Micron and our stakeholders support the advancement of human rights along our value chain.
Our Code of Business Conduct aligns with the RBA code of conduct, which explicitly states that child labor and forced labor are not permitted in any stage of the business. Factories are regularly audited for conformance to these standards, and our human rights policy requires employees to be 16 or older. Micron actively works to uphold the highest level of labor ethics in our own operations, and we also expect our suppliers, contractors and joint venture partners to adhere to our Code and child labor and forced labor laws. During 2018, we worked to articulate our perspective through a new human rights policy published in early 2019.
Our commitment to these concerns is made public through our Slavery and Human Trafficking Statement. As part of our ongoing due diligence in this area, we regularly conduct supplier risk assessments to understand how well suppliers address the issues, with specific focus on operations in areas more at risk for human rights violations. Beyond these important issues, Micron also monitors the following human rights concerns as they relate to our supply chain:
The best outcomes happen when our industry works together. The RBA plays a critical role in upholding a single set of expectations regarding social and environmental responsibility and a single process for demonstrating conformance. Through RBA training materials, monitoring tools and third-party audits, we are able to support the efforts of our key suppliers to maintain responsible operations. We can also hold them accountable when they veer off course. To comply with the RBA code in our own operations, we have adopted a vigorous management approach that includes training employees on the code requirements and using third-party auditors to verify our actions. Our global RBA oversight team includes representatives from legal, human resources, EHS and supplier management functions. They monitor key RBA metrics across all of our manufacturing locations and review quarterly reports on Micron’s overall RBA performance.
This oversight of human rights begins with anyone who works on a Micron site in any capacity, from security to construction work. It extends to the employees of our suppliers and to any person hired temporarily by suppliers, who in some parts of the world are foreign migrant workers. Many of Micron’s suppliers are located in Asia, where human rights violations against these workers have been documented. For example, workers may have their passports withheld or be charged recruiting or administrative fees before being hired. These fees can amount to more than several months’ pay and may require workers to take out loans, effectively forcing them to pay to have a job. In addition, most of these workers send the majority of their earnings back to their home countries to support their families, making the payment of loans and fees especially burdensome.
The RBA code of conduct requirements limiting forced labor differ from the laws regarding fees, levies and working hours in many countries where we do business. While this adds complexity, we enforce the more stringent standard if local laws and the RBA code differ. Micron is actively involved, along with other members of the RBA, in eliminating forced labor issues in our supply chain through training, dialogue with government officials and interviews with foreign migrant workers about their conditions.
Micron is currently working with the RBA and several suppliers in Taiwan to better understand foreign migrant workers’ experiences and address any violations that may be occurring in these locations. During an assessment of two of these suppliers in 2018, we found that they do not charge fees to these workers and do not have issues related to working hours. As part of the assessment, we discovered some dorm overcrowding at one supplier site due to an increase in workers. We expect this supplier to make improvements promptly to its workers’ living conditions. Micron will continue to investigate foreign worker journeys from home country to working country among our key suppliers and address any forced labor violations. By undertaking efforts beyond internal training and moving toward greater understanding of the risk profile of each facility, Micron can stay ahead of any issues that may arise in our supply chain.