The Apple Supplier Code of Conduct.

The Apple Supplier Code of Conduct (PDF) is based on standards created by the International Labor Organization, the United Nations and the Electronic Industry Citizenship Coalition (EICC). It requires suppliers to provide safe and healthy working conditions, to use fair hiring practices, to treat their workers with dignity and respect, and to adhere to environmentally responsible practices in manufacturing. But our Code goes beyond industry standards in a number of areas, including ending involuntary labour practices and eliminating underage labour. To make sure suppliers adhere to the Code, we have an aggressive compliance-monitoring program that includes Apple-led factory audits and corrective action plans, and confirmation that these plans have been carried out.

Apple and the Fair Labor Association.

In 2012, Apple became the first electronics company to be admitted to the Fair Labor Association (FLA), a coalition of universities, non-governmental organizations (NGOs) and businesses committed to improving the well-being, safety, fair treatment and respect of workers.

In February 2012, we asked the FLA to conduct special voluntary audits of our biggest final assembly suppliers, including Foxconn factories in Shenzhen and Chengdu, China. With unrestricted access to our operations, the FLA completed one of the most comprehensive and detailed assessments in the history of manufacturing — in scale, in scope and in transparency. This independent assessment covered an estimated 178,000 workers and included interviews with 35,000 workers.

On March 28, the FLA published detailed reports on what it found, with recommendations for improving conditions for workers. Apple and Foxconn accepted the FLA’s findings and recommendations and created a robust 15-month action plan with defined target dates of completion.

Since then, Apple and the FLA have been monitoring the progress of corrective actions, and at their last checkpoint, they found that Foxconn has implemented many changes ahead of schedule and the rest are on schedule for completion by July 1, 2013. Among the recommendations, Foxconn has engaged consultants to provide health and safety training for employees, improved its internship program and increased access to unemployment insurance for its migrant workers, as well as for all workers in Shenzhen.

How an Apple audit works.

An Apple auditor leads every onsite audit, supported by local third-party auditors who are experts in their fields. Each expert is trained to use Apple’s detailed auditing protocol. At each audited facility, the teams conduct physical inspections, interview workers and managers, and observe and grade suppliers based on more than 100 data points corresponding to each category of our Supplier Code of Conduct. We use this data not only to ensure compliance and sustainable improvement over time, but also to consider new programs that will meet the changing needs of our suppliers and their workers.

In addition to regularly scheduled audits, we conduct a number of surprise audits during which our team visits a supplier unannounced and insists on inspecting the facility within an hour of arrival. We conducted 28 of these surprise audits in 2012. During our regular audits, we may also ask a supplier to immediately show us portions of a facility that are not scheduled for review.

Audits around the world.

Since our first audits in 2006, we’ve expanded to more countries and more supplier categories. We’ve conducted audits in 14 countries, and in 2012, our audits covered nearly 1.5 million workers. We also perform audits in select nonproduction facilities, including call centres and warehouses. In addition, we conduct specialized audits focusing on areas such as the environment and safety.

We audit our final assembly manufacturers annually, and we audit other facilities based on certain risk factors, including location and geographic sensitivities, past audit performance and the nature of the facility’s work. Since many smaller suppliers have never been exposed to auditing, our audits often identify ways to enable operations to comply with our standards. This effort not only improves working conditions at these suppliers, it also helps improve conditions industrywide, since many of our peers use the same companies.

Core violations and corrective action.

Apple considers the most serious breaches of compliance to be core violations. These include physical abuse; underage, debt-bonded or forced labour; falsification of information or obstruction of audit; coaching workers for audits or retaliating against them if they provide information; bribery; significant pollution and environmental impacts; and issues posing immediate threat to workers’ lives or safety. All core violations must be stopped and corrected immediately. Our preference is to fix problems so they don’t happen again rather than just fire the supplier — which would likely let these violations continue for other customers. However, if a violation is particularly egregious, or if we believe a supplier is not fully committed to stopping the behaviour, we terminate our relationship with that supplier and, when appropriate, report the behaviour to the proper authorities.

Workplace ethics and protection for whistle-blowers.

To conduct a thorough audit, suppliers must give our auditors access to factories and provide them with accurate documents and record-keeping processes for review. Our auditors are skilled in identifying circumstances where a supplier may be providing false information or preventing access to critical documents — both of which are core violations of our Supplier Code of Conduct. Coaching workers on what to say during an interview and retaliation against workers for participating in an audit interview are also core violations.

An auditor interviews a worker at a facility in Vishay, China. At these confidential interviews, auditors verify identification and legal status, and they ask workers about conditions at the facility.

After an audit interview, each worker receives a hotline card with case numbers to identify the facility and audit date. This gives the worker a private opportunity to provide additional information to our team or report any unethical consequences as a result of the interview — an action for which we have zero tolerance. When we receive calls, we follow up with suppliers to make sure each issue is properly addressed. In addition, our authorized third-party partner made more than 8000 phone calls in 2012 to workers interviewed by auditors to find out if retaliation or other negative consequences had resulted from the interview.