Accountability

All Corning suppliers must agree to act in accordance with the principles and requirements of our Supplier Code of Conduct, which includes Corning’s Human Rights Policy. To ensure compliance and identify and mitigate social responsibility risks in the supply chain, Corning has developed a comprehensive supplier management process. This process, which leverages a suite of technology platforms and internal processes, enables us to closely monitor operations, capture data and share supply chain information faster, more efficiently, and accurately. Corning takes steps to evaluate, assess, and verify potential risks in our supply chain through our supplier selection, onboarding, and ongoing management processes. Corning uses these processes to ensure that our supply base meets and exceeds internal and external customer expectations relative to performance, social responsibility, and risk management.

Corning conducts responsible and sustainable procurement practices to encourage good labor practices and reduce the risk of human trafficking and forced labor with the supply chain.  For example:
 

• 97% of small disadvantaged suppliers are paid in 60 days or less
• Average length of contracts is two years
• Only 15% of all orders are changed after an order is placed

1. Supplier Selection/Onboarding

Corning’s risk management process begins before companies join our supply chain. Suppliers identified in high risk countries are screened via our third-party risk tool for 49 risk elements, including social responsibility, which includes forced labor and child labor practices and human rights.

In 2015, Corning established a single, standard global process for supplier onboarding. As part of this centralized process, all new suppliers must be approved by our supply management professionals as part of the supplier onboarding process. One of the many benefits of this centralized process has been a decrease in the total number of suppliers added to our supplier base, which has allowed for more robust oversight of new suppliers. Additionally, Corning continues to improve existing processes and to implement new ones to ensure a socially responsible supply chain.

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.

3. Corporate Social Responsibility on-site audit results:

Corning has seen significant improvement in the CSR audit scores, improving from an average of 5 for the initial audit score to an average of 94 currently.  Detailed results of Corning’s supply chain on-site social responsibility audits identified risks within the following areas:

1. A3.1 Hours worked in a workweek over the last 12 months does not exceed 60 hours.
2. A3.2 Workers receive at least one (1) day off every seven (7) days
3. B2.2 Adequate and effective fire detection, alarm and suppression systems are in place
4. B2.4 Effective emergency exit access, exits, and exit discharge are adequate in number and location, readily accessible, and properly maintained
    

In response, Corning collaborated with suppliers to take appropriate actions to successfully address these risks.  Actions taken varied according to the need, but ranged from the implementation of an attendance management system and training for workers and managers in order to provide visibility to manage hours/days worked per week to address items 1 and 2, to the installation of safety exit signs, emergency lighting, and alarm bells and other safety measures to address items 3 and 4.

In alignment with Corning’s commitment to continuous improvement, we proactively work with suppliers to monitor and evaluate the effectiveness of corrective actions.  As such, while we have made great progress in responding to human rights risks and impacts (see chart below showing supplier score improvements), we do not feel we have achieved satisfactory score with all suppliers therefore, efforts continue to identify and take action on opportunities for improvement.
 

4. Ongoing Corning Social Responsibility Training

In 2020, Corning will launch awareness training for its strategic preferred suppliers to re-enforce our Supplier Code of Conduct, which includes slavery and human trafficking, to ensure Corning’s supply chains reflect our values and respect for human rights as identified in our Supplier Code of Conduct and Statement on Efforts to Combat Human Trafficking and Slavery.