External Sustainability Audits Program Manual Version 1.0, April 2013

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1 Sustainability in the Supply Chain External Sustainability Audits Program Manual Version 1.0, April 2013 Siemens AG 2013 All rights reserved. siemens.com/sustainability

2 Table of content 1 Program Background 2 Audit Process 3 Audit Scope and Checklist 4 Further Information Siemens AG 2013 All rights reserved. Page 2

3 Our goal is to balance people, the environment and value creation Responsibility for climate and environment Planet Sustainability Value-oriented action Responsibility for people Source: Siemens Sustainability Office Siemens AG 2013 All rights reserved. Page 3

4 Our sustainability program: Initiatives, walk the talk and alliances 'Planet' Sustainability Nachhaltigkeit Initiatives Walk the talk Alliances We turn our approach to sustainability into concrete business opportunities We are committed to embedding sustain-ability throughout our organization and operations Sustainability our guiding principle Siemens values: excellent innovative - responsible To achieve our sustainability targets, we work with all relevant stakeholders Source: Siemens Sustainability Office Siemens AG 2013 All rights reserved. Page 4

5 Comprehensive program for Sustainability in the Supply Chain is in place Standards for Suppliers Code of Conduct for Siemens Know-How Transfer & Capacity Building Supplier Sustainability Workshops* Web-based training for suppliers* Communication & Information (e.g. brochures, websites) Active development Self optimization Reduce volume/phase-out Supplier Development Assessing Risks & Detecting Issues External Sustainability Audits Supplier quality audits with Sustainability module Sustainability Self Assessments Risk Evaluation with Sustainability criteria Contractual Commitment & Policies Globally binding standards applicable to all Siemens suppliers Commitment through Corporate Responsibility contract Based on the principles of UN Global clause and declaration, Conditions of Purchase Compact and ILO Conventions Supplier Qualification Process Siemens-wide mandatory standards and processes Siemens AG 2013 All rights reserved. Page 5 Compliance Performance

6 Sustainability Audits are conducted to identify & mitigate sustainability related risks at the suppliers Audit Scope Check adherence to the Code of Conduct for Siemens Suppliers (based on UN Global Compact principles, ILO conventions) and local legislation Supplier Scope Suppliers with identified potential risk related to sustainability Strategically important suppliers Execution Sustainability Audits Audits conducted by international qualified auditing companies Intertek and SGS. Goals & Benefits for the Supplier Risk awareness for Siemens and suppliers Identification of strengths/ weaknesses and enabling continuous improvement Active mitigation of sustainability related risks Supplier gets support by Siemens and external experts for performance improvement Improved relationship to Siemens and other customers Taking an active approach to ensure requirement fulfillment and legal compliance. Siemens AG 2013 All rights reserved. Page 6

7 The Audit Scope is based on the requirements of the Code of Conduct for Siemens Suppliers Requirements Legal compliance To comply with applicable legal system(s) Prohibition of corruption and bribery To tolerate no form of corruption and bribery Respect for basic human rights of employees To promote equal opportunities; no discrimination Prohibition of child labor Employ no workers under the age of 15 Health and Safety of employees To take responsibility for the health and safety of employees Environmental protection To minimize environmental pollution and make continuous improvements in environmental protection Supply Chain (2 nd tier suppliers) To promote among its suppliers compliance with the Code of Conduct See: Siemens AG 2013 All rights reserved. Page 7

8 Table of content 1 Program Background 2 Audit Process 3 Audit Scope and Checklist 4 Further Information Siemens AG 2013 All rights reserved. Page 8

9 Risk-based system of interlinked detection modules is in place Criteria Corporate Responsibility Self Assessment Regular supplier quality audit green No findings No findings yellow Minor deviations to the CoC 1) requirements 2) Minor findings with development measures Red Red result & no measure definition (3 months) or Red result & agreed corrective actions are overdue (2 months) KO-criteria Clearing by Sector Procurement External Sustainability Audit Risk Evaluation (Sustainability) Company-wide defined threshold Company-wide defined threshold Company-wide defined threshold Media Reports, other sources Reported breach of CoC 1) with high indicated risk Clearing by Corporate Procurement and Compliance Internal strategy decisions Management decision for External Sustainability Audit 1) Code of Conduct for Siemens Suppliers 2) Definition of measures Siemens AG 2013 All rights reserved. Page 9

10 External Sustainability Audits checks compliance and fosters continuous improvement Process Steps 1 Nomination of Suppliers for External Sustainability Audis 1 Audit scope suppliers 4 High Performance Suppliers 2 Initial audit / Full Re-audit is a full scope audit checking all criteria of the Code of Conduct for Siemens Suppliers. A Corrective Action Plan (CAP) is generated based on the findings in the audit. 3 5 Follow up audit Phase-out Initial audit External Sustainability Audit program ensures continuous improvement and sustainable implementation of defined corrective actions 2 3 The scope of the follow-up is determined by the defined Corrective Action Plan. Depending on the findings, the follow-up should at the latest be executed 9 months after the initial audit. Besides this, defined critical findings require immediate action and are treated individually with Siemens Management and the Supplier. If the follow-up is failed twice, the supplier is required to perform a full re-audit within 6 months of the last follow-up audit. (step 2) 4 If no corrective actions are defined in a initial/re-audit or all corrective actions are closed in a follow-up the supplier is no longer in the External Sustainability Audit program. Generally an audit is not conducted earlier then 2 years after last audit unless there are indications of nonconformance. 5 If a supplier does not manage to close all corrective actions within follow up audits and re-audit, 2 nd level escalation is conducted to decide on next steps (e.g. phasing out the Supplier) Siemens AG 2013 All rights reserved. Page 10

11 External Sustainability Audits follow a standard procedure Opening Meeting Factory inspection Employee Interview Review of Records Closing Meeting Commenced with factory management and related factory staff Request to review the business license Explanation of audit objectives scope, methodology and audit process Interview with top management about policies and Code of Conduct for Siemens Supplier topics Collect records and relevant documents Cross check between records / documents and the actual situation Taking photos if necessary Selection of interviewee by audit provider Conduct interview in a separate room provided by the supplier without factory management Assess compliance to the Code of Conduct for Siemens Suppliers by reviewing the documentation Cross check of the evidences collected during the audit Summarize audit findings and complete the audit summary Must held with factory management Discussion about findings not in compliance with the Code of Conduct for Siemens Suppliers Confirmation of the corrective action plan Signature by factory management and audit provider Siemens AG 2013 All rights reserved. Page 11

12 Table of content 1 Program Background 2 Audit Process 3 Audit Scope and Checklist 4 Further Information Siemens AG 2013 All rights reserved. Page 12

13 Violations against the Code of Conduct are classified following a consistent rating system The Code of Conduct is verified following a checklist of around 300 questions A Non-compliance is a specific breach of legal requirements or code, against which the supplier site is audited. Each finding is categorized, describing the urgency of correction Minor Major Critical An occasional or isolated problem. An issue which presents a low risk to workers/ those on-site. A policy issue or misunderstanding without evidence of a material breach A breach which represents a danger to workers/ those on-site. A material breach of a code requirement/ law. A systematic violation of a code requirement/ law. An issue which presents imminent risk to workers safety/risk to life and limb or constitutes a significant breach of workers human rights, A major non-compliance that has not been addressed or for which no significant improvement has been made by the time of a follow up audit, in spite of supplier commitment to resolve the issue. An attempt to pervert the course of the audit through fraud, coercion, deception or interference. Siemens AG 2013 All rights reserved. Page 13

14 External Sustainability Audits Content of audit checklist 1. Legal Compliance and Prohibition of Corruption and Bribery Intention Requirement Control The supplier needs to comply with the laws of the applicable legal system(s) No toleration of and no engagement in any form of corruption or bribery, including any payment or other form of benefit conferred on any government official for the purpose of influencing decision making in violation of law. Regular training in respect of important compliance issues Written instructions and guidelines Regular review of compliance programs or process, regular updating and information provided to employees Nominated Ombudsman Management interviews Document review Verification by checking contact data Siemens AG 2013 All rights reserved. Page 14

15 External Sustainability Audits Content of audit checklist 2. Management Systems Intention Requirement Control The facility should establish an effective management system which clearly defines and documents policy and procedures to ensure compliance with applicable laws and program requirements. The facility should have a method of measuring the program s effectiveness and a way of assessing its suppliers and subcontractors or their commitment to social compliance. Risk assessment related to social and environmental issues Policies, goals, procedures and responsibilities related to social and environmental issues Measures taken and resources allocated to ensure compliance (training, communication etc) Internal verification of compliance and achievement of goals by monitoring and management reviews Document review Employee interviews on policy awareness Siemens AG 2013 All rights reserved. Page 15

16 External Sustainability Audits Content of audit checklist 3. Forced Labor Intention Requirement Control Forced, bonded, indentured, or trafficked labor or involuntary prison labor must not be used. Also not allowed are any other activities that restrict freedom of movement, such as retaining worker-identification documents and monetary deposits, moving about the workplace, forced overtime, or being prevented from leaving at the end of the shift. Policies against forced labor available and employees trained Company does not lodge ID cards Workers are free to leave their jobs, the factory premises and dormitories No coercion by security staff Overtime working is voluntary Document review Employee interviews Management interviews Employment records Siemens AG 2013 All rights reserved. Page 16

17 External Sustainability Audits Content of audit checklist 4. Harassment & Abuse Intention Employees are to be treated with respect and dignity as laid out in clearly understood disciplinary procedures that forbid acts of bullying, the threat of physical abuse, sexual or other harassment, verbal abuse, monetary deductions, or other forms of intimidation of any kind. Requirement Fair disciplinary procedures and written rules communicated Wage deductions within legal regulations Channels for reporting harassment and abuse are effective and communicated to workers Control Verification of disciplinary procedures and cross check with employee interviews Employee, HR and management interviews checks on wage related records Siemens AG 2013 All rights reserved. Page 17

18 External Sustainability Audits Content of audit checklist 5. Discrimination Intention Companies should not engage in any form of employee discrimination in hiring, compensation, access to training, promotion, termination, or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership, disease, pregnancy, or political affiliation Requirement Equal pay; written description of qualification required for each position Recruitment and promotion based on qualification Effective channels to report discrimination confidentially No pregnancy test or other tests that could be used as discriminatory elements (e.g. HIV) Control Document review Employee interviews Management interviews Employment records Siemens AG 2013 All rights reserved. Page 18

19 External Sustainability Audits Content of audit checklist 6. Hours of work Intention Requirement Control Regular and overtime hours should comply with the legal limitations of the country or collective agreement with accurate and complete record-keeping. Employees should not be requested to work overtime on a regular basis and total hours should strive to be aligned with international-benchmark industry standards with ongoing continuous improvement. Employees are provided at least one day off following six consecutive days worked. Site introduces effective tools for productivity development and provide support to working hour reduction Process and system in place to check hours worked Appropriate meal breaks Plausibility check of production planning records and time records Time records Employee interviews Siemens AG 2013 All rights reserved. Page 19

20 External Sustainability Audits Content of audit checklist 7. Wages and Compensation Intention Requirement Control Wages, overtime pay, benefits and paid leave are provided to employees and at least meet or exceed legal minimum requirements and/ or collective-bargaining agreements (if applicable) with accurate and complete record-keeping. Employees should receive documentation with detailed wage information with each payment. Site maintains complete and consistent payrolls and monitors the payment Benefits such as maternity leave, annual leave, social insurance as per law Site does not employ part-time workers or workers on a semi-permanent contract to avoid allowances Overtime pay according to legal provisions Basic data, e.g. rates payable, number of hours worked, pay period, deductions are checked for at least the last 12 month Comparison of work contracts and time records Payrolls and employee interviews Siemens AG 2013 All rights reserved. Page 20

21 External Sustainability Audits Content of audit checklist 8. Freedom of Association Intention The facility should adopt an open attitude towards the activities of unions, employee representatives, or worker councils and give employees access to the workplace for the purposes of such activities without fear of reprisal. Employees have the right to join or form trade unions and to bargain collectively in accordance with local laws without prior authorization from management. Requirement No discrimination against workers representative Meetings with worker representatives and management Management must not interfere in union activities Control Check on complaint process and complaint mechanism and its effectivity Interview with employee representative Minutes of meetings Siemens AG 2013 All rights reserved. Page 21

22 External Sustainability Audits Content of audit checklist 9. Child Labor Intention Requirement Child labor is a violation of fundamental human rights and companies should not hire employees under the age established by law, or age 15 if there is no law. Special protections shall be in place for young employees under the age of 18. No overtime for young workers and consideration of legal requirements for protection of young workers No child labor Written policy and knowledge of local legislation at management level Effective recruitment procedure to detect worker s age before employment Control Employment records Knowledge check of HR/management representative on legislation Check availability of ID copies Remediation procedure for child labor according to local law Siemens AG 2013 All rights reserved. Page 22

23 External Sustainability Audits Content of audit checklist 10. Health and Safety Intention The workplace environment should be comfortable with safe and clean conditions like adequate controls to manage emergency preparedness. Residential facilities provided to employees should contain adequate living space, be clean and well maintained. Requirement Control Working conditions: sufficient lightning, acceptable noise level, air quality, temperature Hygiene canteens and food preparation areas, hygiene and sufficient toilets Safety of chemicals: safely stored, hazardous chemicals inventory, training of workers handling with chemicals Site observation Visit of dormitories Employee interviews to check the implementation level Document review Siemens AG 2013 All rights reserved. Page 23

24 External Sustainability Audits Content of audit checklist 11. Environment Intention The facility should be aware of the potential environmental impacts of its site and establish an effective environmental management system to better understand and comply with all environmental laws, regulations, and permits as they relate to solidwaste, hazardous-waste, wastewater, storm-water, and air emissions. Requirement Site has a system to track compliance of environmental laws Measures for continuous reduction or avoidance of pollution Product related environmental issues: Incidents and measures to ensure compliance Control documentation from municipalities to confirm with law Site observation investment plans Siemens AG 2013 All rights reserved. Page 24

25 External Sustainability Audits Content of audit checklist 12. Supply Chain Intention Suppliers are expected not only to comply with the Code of Conduct for Siemens Suppliers in their own organization but also to ensure in turn that their subcontractors adhere to the international standards summarized in the Code of Conduct for Siemens Suppliers Requirement Company has to encourage its suppliers to comply with the code of conduct Supplier has to take actions, if a violation against the code of conduct is identified at sub suppliers Control Management interviews Supplier contracts and supplier monitoring systems Documentation on actions Siemens AG 2013 All rights reserved. Page 25

26 Table of content 1 Program Background 2 Audit Process 3 Audit Scope and Checklist 4 Further Information Siemens AG 2013 All rights reserved. Page 26

27 Contact Contact Further Information Siemens AG Wittelsbacherplatz Munich Germany Sustainability at Siemens Public reporting on Supplier Audits Siemens Sustainability Report Supply Chain Management at Siemens Siemens AG 2013 All rights reserved. Page 27

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