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| 1. Does the brand (company) have a policy that excludes smelters of conflict minerals by only sourcing minerals from conflict free areas or by only sourcing minerals from conflict areas when human rights are respected and where contributing to conflict is avoided? |
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Dell states to exclude smelters of conflict minerals by refraining from purchasing from any known conflict sources and by being active in the EICC conflict-free smelter program (see link). |
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| 2. Does the brand (company) have a Code of Conduct (CoC) for both its own factories and those of its suppliers, which includes the following standards: No forced or slave labor, no child labor, no discrimination of any kind and a safe and hygienic workplace? |
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Dell uses the EICC Code of Conduct, in which all standards are mentioned (for Code of Conduct, see next question). |
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| 3. Does the brand’s (company’s) CoC include at least 3 of the following workers rights: 1. a formally registered employment relationship 2. a maximum working week of 48 hours with voluntary paid overtime of 12 hours maximum 3. a sufficient living wage 4. form and join labor unions and bargain collectively; and in those situations where these rights are restricted under law, to develop parallel means? |
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1. Not mentioned; 2. No, the CoC states a maximum of 60 hours per week but does not specify how many are overtime; 3. No, wages must comply with applicable wage laws but does not mention a living wage; 4. No, this right is mentioned but a parallel means in situations where these rights are restricted under law is not mentioned. |
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| 4. Does the brand (company) have a published list of direct suppliers that have collectively contributed to more than 90% of the purchase volume? |
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Dell provides a list of 95% spend and key supply chain partners. |
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| 5. Is the brand (company) a member of a multi stakeholder initiative (MSI), wherein independent NGO’s or labor unions are represented, that collectively aims to improve labor conditions and that carries out independent audits? Or does the brand (company) significantly purchase its supplies from factories certified by such MSI’s? |
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Dell is an implementation partner of the Dutch Sustainable Trade Initiative (IDH) Electronics program, which is an MSI that aims to improve the working conditions of factory laborers, and wherein NGO's are represented. |
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| 6. Does the brand (company) annually report on the results of its labor conditions policy? |
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Dell mentions performing audits but does not publish the results (see p. 32). |
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| 7. Has the brand’s labor conditions policy resulted in a ‘compliance level’ of at least 30% of the purchase volume, or a ‘monitored level' of at least 80%? |
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See remark for labor conditions question 6. |
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