2. Supplier Assessments, On-site Audits and Social Responsibility Audits
All of Corning’s suppliers must agree to act in accordance with the principles and requirements of our Supplier Code of Conduct, which includes Corning’s right to assess and audit suppliers for such compliance. Corning supply management professionals leverage a variety of tools, including report cards, quarterly business reviews and supplier performance management to ensure Corning’s suppliers meet and exceed our customer and industry standards.
a) Supplier Assessments
A web-based tool is used to conduct internal assessments of the systems, products, and processes of strategic suppliers based on industry standards and the Corning quality framework. Corning uses a consolidated and consistent template for these assessments, which addresses a wide range of criteria, including social responsibility drivers (e.g., forced labor, child labor and human trafficking), environmental factors, sustainability, health and safety, quality, and performance. Once Corning assesses the supplier’s performance, as defined by the supplier performance assessment process, we share the results with participating suppliers and schedule follow-up meetings to develop corrective action plans that include specific performance improvement goals. Supplier performance is reviewed periodically throughout the year to assess progress to plan and remediation is pursued, if appropriate. In 2019, 100% of Corning’s most strategic suppliers were evaluated through this assessment process. In 2020, Corning’s goal is to extend supplier assessments to the remainder of our top suppliers, representing 80% of Corning spend, by year-end.
b) On-site Audits
A key component of our Supplier Relationship Management process is supplier on-site audits, which are being expanded to include social responsibility in 2020.
Corning supply chain professionals conduct periodic on-site audits for strategic suppliers. These audits utilize standardized templates based on industry standards. A key component of our supplier assessment and audit process is the development of corrective action plans to remedy non-compliance. These plans are designed to bring the supplier in compliance within a defined timeframe. While working within a corrective action plan, a supplier will be subject to frequent progress reviews.
c) Social Responsibility Audit
Corning has a comprehensive audit program for its highest risk strategic Suppliers, which includes a specific focus on contract manufacturers, where Corning has determined the risk of human trafficking in its supply chains to be the highest, given the nature of such operations.
Corning has developed a matrix to identify high-risk countries which is based upon (i) the Amfori 6 factors (https://www.amfori.org/resource/countries-risk-classification) and (ii) a third-party tool, riskmethods, which is a supply risk profile/rating solution that utilizes 49 risk indicators to identify potential risks.
Audits are conducted using Responsible Business Alliance (RBA) standard principles and performed by selected APSCA certified third-party auditors chosen from RBA’s approved audit firms, with reassessments to follow on a two-year cycle thereafter. Based on the results, improvement plans for mitigation and training are developed, and follow-ups are scheduled. Insufficient remediation may result in contract termination.
In 2017, Corning implemented an on-going, in-depth third-party audit process beginning with 100% of our highest risk suppliers, and remediation of findings from these audits continued through 2018. We expanded these audits in 2019 to encompass a portion of our medium-risk suppliers. In 2020, Corning will reassess strategic suppliers and expand audits to additional medium risk suppliers.
The on-site audit process includes:
1. Supplier Self-Assessments – Supplier completes a self-assessment questionnaire prior to an on-site visit.
2. On-site Visit from Corning Auditors – On-site meetings occur prior to the third-party audit and includes the development of an audit plan and audit onboarding. If a supplier score from the self-assessment and on-site visit does not meet expectations based on RBA standards, the supplier is notified, and corrective actions are taken by the supplier and tracked/verified by Corning prior to the third-party audit.
3. Third-Party Audit – Third party auditors conduct an extensive on-site audit that includes assessments related to social responsibility. The on-site audit consists of management interviews, site observations (facility walk-throughs) and document reviews (e.g. human rights, child labor, human trafficking, health and safety, working hours), as well as off-site employee interviews.
a. Employee Interviews (off-site): The number of employees interviewed is defined by RBA standards. The interviews are conducted privately, off-site, without the presence of managers, or other staff, and worker responses are confidential. Senior managers must agree to encourage workers to be open and honest during interviews. Managers are also required to actively protect any interviewed worker from retaliation.
b. Site Observations: A review of “living facilities of workers” is required by auditors during the site observations. The related areas that are reviewed are: dormitories (including hostels and off-site housing, if company or labor agent owns/rents accommodation), canteens and kitchens, toilets and sanitation, and recreational facilities.
4. Corrective Action Plans – A key component of our supplier assessment and audit process is the development of corrective action plans to remedy non-compliance in the areas of social responsibility (e.g., labor and human trafficking), environmental sustainability, health and safety, quality, and performance. Based on the findings of the third-party audit, these plans are created by Corning, in collaboration with our third-party auditors and the supplier’s Corporate Social Responsibility lead and senior management, to ensure the supplier meets or exceeds Corning’s corporate social responsibility requirements. These plans are designed to bring the supplier into compliance within a defined timeframe. While working within a corrective action plan, a supplier will be subject to frequent progress reviews. Corrective action plans for the highest risk suppliers are reviewed with senior corporate leadership, including the Corporate Risk Council.
If a supplier does not make sufficient progress, outcomes can include:
• Special projects to remedy compliance problem
• Warning letter
• Third-party investigation
• Stop-work notices
• Termination of working agreements
5. Corporate Social Responsibility (CSR) Training – Corning and/or a third-party hold a training summit to present Corporate Social Responsibility to all identified suppliers to discuss the criteria and overall outcome of the Social Responsibility Audit. Best practices, strategies, and tactics to improve and mitigate social responsibility practices and risks (including the topics of forced labor, child labor and human trafficking) are shared and discussed to ensure alignment with Corning values and expectations.
6. Follow-up – Corning conducts regularly scheduled meetings (daily/weekly) with suppliers to assess progress against the remediation plans, and follow-up is managed by certified Corning auditors. Closure is completed by the third-party auditors to maintain consistency and fairness.