective action plan.

d) Summary of manufacturer’s preventative and corrective actions to address all major nonconformities, including specific examples (e.g., assisting struggling suppliers through continuous improvement requirements or capacity building), and the measured impact of stated corrective actions to cease, prevent, mitigate, and remedy human rights issues.

 

[ADD: Part B: Transparency on suppliers (1 point)]

Manufacturer shall make publicly available on the manufacturer’s website a list of supplier facilities covering 80% by production spend, including the name and site addresses of the facilities.

 

 

The following text should be added to avoid identifying suppliers in the summary report.

 

[ADD: The information which might identify the audited supplier need not be given.]

 

(The verification requirements do not state that names of the suppliers audited should be made public, but we would like to ensure that supplier information is protected from a confidentiality perspective.)

 

 

Moreover, Verification requirements of 7.1.4 should be modified in accordance with texts reverted from 7.1.3.