California Senate Bill 657

NetApp Statement on Human Trafficking

NetApp is a company that is guided by a set of company values that includes trust and integrity and creating a model company.  Part of creating a model company includes a commitment to conducting business in a socially and environmentally responsible manner. The purpose of this statement is to reaffirm the Company’s position regarding the California Transparency in Supply Chains Act of 2010 (Section 1714.43 of the California Civil Code). This act requires retail and manufacturing companies to disclose their efforts to ensure that their supply chains are free from slavery and human trafficking.

Statement

  • NetApp has adopted a Supplier Code of Conduct that incorporates and adopts the operating principles of the Electronics Industry Code of Conduct (the “Supplier Code of Conduct”), which includes a prohibition on human trafficking and slavery. NetApp provides its Supplier Code of Conduct to its suppliers and expects them to review and comply with its operating principles.
  • NetApp employees and management who are directly responsible for supply chain management are involved in the implementation of the Supplier Code of Conduct.
  • NetApp has conducted an initial assessment of its top suppliers to identify the risks of non-compliance with the EICC Code, including the actual or potential risks of slavery and human trafficking occurrences. Results of that assessment indicated a low risk of human trafficking and slavery in NetApp's supply chain. NetApp has not engaged any independent third parties to verify these conclusions regarding its supply chain.
  • We expect NetApp’s top-tier suppliers to assess their conformance with the tenets of the Supplier Code of Conduct with the completion of a Self Assessment Questionnaire for all facilities providing NetApp with products or components.  The supplier must provide NetApp with access to its completed questionnaire and, if requested, support a site audit by NetApp or its representative. 
  • NetApp may also request that its suppliers provide evidence that their policy or principles are aligned with both our Guiding Principles, which includes the principles that the supplier (i) operate ethically and in compliance with applicable laws, (ii) value employees, embrace diversity and promote a fair and respectful workplace and (iii) be an asset to communities where we operate by supporting educational and critical community needs.
  • NetApp has also adopted a Code of Business Conduct and Ethics (the "NetApp Code of Conduct"), which states that NetApp holds its suppliers to the same high standards to which we hold ourselves. NetApp expects that anyone who conducts business on our behalf will operate ethically, in compliance with the law, and in a manner that is consistent with the standards of the NetApp Code of Conduct and our policies.  NetApp requires all employees and management, including those who are directly responsible for supply chain management, to complete trainings and certifications of the NetApp Code of Conduct.  NetApp maintains internal accountability standards for employees who fail to meet NetApp's business standards such as the NetApp Code of Conduct.