GOVERNANCE

Human Rights

EMC supports and respects the protection of internationally proclaimed human rights for all, including our employees, workers within our supply chain, and people impacted by the use of our products. We have a process in place for clear and accurate communication of our policies, practices, and performance expectations to workers, suppliers, and customers. As part of that process, we encourage worker feedback and regularly review results of audits and assessments.

EMC’s commitment to human rights is reflected in our Human Rights and Global Labor Principles. EMC’s Principles are based on the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, the International Labour Organization standards, and other respected standards. These Principles reflect EMC’s commitment to core human rights for our employees and for workers in our supply chain, including but not limited to freely chosen employment, child labor avoidance, working hours, wages and benefits, humane treatment, non-discrimination, freedom of association, and freedom of expression. The Principles also state clearly that we will not tolerate misuse of our products to infringe on human rights. In 2015, EMC continued our discussions with NGOs as well as with our peers to clarify how best to apply these Principles to the IT industry, and revised the Principles to explicitly incorporate support for the right to privacy.

In furtherance of our commitment to human rights, EMC is an active participant in and a member of the board of directors of the Electronic Industry Citizenship Coalition (EICC), a collaboration of leading information and communications technology companies dedicated to improving supply chain social and environmental responsibility through collaboration and common tools and standards. We have adopted the EICC’s Code of Conduct for ourselves and our suppliers. The EICC Code sets standards for labor, ethics, environment, health and safety, and management systems. All direct materials suppliers are required to acknowledge the Code, and compliance with the Code is part of our standard contract language for all EMC vendors. To learn more about how we monitor suppliers’ compliance to the Code, assess risk, engage with suppliers to drive positive change, and create incentives for improvement, visit Supply Chain Responsibility.

Two of our primary areas of focus within the broader scope of supply chain human rights are forced labor and conflict minerals. The EICC’s recent expansion of its audit protocol to include all labor agents and on-site service providers has resulted in increased findings related to forced labor. We require any audit findings to be addressed through corrective action, and provide feedback, training and other assistance to help our suppliers in that process. In 2015, we also reached out to suppliers demonstrating risk factors for forced labor to collect additional detail about their management practices and to identify and remedy any gaps. For more information on what we are doing to combat human trafficking, see our EMC Policy Statement on Slavery and Human Trafficking.

EMC is also committed to the ethical sourcing of minerals used in our products. This includes our goal not to purchase product materials containing minerals whose sale finances armed conflict in the Democratic Republic of the Congo. To this end, we survey our suppliers, perform risk assessments, and require corrective actions where appropriate. We also participate in the Conflict-Free Sourcing Initiative to promote conflict-free sourcing and transparency in the global mineral supply chain. In 2015, we continued and expanded our activities to engage smelters in the Conflict-Free Smelter Program (CFSP). This program gives us assurance that participating smelters have systems in place to source only DRC Conflict-Free material. For more information on our work in conflict minerals, see our Conflict Minerals Report.

With regards to human rights considerations in the use of our products, EMC is working to mitigate social impacts, including respecting the right to privacy and freedom of expression.  As part of those efforts, we have been working to establish criteria that can be used to identify potential high-risk sales or service opportunities (e.g., geography, potential customer/partner, product type). This includes working with a third party to assess which products may present greater human rights-related risks. Based on that assessment, we believe our focus should be on our security products, on-site services, and consulting services.

Most EMC sales, particularly internationally, are transacted via partners and distributors. In recent years, we have enhanced our due diligence, onboarding, and monitoring processes in an effort to ensure that we are properly evaluating risks when we on-board distributors and tier one partners, and on a periodic basis thereafter. We are working to expand this program in 2016 to include other third parties with whom we do business. We are also training EMC employees on the risks associated with third parties, and asking them to speak up if they have questions or concerns in order to minimize the risk of being unintentionally complicit in human rights abuses. This online training went live in November 2015 and is available to all employees.

ADDITIONAL INFORMATION

HUMAN RIGHTS AND GLOBAL LABOR PRINCIPLES
SUPPLIER CODE OF CONDUCT
PARTNER CODE OF CONDUCT
CORPORATE ETHICS HOTLINE
BUSINESS CONDUCT GUIDELINES
STATEMENT AGAINST SLAVERY AND HUMAN TRAFFICKING
EMC POLICY ON CONFLICT MINERALS
TRANSPARENCY AT EMC

Notes: