Responsible Supply Chain

Western Digital is committed to advancing its corporate social and environmental responsibility (CSER) within our internal operations and with our global suppliers.  We continue to be an active member of the Responsible Business Alliance (RBA) and to subscribe to the RBA Code of Conduct.  As part of our commitment, and as a condition of RBA membership, we require global production parts (PP) suppliers and contract manufacturers (CMs) that support the manufacture of Western Digital products (including WD, SanDisk, HGST and other brands) to meet the following requirements:

  • Commit to and have policies and programs in place for complying with the RBA Code of Conduct and demonstrate that they have implemented an effective process to communicate the Code's requirements to their next tier suppliers.
  • Register for RBA Online and complete an RBA self-assessment questionnaire (SAQ) for the facilities that support Western Digital products.
  • Authorize Western Digital to access their RBA facility SAQs that they've uploaded to RBA Online and any Validated Audit reports for their facilities that support the manufacture of Western Digital products.

Additionally, Western Digital requires major PP suppliers and contract manufacturers to also meet the following additional requirements:

  • Undergo an RBA Validated Assessment Process (VAP) Audit every two years and implement corrective action plans for any findings in accordance with RBA timelines.
  • Obtain certification to the most updated revision of ISO 14001 (Environmental) and OHSAS 18001 (Occupational Health & Safety), or ISO 45001 Management System standards.

Responsible Minerals Policy
Western Digital strongly disapproves of the violence, unsafe working conditions and child labor in the Democratic Republic of Congo (DRC), adjoining countries and other conflict-affected or high-risk areas. Western Digital is committed to supporting responsible sourcing of conflict minerals (gold, columbite-tantalite (also known as coltan), cassiterite, and wolframite, as well as their derivatives, tin, tantalum and tungsten (collectively 3TG)), cobalt and other minerals from the DRC region (including conformant smelters within the DRC) and other conflict-affected or high-risk areas. Western Digital is committed to source responsibly and will consider suspending or discontinuing engagement with suppliers where it identifies a reasonable risk. Western Digital conducts due diligence in line with OECD Guidance.

Western Digital expects its suppliers to comply with its requirements relating to conflict minerals and responsible sourcing. This means (1) any 3TG necessary to the functionality and production of supplied materials do not directly or indirectly: (a) finance armed groups through mining or mineral trading in the DRC, adjoining countries or other conflict-affected or high-risk areas, or (b) contribute to child labor, human rights abuses or environmental pollution; or (2) any 3TG in supplied materials are from recycled or scrap sources. Western Digital also expects its suppliers to responsibly source all minerals, including cobalt, from the DRC, adjoining countries and other conflict-affected or high-risk areas. Western Digital further expects its suppliers to adopt policies based on OECD Guidance with respect to 3TG, cobalt and other minerals in support of this policy and, throughout the supply chain, to require their suppliers to adopt similar policies. Western Digital works with other stakeholders, collaborating with industry working groups, customers and suppliers to drive and align on the responsible sourcing of minerals more broadly.

Western Digital’s major production parts suppliers and contract manufacturers must meet additional requirements, including undergoing a Validated Assessment Program audit conducted by the Responsible Business Alliance. Western Digital requires contract provisions in support of this policy with its suppliers and contract manufacturers, which govern their relationships with refiners and smelters that contribute to Western Digital products. Western Digital also has an Ethics Helpline that is available for employees, suppliers and other stakeholders in the supply chain to raise concerns. Western Digital’s Board of Directors oversees the company’s corporate responsibility and sustainability program, including with respect to human rights.

For additional information on Western Digital’s policies and procedures, including due diligence, see the Conflict Minerals Report and Sustainability Report.

Due Diligence Program
We have established and maintain a responsible supply chain due diligence program designed to ensure responsible sourcing of 3TG used in our products.  This includes ongoing communication and engagement with our global production parts suppliers to ensure sustained due diligence in the sourcing of minerals used in our products.  We are also active members of the Responsible Minerals Initiative (RMI) and we participate in various working groups dedicated to advancing responsible minerals sourcing.  More information about RMI and its programs is available at: http://www.responsiblemineralsinitiative.org/.