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 more than 50 risk elements. Potential suppliers are screened to monitor corporate social responsibility areas, which includes the monitoring of potential forced labor, child labor and/or human rights violations.

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. 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:

100% of high-risk contract manufacturers (CMs) are audited by a third-party auditor per the Responsible Business Alliance (RBA) standard. A partial list of medium-risk CMs are also audited.  

Supply Chain Monitoring

Average Human Rights Scoring

 Average Human Rights Scoring (out of 200) in contract manufacturing audits
 

How we work with suppliers

On-site supply chain social responsibility audits identified risks in 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 varied according to need, ranging from implementation of an attendance management system and training for workers and managers to effectively manage hours/days worked per week for items 1 and 2 to the installation of safety exit signs, emergency lighting, alarm bells, and other safety measures for items 3 and 4.

On recruitment fees and risks related to worker documents being withheld, we take immediate steps to investigate and successfully address such issues when they arise. Specifically, we enlist our third-party audit partners to appropriately engage the workers that have been affected to determine an appropriate course of action and ensure identification documents are returned and recruitment fees are repaid. We also take lessons from these instances to continuously improve Corning’s standards and approaches to responsible recruitment, including updating our Supplier Code of Conduct, training our own employees on responsible recruitment, and applying key lessons across our supply chain.

Corning uses a consistent process to help our suppliers improve their performance related to human rights:

1. Step-by-step guidance is provided to suppliers by a Corning CSR Subject Matter Expert (SME) through communication meetings, trainings, and/or follow-up meetings to identify gaps and/or root causes of specific issues and collaboratively brainstorm solutions.
2. An improvement plan is established in a joint session between the supplier nd the Corning SME.
3. The supplier performs a self-assessment and submits results for review by Corning.
4. A pre-assessment audit is conducted by a Corning SME prior to a formal third-party audit.
    

In alignment with Corning’s commitment to continuous improvement, we proactively work with suppliers to monitor and evaluate the effectiveness of corrective actions. Corning has seen significant improvement in total CSR audit scores (which include the Human Rights scores shown above), increasing from an initial average of 48 out of 200 to an average of 134 out of 200 in 2021.  While we have made great progress in responding to CSR risks and impacts (see Supplier Score Improvements table below), we do not feel we have achieved satisfactory score with all suppliers. Therefore, efforts continue to identify and act on opportunities for improvement.
 

Supplier Score Improvements

Commitment on Living Wage

Currently, Corning assesses supplier compliance to minimum wage. We will begin living-wage audits in 2022.
 

Commitment on Freedom of Association and Collective Bargaining

Questions about freedom of association and collective bargaining are included in Corning CSR audits. We have never found a violation, but if we do, remediation will be required.
 

Commitment on Child Labor and Young Workers

Child Labor and Young Worker Findings

Corning has not encountered any child labor issues while auditing suppliers, but has found cases of young workers (age 16-18) working overtime and/or night shifts, which violates the RBA requirements. Corning initiated the following actions with the supplier:

1. Requested immediate action to remove young worker from the overtime or night shift situation.
2. Organized communication sessions with the impacted worker, their supervisor, and management.
3. Reviewed HR procedures with management and updated those policies and procedures to ensure ongoing compliance.
4. Requested a self-assessment by the supplier regarding this finding.
5. Conducted a follow-on pre-assessment audit to validate actions taken by supplier prior to a formal third-party audit.
   
    

Commitment on Health Fees

Corning has encountered cases where workers were required to cover the cost of onboarding health-check fees in 2019, 2020, 2021. Fees ranged between USD $6-$25.

Corning initiated the following remediation plans with identified suppliers and requested corrective actions:

1. Revision of recruiting process/procedures
2. Reimbursement of the fees to the impacted workers
3. Establishment of a solution in collaboration with the supplier to sign a contract with a third-party health-check company to ensure health-check fees will be paid directly by the company.
    

Corning is highlighting the onboarding health-check fee issue along with latest RBA requirements, which were tightened in 2020, in CSR training with suppliers starting in Q4 2014.
 

Commitment to Women's Rights

Findings on Women's Rights

Corning has encountered a few cases that were in violation of women's rights expecations, such as  missing risk analysis for pregnant women and nursing mothers, lack of nursing room availability, or lack of refrigerator or washing facilities inside nursing rooms.

Corning initiated actions in collaboration with the suppliers to address the issues, ensuring that the suppliers:

1. Establish general policies and procedures to minimize the Health & Safety impact to pregnant woman and nursing mothers.
2. Perform risk analysis to identify any work positions unsuitable for pregnant woman and nursing mothers.
3. Provide reasonable accommodations for nursing mothers that include wash facilities and a refrigerator.

4. Ongoing Corning Social Responsibility Training

We have performed two training sessions in which forced labor topics were covered and highlighted:

• In June 2018, classroom training was provided by a third party to major contract manufacturers associated with Corning^® Gorilla^® Glass products. 
• On Dec. 15, 2020, online training was provided to contract manufacturers across all business units by third party trainers and Corning.
• In 2021, a Supply Chain Social Responsibility eLearning Program was developed. Over 300 suppliers participated in the e-learning and completed the assigned courses.
   

In 2022, a CSR refresh training is planned for our contract manufacturers and suppliers highlighting the updated requirements of the RBA standard.