Corporate Human Rights Benchmark

2022 Company Scoresheet

Company Name Apple

Industry ICT (Supply Chain only)
Overall Score 31.6 out of 100

Theme Score Out of For Theme

2.8 10 A. Governance and Policies
5.3 25 B. Embedding Respect and Human Rights Due Diligence
9.5 20 C. Remedies and Grievance Mechanisms
8.7 25 D. Performance: Company Human Rights Practices
5.2 20 E. Performance: Responses to Serious Allegations

Please note that any small differences between the Overall Score and the added total of Measurement Theme scores are due to
rounding the numbers at different stages of the score calculation process.

Please note also that the "Not met" labels in the Explanation boxes below do not necessarily mean that the company does not
meet the requirements as they are described in the bullet point short text. Rather, it means that the analysts could not find
information in public sources that met the requirements as described in full in the CHRB 2022 Methodology document for the
sector concerned. For example, a "Not met" under "General HRs Commitment", which is the first bullet point for indicator A.1.1,
does not necessarily mean that the company does not have a general commitment to human rights. Rather, it means that the
CHRB could not identify a public statement of policy in which the company commits to respecting human rights.

Detailed assessment
A. Governance and Policies (10% of Total)
A.1 Policy Commitments (5% of Total)
Indicator Code Indicator name Score (out of 2) Explanation
A.1.1 Commitment to The individual elements of the assessment are met or not as follows:
respect human Score 1
rights • Met: International Bill of Human Rights: The Company states in its Human Rights
Policy: 'We’re deeply committed to respecting internationally recognized human
rights in our business operations, as set out in the United Nations International Bill
of Human Rights and the International Labour Organization’s Declaration on
Fundamental Principles and Rights at Work.' [Human Rights Policy, 08/2020:
s2.q4cdn.com]
Score 2
1
• Not Met: Commitment to the UNGPs: In addition, in its Human Rights Policy, it
indicates: 'Our approach is based on the UN Guiding Principles on Business and
Human Rights.' However, to be 'based on' is not considered a formal statement of
commitment according to CHRB wording criteria. This subindicator looks for a
formal commitment to follow the UNGPs or respect human rights as set out in this
document, acting in accordance to these principles. [Human Rights Policy, 08/2020:
s2.q4cdn.com]
• Not Met: Commitment to the OECD Guidelines for Multinational Enterprises
[Supplier Responsibility 2020 Progress Report, 05/2020: apple.com]
A.1.2.a Commitment to The individual elements of the assessment are met or not as follows:
respect the Score 1
human rights of • Met: Company has a commitment to the ILO Core: The Company states in its
Human Rights Policy: 'We’re deeply committed to respecting internationally
workers: ILO 0.5
recognized human rights in our business operations, as set out in the United
Declaration on
Nations International Bill of Human Rights and the International Labour
Fundamental Organization’s Declaration on Fundamental Principles and Rights at Work'. [Human
Rights Policy, 08/2020: s2.q4cdn.com]
Indicator Code Indicator name Score (out of 2) Explanation
Principles and • Not Met: Company has a explicit commitment to All four ILO Core: The Company
Rights at Work indicates in its Human Rights Policy: 'At Apple and throughout our supply chain, we
prohibit harassment, discrimination, violence, and retaliation of any kind'.
Although, the Company commits to respect recognized human rights as set out in
the International Labour Organization's Declaration on Fundamental Principles and
Rights at Work, no explicit statement committing, by name, to each of the areas
covered by the Fundamental Conventions: Forced Labour, child labour,
discrimination, freedom of association and collective bargaining.
[Human Rights Policy, 08/2020: s2.q4cdn.com]
Score 2
• Met: Company expect suppliers to commit to ILO Core: In its Supplier Code of
Conduct, the Company indicates that 'Apple suppliers shall uphold the highest
standards of human rights.', and include provisions for each of discrimination,
forced labour, child labour, freedom of association and collective bargaining. In
relation with these last two, it requires that 'Supplier shall freely allow Workers’
lawful rights to associate with others, form and join (or refrain from joining)
organizations of their choice, and bargain collectively, without interference,
discrimination, retaliation, or harassment.' [Supplier Code of Conduct & Standards,
01/2022: apple.com]
• Met: Company explicitly list All four ILO for suppliers: In its Supplier Code of
Conduct, the Company indicates that 'Apple suppliers shall uphold the highest
standards of human rights.', and include provisions for each of discrimination,
forced labour, child labour, freedom of association and collective bargaining. In
relation with these last two, it requires that 'Supplier shall freely allow Workers’
lawful rights to associate with others, form and join (or refrain from joining)
organizations of their choice, and bargain collectively, without interference,
discrimination, retaliation, or harassment.' In its Supplier Responsible Standards,
they also indicate that 'Where Applicable Laws and Regulations substantially
restrict freedom of association, Supplier shall allow alternative means for Workers
to individually and collectively engage with Supplier, including processes for
Workers to express their Grievances and protect their rights regarding working
conditions and terms of employment'. [Supplier Code of Conduct & Standards,
01/2022: apple.com]
A.1.2.b Commitment to The individual elements of the assessment are met or not as follows:
respect the Score 1
human rights of • Met: Commitment to respect H&S of workers: The Business Conduct Policy states
that 'Apple is committed to protecting the environment, health, and safety of our
workers: Health
employees, customers, and the global communities where we operate'. [Business
and safety and
Conduct Policy, 10/2020: apple.com] & [Environmental Health and Safety Policy
working hours Statement, 03/2013: images.apple.com]
• Not Met: Respect ILO labour standards on working hours or Commits to 48 hours
regular work week
Score 2
• Met: Expect suppliers to commit to H&S of their workers: The Supplier Code of
Conduct indicates: 'Supplier shall provide and maintain a safe work environment
0.5
and integrate sound health and safety management practices into its business.
Workers shall have the right to refuse unsafe work and to report unhealthy working
conditions'. [Supplier Code of Conduct & Standards, 01/2022: apple.com]
• Met: Expect suppliers to commit to ILO labour standard or to 48 hours regular
work week: The Supplier Code includes the following: 'A workweek shall be
restricted to 60 hours, including overtime, and workers shall have at least one day
off every seven days except in emergencies or unusual situations. Regular
workweeks shall not exceed 48 hours. Supplier shall follow all applicable laws and
regulations with respect to working hours and days of rest, and all overtime must
be voluntary'. It also indicates that 'supplier shall compensate workers for overtime
hours at the legal premium rate'. [Supplier Code of Conduct & Standards, 01/2022:
apple.com]
A.1.3.a.ICT Commitment to The individual elements of the assessment are met or not as follows:
respect human Score 1
rights • Met: Responsible mineral sourcing: In its Conflict Minerals Report 2021, the
Company states: 'Apple does not directly purchase or procure primary sourced
particularly
minerals from mine sites. We are, however, committed to both meeting and
relevant to the
2 exceeding internationally-accepted due diligence standards for primary minerals
industry – and recycled materials supply chains.. [...] Conducting human rights due diligence in
responsible alignment with the Organisation for Economic Co-operation and Development
sourcing of (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from
minerals (ICT) Conflict-Affected and High-Risk Areas (2016) and related Supplements (the “OECD
Due Diligence Guidance”) and the United Nations Guiding Principles on Business
Indicator Code Indicator name Score (out of 2) Explanation
and Human Rights (“UN Guiding Principles”) is the foundation of Apple’s
responsible sourcing program for primary sourced minerals, and informs Apple’s
due diligence program for recycled minerals'. This SD report is considered a proxy
for policy statements under CHRB revised approach. [Conflict Minerals Report
2021, 2022: apple.com]
• Met: Based on OECD Guidance: As indicated above, 'We are, however, committed
to both meeting and exceeding internationally-accepted due diligence standards
for primary minerals and recycled materials supply chains.. [...] Conducting human
rights due diligence in alignment with the Organisation for Economic Co-operation
and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains
of Minerals from Conflict-Affected and High-Risk Areas (2016) and related
Supplements (the “OECD Due Diligence Guidance”)'. This SD report is considered a
proxy for policy statements under CHRB revised approach. [Conflict Minerals
Report 2021, 2022: apple.com] & [Supplier Code of Conduct & Standards, 01/2022:
apple.com]
• Met: Requires suppliers to commit to responsible mineral sourcing: In its Supplier
Responsibility Standards, the Company indicates: 'Suppliers shall develop an
appropriate management system to conduct due diligence in accordance with the
standards set out in the OECD Due Diligence Guidance for Responsible Supply
Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD
Guidance”) and other applicable international standards [...]'. [Supplier Code of
Conduct & Standards, 01/2022: apple.com]
Score 2
• Met: Commits to follow OECD Guidance for all minerals: The Conflict Minerals
Report states that 'Apple does not directly purchase or procure virgin raw minerals
from mine sites, but is committed to both meeting and exceeding internationally-
accepted due diligence standards for minerals supply chains. [...] Conducting
human rights due diligence in alignment with the Organisation for Economic Co-
operation and Development (“OECD”) Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict Affected and High-Risk Areas (2016) and
related Supplements (the “OECD Due Diligence Guidance”) is the foundation of
Apple’s responsible sourcing program for primary sourced minerals, and informs
Apple’s due diligence program for recycled minerals' [Conflict Minerals Report
2021, 2022: apple.com]
• Met: Suppliers expected to make similar requirements of their suppliers: The
Supplier Code states that 'Suppliers shall exercise due diligence on Relevant
Minerals and Relevant Materials in their Supply Chain. […] Due diligence shall be
conducted to the material processing level in order to determine whether relevant
materials originate from regions with High Risks, which include areas associated
with conflict, worst forms of child labor, forced labor and human trafficking, gross
human rights violations such as widespread sexual violence, or other reasonably
objective high risk activities, including severe health and safety risks and negative
environmental impacts'. By Relevant Materials, the Company means: Including, but
not limited to: Cassiterite (Tin); Cobalt; Columbite-tantalite (Coltan); (Tantalum);
Gold; Wolframite (Tungsten); Mica; Any additional minerals notified to Suppliers by
Apple'; and by Relevant Materials: 'Recycled plastics; Bio-based material; Any
additional materials notified to Suppliers by Apple.' In addition its SR Report 2022
reads: 'Our Responsible Sourcing of Materials Standard, part of our [Supplier] Code
and Standards, covers all primary and recycled materials, including advanced and
biobased materials'. In its 'Combat Human Trafficking' Statement 2019, the
Company indicates: 'Suppliers are also required to apply our requirements to their
sub-contractors, next-tier suppliers and third party recruitment agencies, through
all levels of the supply chain'. In addition, in the Modern slavery statement, the
Company states: 'Smelters and refiners deeper in our supply chain are held to
similar standards and if they exhibit a lack of commitment to meet our Supplier
Code and Standards, they risk losing Apple’s business'. [Supplier Code of Conduct &
Standards, 01/2022: apple.com] & [Supplier Responsibility 2022 Progress Report,
2022: apple.com]
A.1.3.b.ICT Commitment to The individual elements of the assessment are met or not as follows:
respect human Score 1
rights • Not Met: Women's rights [Human Rights Policy, 08/2020: s2.q4cdn.com]
• Not Met: Children's rights: The Company indicates in its Modern slavery
particularly
0.5 statement that 'We are dedicated to protecting children wherever our products are
relevant to the
made or used. Apple’s Global Security Investigations and Child Safety team
industry – supports implementation of our robust policies focused on child protection at all
vulnerable levels of our software platforms and services, and throughout our supply chain'.
groups (ICT) However, no evidence found of a statement where the Company commits to
Indicator Code Indicator name Score (out of 2) Explanation
respect children's rights in a suitable source for policy statement. [Human Rights
Policy, 08/2020: s2.q4cdn.com]
• Not Met: Migrant worker's rights: It also indicates in its 2019 Modern slavery
statement: 'We continuously strengthen our efforts to uphold the rights of foreign-
contract workers in our supply chain. When labor supply is limited in one country
but plentiful in another, some suppliers rely on third-party recruiters to secure
foreign-contract workers from countries such as the Philippines, Nepal, Thailand,
Indonesia, and Vietnam. A foreign contract worker is a person who seeks
employment in a country other than the one of which he or she is a citizen. Of the
millions of people who work at Apple supplier facilities every year, a small
percentage are foreign contract workers. These individuals can be particularly
vulnerable to debt-bonded labor, a form of modern slavery. Debt-bonded labor
occurs when a person is forced to work in exchange for the repayment of a debt or
other obligation—sometimes levied as a fee for receiving a job in the first place.'
However, 'continuously strengthen our efforts to uphold the rights' is not
considered a commitment statement according to CHRB wording criteria. In
addition, this document is no longer considered a suitable source for policy
statements according CHRB's revised approach. No further evidence found. [2019
Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and
Supply Chains, 03/03/2020: apple.com]
• Met: Expects suppliers to respect at least one of these rights: The Supplier code
includes provisions related to women's rights, such as: 'Supplier shall have a system
to discipline supervisors, managers, or Workers who engage in any Physical Abuse,
Sexual Harassment or sexual abuse, Psychological Harassment, or Verbal
Harassment or Verbal Abuse, through measures such as compulsory counselling,
warnings, demotions, and terminations or any combination thereof, regardless of
whether such action was intended as a means to maintain labor discipline. […]
Security Practices. All security practices shall be gender appropriate and
nonintrusive. […] Pregnancy and Nursing Mothers Anti-Discrimination. Supplier
shall comply with all Applicable Laws and Regulations regarding pregnancy and
postnatal employment protections, benefits, and pay. Supplier shall make
reasonable accommodations for nursing mothers unless prohibited by Applicable
Laws and Regulations. Supplier shall not (i) refuse to hire an applicant for a non-
Hazardous position or (ii) terminate a Worker’s employment solely based on the
Worker’s pregnancy or nursing status. Supplier shall not prohibit female Workers
from becoming pregnant nor threaten female Workers with adverse employment
consequences, including dismissal, loss of seniority, or deduction of wages, in order
to discourage them from becoming pregnant. […] Pregnancy and Medical Testing.
Supplier shall not require pregnancy tests or Medical Tests, including but not
limited to Hepatitis B or HIV, either as a condition for employment or as a
requirement for continued employment. […]' [Supplier Code of Conduct &
Standards, 01/2022: apple.com]
Score 2
• Not Met: CEDAW/Women's Empowerment Principles
• Not Met: Child Rights Convention/Business Principles
• Not Met: Convention on migrant workers
• Not Met: Expecting suppliers to respect these rights
A.1.4 Commitment to The individual elements of the assessment are met or not as follows:
remedy Score 1
• Not Met: The Company commits to remedy: The Company indicates in its Human
Rights Policy: ' We seek to remedy adverse impacts, track and measure our
progress, and report our findings.' However, to 'seek' is not considered a formal
statement of commitment according to CHRB wording criteria. [Human Rights
Policy, 08/2020: s2.q4cdn.com]
• Not Met: Company expect suppliers to make this commitment: The Company
includes in its Supplier Code some requirements related to remedy the adverse
impacts on individuals and workers, such as: 'If any Active Underage Worker,
0
Historical Underage Worker, or Terminated Underage Worker is found either
through an external audit or self-review, Supplier shall notify Apple immediately
and shall implement a remediation program as directed by Apple. [..] In the event
that the Supplier finds that a FCW has paid Fees and Expenses related to their
employment, Supplier shall reimburse such Fees and Expenses to that FCW within
30 days of the later of (i) the start of the FCW’s employment with Supplier or (ii)
the date Supplier discovers the fee payment(s)'. However, no requirement to
commit to remedy of any adverse impacts on individuals and workers and
communities that it has caused or contributed to was found. [Supplier Code of
Conduct & Standards, 01/2022: apple.com]
Indicator Code Indicator name Score (out of 2) Explanation
Score 2
• Not Met: Collaborating with other remedy initiatives
• Not Met: Work with suppliers to remedy impact: The Company's 'Supplier
Responsibility Standards' document includes requirements to remedy specific cases
such of non-compliances. In addition, it states that 'If a Supplier or Apple discovers
alleged or actual risks associated with its Supply Chain, Supplier shall work with
Apple to respond to the applicable risks by (to the extent not prohibited by
applicable law): […] Utilizing grievance channels of recognized Third-Party
organizations to report risks and request that appropriate action be taken to
address identified High Risks'. In addition, in its Modern Slavery Statement 2019,
the Company gives some examples of 'Recognized Third-Party Programs with
Grievance Channels: 'Several, but not all, Third-Party verification or audit programs
have developed grievance channels, including first or second-party channels to
address alleged or confirmed High Risks with Suppliers, traders, or mines or due
diligence or whistleblowing platforms (as available) established to report on and
address identified risks. Examples include: ITRI’s Tin Supply Chain initiative: […]; The
Responsible Jewellery Council'. In its 2018 Statement on combat human trafficking,
the Company reports that it has been working in different Remediation Guidelines,
such us the 'Remediation Guidelines for Victims of Exploitation in Extended
Minerals Supply Chain' which states who is responsible for actions to be taken and
give a step-by-step process to remedy the issue, or the 'Bonded Labor remediation
program'. Its SR Report 2022, also discloses information about examples of how it
works with supplier to provide remedy: 'Responding to supplier employee concerns
and providing remedy: Worker feedback is essential to cultivating greater
transparency and protecting workers’ rights. It is also an indication that workers
are aware of their rights, and have enough confidence in the feedback channels to
speak freely without fear of retaliation. It also gives our suppliers the opportunity
to address and remedy issues, and for us to find better ways to help suppliers
improve their performance...'. However, these reports are no longer considered
suitable sources for policy statements according CHRB's revised approach. No
statement committing to work and collaborate with suppliers to remedy adverse
impacts which are directly linked to the company’s operations, products or services
was found in a suitable source for policy. [Supplier Code of Conduct & Standards,
01/2022: apple.com] & [2018 Statement on Efforts to Combat Human Trafficking
and Slavery in Our Business and Supply Chains, 02/2019: apple.com]
A.1.5 Commitment to The individual elements of the assessment are met or not as follows:
respect the Score 1
rights of human • Not Met: Zero tolerance attacks on HRs Defenders (HRDs): In its Modern slavery
statement the Company indicates: 'Apple believes that empowering independent
rights
voices in the supply chain is critical to identifying, assessing, and remedying risks
defenders
related to human trafficking and involuntary labor. […] Since 2017, we partnered
with the Fund for Global Human Rights, a leading human rights organization, to
support their work with grassroots human rights defenders in the Democratic
Republic of the Congo (“DRC”).' A similar statement was included in its CMR 2019.
However, no evidence found of a statement where the Company commits to not
tolerating attacks against human rights defenders, including in a suitable source for
policy statement according to CHRB's revised approach. [2019 Statement on Efforts
to Combat Human Trafficking and Slavery in Our Business and Supply Chains,
03/03/2020: apple.com]
• Not Met: Company expect suppliers to make this commitment
Score 2
0.5
• Met: Work with HRD to create safe and enabling environment: The Company
indicates in its SR Report 2022: 'Empowering local, independent voices is critical to
identifying and assessing risks and opportunities deeper in our supply chain. In
2021, we supported more than 60 organizations, including human rights and
environmental defenders working around the world on issues including social and
economic rights in mining communities, the prevention of modern slavery, and
media freedom. We’ve supported many of these organizations through our
continuing partnership with the Fund for Global Human Rights — a public
foundation that works with local human rights organizations in more than 25
countries around the globe — to equip activists, mobilize movements, and improve
lives by supporting groups and individuals working to create lasting change. We’ve
provided financial support to the Fund’s frontline activists and human rights
defenders working on a range of issues, including economic and social rights of
mining communities, inclusive economic growth, judicial advocacy, environmental
justice, the rule of law, health and safety, and fair compensation for mining
communities.' [Supplier Responsibility 2022 Progress Report, 2022: apple.com]
A.2 Policy Commitments (5% of Total)
Indicator Code Indicator name Score (out of 2) Explanation
A.2.1 Commitment The individual elements of the assessment are met or not as follows:
from the top Score 1
• Met: Board level responsibility for HRs: The Company indicates in its ESG Report
2021: 'Our Board of Directors adopted the [Human Rights] policy and is
responsible for overseeing and periodically reviewing it. Apple’s Senior Vice
President and General Counsel is responsible for its implementation, and reports
to the Board and its committees on our progress and significant issues.[...] The
0.5 Board and its committees review and discuss with management progress relating
to Apple’s values. Further, the Board and its committees also review and discuss
Apple’s commitments and progress on inclusion and diversity, employee
engagement, compensation and benefits, and compliance'. [ESG Report 2021,
2021: s2.q4cdn.com]
• Not Met: Describe HR expertise of Board member
Score 2
• Not Met: Speeches/letters by Board members or CEO
A.2.2 Board The individual elements of the assessment are met or not as follows:
responsibility Score 1
• Not Met: Board/Committee review HRs strategy: The Company indicates in its
ESG Report 2021: 'The Board and its committees review and discuss with
management progress relating to Apple’s values. Further, the Board and its
committees also review and discuss Apple’s commitments and progress on
inclusion and diversity, employee engagement, compensation and benefits, and
compliance. ' However, no information describing the processes it has in place to
discuss and regularly review its human rights strategy or policy or management
processes at board level or a board committee was found. [ESG Report 2021,
1 2021: s2.q4cdn.com]
• Met: Examples/trends re HR discussion in the last reporting period: In addition,
the Company reports: 'During 2020, the Board and its committees engaged with
management on the impact of COVID-19 on Apple’s employees, supply chain, and
business. The Board reviewed strategies and initiatives to respond to, and
mitigate, adverse impacts, including enhanced health and safety measures for
Apple employees as well as workers in our supply chain'. [ESG Report 2021, 2021:
s2.q4cdn.com]
Score 2
• Not Met: Meets both requirements under score 1
• Not Met: How affected stakeholders/HR experts informed discussions
A.2.3 Incentives and The individual elements of the assessment are met or not as follows:
performance Score 1
management • Not Met: Incentives for at least one board member: The Company indicates in its
ESG Repòrt 2021: 'Our executive compensation program is built on sound
compensation policies and practices and clear guiding principles that align
executive compensation with our shareholders’ interests. We manage Apple for
the long term. Consistent with this approach, beginning in 2021, an ESG modifier
based on Apple’s values and other key community initiatives has been
incorporated into our annual cash incentive program. This change is intended to
0
further motivate Apple’s executive team to meet exceptionally high standards of
values-driven leadership in addition to delivering strong financial results.'
However, it is not clear whether Supervisory Board members receive these
incentives or whether human rights related indicators or factors are considered in
this mechanism. [ESG Report 2021, 2021: s2.q4cdn.com]
• Not Met: At least one key HR risk, beyond employee H&S
Score 2
• Not Met: Performance criteria made public
• Not Met: Review of other board performance criteria
A.2.4 Business The individual elements of the assessment are met or not as follows:
model strategy Score 1
and risks • Not Met: Board process to review bussiness model and strategy
0 • Not Met: Describe frequency and triggers for reviewing
Score 2
• Not Met: Meets both requirements under score 1
• Not Met: Example of actions decided
B. Embedding Respect and Human Rights Due Diligence (25% of Total)
B.1 Embedding Respect for Human Rights in Company Culture and Management Systems (10% of
Total)
Indicator Code Indicator name Score (out of 2) Explanation
B.1.1 Responsibility The individual elements of the assessment are met or not as follows:
and resources Score 1
for day-to-day • Not Met: Score of 1 on A.1.2.a: See indicators A.1.2.a
• Met: Senior responsibility for HR implementation and decision making: The
human rights
Company discloses information about its senior management positions, including
functions
the ones related to human rights issues: 'Sabih Khan is Apple’s senior vice president
of Operations reporting to COO Jeff Williams. Sabih is in charge of Apple’s global
supply chain, ensuring product quality and overseeing planning, procurement,
manufacturing, logistics and product fulfilment functions, as well as Apple’s
supplier responsibility programs that protect and educate workers at production
facilities around the world.'; 'Deirdre O’Brien is Apple’s senior vice president of
Retail + People, reporting to CEO Tim Cook. […] In her role leading the People team,
Deirdre works to help Apple connect, develop and care for its employees […]. Her
teams oversee a broad range of functions including talent development and Apple
University, recruiting, employee relations and experience, business partnership,
benefits, compensation, and inclusion and diversity'. Therefore, the Company is
reporting senior role for own operations and for supply chain. [Leadership and
Governance, N/A: investor.apple.com]
Score 2
0.5
• Met: How it assigns Day-to-day responsibility: The Company indicates that: 'A
number of cross-functional teams are responsible for carrying out related efforts
with respect to Apple’s anti-human trafficking policies, including, but not limited to,
our Global Security, Business Conduct, and Supplier Responsibility (“SR”) teams.
The Global Security team sits within Apple’s Legal and Global Security organization
and seeks to identify risks across Apple and our supply chain, and mitigate them
with efficient and effective security solutions. The Business Conduct team also sits
within Apple’s Legal and Global Security organization and sets policies and provides
guidance to ensure that Apple conducts business ethically, honestly, and in full
compliance with applicable laws and regulations. The SR team sits in Apple’s World
Wide Operations organization and coordinates activities related to our Code and
our strategy to eradicate modern slavery. It works across a number of Apple
business groups, teams and functions, including, but not limited to Apple’s Global
Security Investigations and Child Safety team, Business Conduct, Legal, Finance,
Product Design, Procurement, Manufacturing Operations, and Retail.' [2019
Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and
Supply Chains, 03/03/2020: apple.com]
• Not Met: Day-to-day resources and expertise allocation in own ops
• Not Met: Resources and expertise allocation in the supply chain
B.1.2 Incentives and The individual elements of the assessment are met or not as follows:
performance Score 1
management • Not Met: Senior manager incentives for human rights: The Company indicates in
its ESG Repòrt 2021: 'Our executive compensation program is built on sound
compensation policies and practices and clear guiding principles that align
executive compensation with our shareholders’ interests. We manage Apple for the
long term. Consistent with this approach, beginning in 2021, an ESG modifier based
on Apple’s values and other key community initiatives has been incorporated into
0 our annual cash incentive program. This change is intended to further motivate
Apple’s executive team to meet exceptionally high standards of values-driven
leadership in addition to delivering strong financial results.' However, it is not clear
whether and how human rights related indicators or factors are considered in this
mechanism. [ESG Report 2021, 2021: s2.q4cdn.com]
• Not Met: At least one key HR risk, beyond employee H&S
Score 2
• Not Met: Performance criteria made public
• Not Met: Review of other senior management performance
B.1.3 Integration The individual elements of the assessment are met or not as follows:
with enterprise Score 1
risk • Not Met: HR risks is integrated as part of enterprise risk system: The Company
indicates in its ESG Report 2021: 'Apple also has internal systems and procedures
management 0
for managing environmental, social, and governance (ESG) topics, including with
external stakeholders to learn about their priorities and get their feedback and to
coordinate relevant projects and initiatives. Work on environmental and social
initiatives is embedded across different lines of business, with broad collaboration
Indicator Code Indicator name Score (out of 2) Explanation
to drive forward initiatives that are important to Apple'. However, no further
information describing how human rights are integrated in its Enterprise Risk
Management (ERM) or enterprise risk system was found. [ESG Report 2021, 2021:
s2.q4cdn.com]
• Not Met: Provides an example
Score 2
• Not Met: Audit Ctte or independent risk assessment
B.1.4.a Communication The individual elements of the assessment are met or not as follows:
/dissemination Score 1
of policy • Not Met: Score of 1 on A.1.2.a: See indicator A.1.2.a
• Met: Communicates its policy to all workers in own operations: In its 'Combat
commitment(s)
Human Trafficking' Statement, the Company indicates: 'The Human Rights Policy is
to workers and
referenced in Apple's Business Conduct Policy, and included in the annual Business
external Conduct training required of all employees'. [Statement on Efforts to Combat
stakeholders Human Trafficking and Slavery in Supply Chain 2021, 2022: apple.com]
Score 2
• Not Met: Communication of policy commitments to stakeholder: The Company
0.5
indicates in its ESG Report 2021: 'Apple also has internal systems and procedures
for managing environmental, social, and governance (ESG) topics, including with
external stakeholders to learn about their priorities and get their feedback and to
coordinate relevant projects and initiatives. Work on environmental and social
initiatives is embedded across different lines of business, with broad collaboration
to drive forward initiatives that are important to Apple.' However, no further
information describing how it actively communicates its policy commitments to
affected stakeholders, including local communities, was found. [ESG Report 2021,
2021: s2.q4cdn.com]
• Not Met: How policy commitments are made accessible to audience
B.1.4.b Communication The individual elements of the assessment are met or not as follows:
/dissemination Score 1
of policy • Met: Meets ILO requirement for suppliers on A.1.2.a: See indicator A.1.2.a
• Met: Requires suppliers to communicate policy requirements: In its 'Combat
commitment(s)
Human Trafficking' Statement 2019, the Company indicates: 'To do business with
to business
Apple, suppliers must agree to operate in full compliance with all applicable laws
relationships and regulations, and adhere to our Supplier Code and Standards. Our Supplier Code
and Standards go beyond compliance with existing law. […] Suppliers are also
required to apply our requirements to their sub-contractors, next-tier suppliers and
third party recruitment agencies, through all levels of the supply chain. […] The
Supplier Code is published in 15 languages and is publicly available on apple.com.'
In addition, in the Modern slavery statement, the Company states: 'Smelters and
refiners deeper in our supply chain are held to similar standards and if they exhibit
a lack of commitment to meet our Supplier Code and Standards, they risk losing
Apple’s business'. [2018 Statement on Efforts to Combat Human Trafficking and
Slavery in Our Business and Supply Chains, 02/2019: apple.com] & [2019 Statement
on Efforts to Combat Human Trafficking and Slavery in Our Business and Supply
Chains, 03/03/2020: apple.com]
Score 2
• Met: How HR commitments made binding/contractual: As indicated above:
2
'Suppliers are also required to apply our requirements to their sub-contractors,
next-tier suppliers and third party recruitment agencies, through all levels of the
supply chain.' [2019 Statement on Efforts to Combat Human Trafficking and Slavery
in Our Business and Supply Chains, 03/03/2020: apple.com]
• Met: Company requires suppliers to cascade down to their suppliers: As indicated
above, Suppliers are also required to apply commitments to their suppliers, and so
forth, through all levels of the supply chain. Requirements for suppliers include
'suppliers are required to adhere to the supplier code and standards, including any
subsequent amendments or updates'. It also adds that 'Smelters and refiners
deeper in our supply chain are held to similar standards and if they exhibit a lack of
commitment to meet our Supplier Code and Standards, they risk losing Apple’s
business'. In addition, suppliers shall perform periodic evaluations of facilities and
operations of its subcontractors and next-tier suppliers to ensure compliance with
the Code (and permit Apple and any third party designated to do the same). The
Supplier Code reads: 'This Code applies to Apple suppliers and their subsidiaries
and affiliates, as well as any subcontractors and sub-tier suppliers (each a
“Supplier”) providing goods or services to Apple or for use in or with Apple
products'. [Supplier Code of Conduct & Standards, 01/2022: apple.com] & [2019
Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and
Supply Chains, 03/03/2020: apple.com]
Indicator Code Indicator name Score (out of 2) Explanation
B.1.5 Training on The individual elements of the assessment are met or not as follows:
Human Rights Score 1
• Not Met: Scores at least 1 on A.1.2.a: See indicator A.1.2.a
• Met: How workers are trained on HR policy commitments: In its 'Combat Human
Trafficking' Statement, the Company indicates: 'All Apple employees and interns
are required to complete mandatory, annual Business Conduct training that
includes education on key points in Apple’s Anti-Human Trafficking Policy'. This
policy has not been found in the public domain. In addition, the Company also
indicates: 'All Apple corporate employees are provided annually with information
on key points in the Code as well as Apple’s SR issue reporting process and are
instructed to report anything that might be considered a violation, including forced
labor, trafficking, or ethical violations'. In the document's latest version, the
0.5
Company indicates: 'The Human Rights Policy is referenced in Apple's Business
Conduct Policy, and included in the annual Business Conduct training required of all
employees'. [2019 Statement on Efforts to Combat Human Trafficking and Slavery
in Our Business and Supply Chains, 03/03/2020: apple.com] & [Statement on
Efforts to Combat Human Trafficking and Slavery in Supply Chain 2021, 2022:
apple.com]
• Not Met: Trains relevant managers including procurement
Score 2
• Not Met: Score of 2 on A.1.2.a: See indicator A.1.2.a
• Not Met: Meets both requirements under score 1
• Not Met: Trains suppliers to meet company's HR commitment
• Not Met: Disclose % trained
B.1.6 Monitoring and The individual elements of the assessment are met or not as follows:
corrective Score 1
actions • Not Met: Scores at least 1 on A.1.2.a: See indicator A.1.2.a
• Met: Monitoring implementation of HR policy commitments across global ops
and supply chain: The Company describes its MSA 2022: '[...] we conduct internal
and third-party independent assessments of our compliance programs to
determine effectiveness, and make changes to our policies and our training to
reflect emerging trends. With respect supply chain monitoring process, the
Company indicates in its SR 2022: 'In addition to having teams from Apple in our
suppliers’ facilities regularly, we work with independent, third-party auditors to
perform rigorous assessments of our suppliers’ performance in upholding our strict
standards'. 'Activities included in our Code of Conduct assessments: Management
interviews, Extensive document review, Employee interviews, Site walk-throughs'.
[Statement on Efforts to Combat Human Trafficking and Slavery in Supply Chain
2021, 2022: apple.com] & [Supplier Responsibility 2022 Progress Report, 2022:
apple.com]
• Not Met: Proportion of supply chain monitored: The Company indicates: 'In
reporting year 2021, 1,117 independent, third party assessments were conducted
in 52 countries, including 886 Code of Conduct assessments and 291 smelter and
refiner assessments.* Since 2007, Apple-managed assessments have covered 94
percent of Apple’s direct manufacturing spend.' However, it is not clear what % of
its supply chain does this percentage represent. [Supplier Responsibility 2022
0.5
Progress Report, 2022: apple.com]
• Not Met: Describe how workers are involved in monitoring [Supplier
Responsibility 2022 Progress Report, 2022: apple.com]
Score 2
• Not Met: Score of 2 on A.1.2.a: See indicator A.1.2.a
• Met: Describes corrective action process: The Company indicates in its SR 2022:
'If we uncover non-compliance, we take prompt action to ensure suppliers not only
correct the issue, but make meaningful, long-term changes. We do this through a
Corrective Action Plan (CAP), during which 30-, 60-, and 90-day check-ins with
Apple are required. We then conduct our Corrective Action Verification (CAV)
process to verify that all corrective actions have been successfully implemented,
and necessary steps have been taken to prevent a reoccurrence'. [Supplier
Responsibility 2022 Progress Report, 2022: apple.com]
• Not Met: Disclose findings and number of corrective action: The Company
reports: 'In FY2021, 11 Core Violations were found, including two debt-bonded
labor violations, and nine instances of working hours or labor data falsification.*
The two debt-bonded labor Core Violations occurred at two separate facilities
owned by the same supplier in Taiwan. Auditors found that Foreign Contract
Workers had paid recruitment fees, a practice that is strictly prohibited by Apple
everywhere we operate, and even if local laws allow it. Any time we find Foreign
Contract Workers have paid any recruitment fee we require the supplier to
immediately repay the employees in full and we verify this repayment through a
Indicator Code Indicator name Score (out of 2) Explanation
third-party auditor. As always, we also worked with the supplier to enhance their
management systems and practices to prevent a reoccurrence. In the nine
instances of working hours or labor data falsification, suppliers were found to have
provided falsified records to Apple that showed full compliance with our working
hours requirements — which includes limiting working hours to no more than 60
hours per week, and 6 consecutive workdays — in order to hide excessive overtime
and/or lack of weekly rest days. There were also two instances in which suppliers
falsified records in order to hide non-compliance with our working requirements
for students and interns. For each instance, the supplier involved was placed on
immediate probation and their CEO was notified. The supplier’s ethics policy and
management systems underwent a thorough review to identify the root causes of
the issues, and the supplier was required to undergo additional assessments to
ensure that policy changes are implemented to prevent future violations. The
suppliers were also required to revise all records to reflect an accurate accounting
of hours worked'. However, evidence seems to focus only in "core violations", it is
not clear the number of corrective actions processes as a result of the monitoring.
[Supplier Responsibility 2022 Progress Report, 2022: apple.com]
B.1.7 Engaging and The individual elements of the assessment are met or not as follows:
terminating Score 1
business • Met: HR affects selection of suppliers: In its 'Combat Human Trafficking'
Statement, the Company indicates: 'Through our responsible procurement
relationships
program, we assess new suppliers before they enter our supply chain and before
business is awarded. A dedicated team in Apple’s Product Operations group uses a
supplier selection framework that includes comprehensive questions on human
rights and risks of human trafficking, including on debt-bonded labor.' [2019
Statement on Efforts to Combat Human Trafficking and Slavery in Our Business and
Supply Chains, 03/03/2020: apple.com]
• Met: HR affects on-going supplier relationships: The Company indicates in its
Supplier Code of Conduct that it 'will assess its suppliers’ compliance with this
Code, and any violations of this Code may jeopardize the supplier’s business
relationship with Apple, up to and including termination'. The Company also
indicates in its MSA Statement: 'When a Core Violation is identified, Apple issues a
Notice of Probation directly to the president or CEO of the supplier, and the
supplier is commercially penalized. Our Code requires that Core Violations be
addressed immediately, and when appropriate, we also report these violations to
local authorities. Any supplier with a documented Core Violation is placed on
probation until the satisfactory completion of their next audit. During probation,
the issue that caused the Core Violation is monitored closely by Apple, and if the
supplier does not demonstrate necessary progress toward corrective action, they
risk removal from our supply chain. To date, 22 manufacturing supplier facilities
have been removed from our supply chain.' [Supplier Code of Conduct & Standards,
01/2022: apple.com] & [2019 Statement on Efforts to Combat Human Trafficking
2
and Slavery in Our Business and Supply Chains, 03/03/2020: apple.com]
Score 2
• Not Met: Describe positive incentives offered to respect human rights
• Met: Working with suppliers to meet HR requirements: According to its Supplier
Responsibility 2020 Progress Report: 'Consulting closely with stakeholders and the
IOM, we created the Responsible Recruitment Due Diligence Toolkit (“the Toolkit”).
The Toolkit offers suppliers and labor agents a comprehensive “how-to” guide with
practical tools covering six core areas: embedding responsible recruitment into
policies and management systems; identifying and assessing risks; preventing and
mitigating risks; tracking implementation and results; communicating how risks are
addressed; and providing access to remediation. […] We began holding training
sessions on the Toolkit in those countries where the most prevalent migration
corridors in our supply chain exist, including Malaysia, Singapore, and the
Philippines.' In addition, in its 'Supplier Responsibility 2019 Progress Report', the
Company indicates: 'Following an assessment, we partner with a supplier to
develop a corrective action plan to make improvements where needed. Ongoing
engagements with our suppliers can include months on the ground working with
suppliers, providing training, tools, and support to help them meet our standards.
To support capability building, Apple’s SupplierCare platform provides information
to increase understanding of the Supplier Code of Conduct and educate suppliers
on best practices. Tutorials range in topics from safe storage of chemicals to
responsibly sourcing minerals. In 2018, SupplierCare expanded to provide online
trainings to 219 active supplier facilities.' [Supplier Responsibility 2019 Progress
Report, 2019: apple.com] & [Supplier Responsibility 2020 Progress Report,
05/2020: apple.com]
Indicator Code Indicator name Score (out of 2) Explanation
B.1.8 Approach to The individual elements of the assessment are met or not as follows:
engagement Score 1
with affected • Not Met: Stakeholder process or systems to identify and engage with
workers/communities in the last two years: The Company indicates in its SR 2022:
stakeholders
'As part of our comprehensive approach to identifying and preventing risks, we
engage with civil society organizations, governments, NGOs, UN agencies, and
other expert stakeholders throughout the year in both structured and informal
roundtables and dialogues to help us understand what we are doing well, where
we could do more, and to identify emerging areas of risk and opportunity. The
feedback we receive directly influences our strategy and programs, and has
enabled us to make faster progress in our supply chain. We share the learnings
from this process with other companies through industry associations and at
relevant conferences to accelerate progress across the industry.' In addition, its ESG
Report 2021 reads: 'Apple engages with stakeholders as part of our commitment to
advance meaningful change and find novel solutions to pressing challenges. Every
day, at all levels of the business, we interact with a variety of stakeholders to listen
and learn from others’ perspective and experiences, share our progress, and
promote best practices. Throughout the year, we proactively engage with
shareholders and other stakeholders. These engagements help us understand their
perspectives on significant issues, from company performance, strategy, and
corporate governance to executive compensation and other ESG topics. We take
feedback and insights from our engagement with all stakeholders into
consideration as we review and enhance our operations and disclosures, sharing
them with our Board as appropriate.' However, no information found describing
the process by which the Company identifies affected stakeholders with whom to
0.5
engage in relation to human rights impacts, including workers or local
communities, including supply chain. [Supplier Responsibility 2022 Progress Report,
2022: apple.com] & [ESG Report 2021, 2021: s2.q4cdn.com]
• Not Met: Discloses stakeholders that HRs may be affected
• Met: Provides two examples of engagement with stakeholders: Example 1: the
Company reports in its SR 2022: 'Supplier employee interviews are an important
part of every assessment conducted. Each year, we interview tens of thousands of
supplier employees in their local language and without their managers present, to
determine whether or not their experience on the job aligns with auditors’
observations during assessments'.
Example 2: In addition to interviews and grievance channels, which are
requirements under our Code and Standards, we also engage with supplier
employees in order to understand their overall workplace satisfaction. In 2021, we
anonymously surveyed 264,963 supplier employees in 191 facilities across Greater
China, India, Ireland, Malaysia, Philippines, Singapore, UK, U.S., and Vietnam about
their workplace experiences — nearly double the number of supplier employees
surveyed last fiscal year. In order to better identify the issues that matter most to
supplier employees, we asked participants to provide feedback on different aspects
of their workplaces, including working and living conditions, food, and
management. We then worked with suppliers to analyze the results, and develop
action plans to address their employees’ needs and concerns.' [Supplier
Responsibility 2022 Progress Report, 2022: apple.com]
Score 2
• Not Met: Analysis of stakeholder views on company's HR issues
• Not Met: Describe how views influenced company's HR approach
B.2 Human Rights Due Diligence (15% of Total)
Indicator Code Indicator name Score (out of 2) Explanation
B.2.1 Identifying The individual elements of the assessment are met or not as follows:
human rights Score 1
risks and • Met: Identifying risks in own operations: The Company indicates in its ESG Report
2021: 'Identifying human rights risks is the first step to addressing those risks
impacts
through improvements to our policies and management systems. We work to align
our efforts with the business and human rights due diligence process set forth in
the UNGPs to identify, mitigate, prevent, and remedy human rights risks. We
identify salient human rights risks through internal risk assessments and external
industry-level third-party audits, as well as through the channels we maintain with
rights holders and other stakeholders, including investors, human rights and labor
experts, governments, and international bodies such as the UN. In addition to our
own internal monitoring, we consider reports identifying potential risks from
external sources, including international organizations, policymakers, shareholders,
civil society organizations, news outlets, customers, individuals in the supply chain
or supply chain communities, whistleblower mechanisms, and third-party hotlines.
They also come through the reporting mechanisms we make available directly to all
supplier employees, Apple employees, and the general public. These reports can
come to us in any language and can be anonymous'. [ESG Report 2021, 2021:
s2.q4cdn.com]
• Met: Identifying risks through relevant business relationships: The Company
indicates in its SR 2022: 'Identifying risks in our global supply chain is the first step
to eliminating those risks through improvements to our policies and strategies, and
through collaborative capability-building with our suppliers. Our efforts to identify,
1 mitigate, prevent, and remedy human rights risks align with the Business and
Human Rights Due Diligence process set forth in the UNGPs. First, we identify
salient human rights risks through our robust assessment processes, as well as by
participating in industry-level, third-party audits. Apple selects suppliers for
assessment based on a number of factors, including previous audit performance,
manufacturing process risks, and planned spending. We also identify salient human
rights risks through our own risk analysis and through the channels we maintain
with key rights-holders, stakeholders, and partners. These include supplier
employee interviews and surveys, consultations with human rights, labor, and
environmental experts, expert groups we convene on specialized or emerging
human rights topics, UN and government labor and human rights reporting and
consultations, media reports, the results of our supplier assessments, discussions
with supplier management teams, and reports received through our partners
around the world.' [Supplier Responsibility 2022 Progress Report, 2022: apple.com]
Score 2
• Not Met: Describe ongoing global risk identification in consultation with
stakeholder/HR experts: See above, the company reports consulting through
channels with 'key rights-holders, stakeholders, and partners'. Including supplier
employee interview and surveys. This is an ongoing process. The company also
indicates that consults with experts. However, no details found in relation to
experts. Also, this process refers to supply chain only. [Supplier Responsibility 2022
Progress Report, 2022: apple.com]
• Not Met: Triggered by new circumstances
• Not Met: Describes risks identified
B.2.2 Assessing The individual elements of the assessment are met or not as follows:
human rights Score 1
risks and • Not Met: Describe process for assessment of HR risks and discloses salient HR
issues: The Company indicates in its ESG Report 2021: 'We work to align our efforts
impacts
with the business and human rights due diligence process set forth in the UNGPs to
identify, mitigate, prevent, and remedy human rights risks. We identify salient
human rights risks through internal risk assessments and external industry-level
third-party audits, as well as through the channels we maintain with rights holders
and other stakeholders, including investors, human rights and labor experts,
0 governments, and international bodies such as the UN. In addition to our own
internal monitoring, we consider reports identifying potential risks from external
sources, including international organizations, policymakers, shareholders, civil
society organizations, news outlets, customers, individuals in the supply chain or
supply chain communities, whistleblower mechanisms, and third-party hotlines.
They also come through the reporting mechanisms we make available directly to all
supplier employees, Apple employees, and the general public.' However, no further
information describing the assessment process was found, including how relevant
factors are taken into account when , such as geographical, economic, social and
other factors. [ESG Report 2021, 2021: s2.q4cdn.com]
Indicator Code Indicator name Score (out of 2) Explanation
• Not Met: How process applies to supply chain: The Company indicates in its SR
2022: 'First, we identify salient human rights risks through our robust assessment
processes, as well as by participating in industry-level, third-party audits. Apple
selects suppliers for assessment based on a number of factors, including previous
audit performance, manufacturing process risks, and planned spending. We also
identify salient human rights risks through our own risk analysis and through the
channels we maintain with key rights-holders, stakeholders, and partners. These
include supplier employee interviews and surveys, consultations with human rights,
labor, and environmental experts, expert groups we convene on specialized or
emerging human rights topics, UN and government labor and human rights
reporting and consultations, media reports, the results of our supplier assessments,
discussions with supplier management teams, and reports received through our
partners around the world.' However, no information found describing the process
to assess these risks and impacts, including how it takes social, geographical,
economic or other factors into account beyond the context of conflict minerals. No
new relevant evidence found in latest review. [Supplier Responsibility 2022
Progress Report, 2022: apple.com]
• Not Met: Public disclosure of the results of HR assessment: The Company reports
in its SR 2022: 'The following are examples of “salient human rights risks” in our
supply chain that relate to the ILO Core Conventions, which are based on supplier
assessments, due diligence deeper in our supply chain, work within our industry,
and public reporting. Each of these is addressed in our Code and Standards:
Discrimination, Freedom of Association and Collective Bargaining, Involuntary
Labor and Human Trafficking, Underage Labor' However, no complete information
with respect its salient human rights risks was found. [Supplier Responsibility 2022
Progress Report, 2022: apple.com]
Score 2
• Not Met: Meets all requirements under score 1
• Not Met: How it involved affected stakeholders in the assessment
B.2.3 Integrating and The individual elements of the assessment are met or not as follows:
acting on Score 1
human rights • Not Met: Action Plans to mitigate risks: The Company has provided comments to
CHRB regarding this indicator. However, evidence was not material for this
risks and
indicator.
impact
• Not Met: Description of how global system applies to supply chain: The Company
assessments discloses some information in a section named 'Assessing impacts, integrating
findings, and taking action' of its SR 2022: ' Supplier performance is assessed
against our Code and Standards to drive improvements in the areas of labor and
human rights, health and safety, environment, ethics, and management systems.
Assessments are a comprehensive process that can require multiple days at a
supplier in order to conduct site inspections, review documents, and complete
worker and management interviews. [...] If non-compliances are identified during
an assessment, we create a Corrective Action Plan for the supplier, requiring 30-,
60-, and 90-day check-ins.' However, this process seems to be related to supply
chain monitoring process evaluated in B.1.6 indicator. This indicator looks for
evidence of proactive action taken against salient risks and impacts that have been
determined relevant for the Company. [Supplier Responsibility 2022 Progress
Report, 2022: apple.com]
0 • Not Met: Example of actions decided on at least 1 salient HR issues: The Company
discloses information about its strategy for safer materials: 'A great deal of care
and research go into choosing materials for Apple products to ensure
manufacturing workers, customers, and recyclers can use and handle Apple
products safely. Consideration of the toxicological profile of materials is a key
component of Apple’s material selection process during new product development.
[…] Apple believes that reducing the use of hazardous substances in materials is
essential to ensure the safety of workers who manufacture its products, customers
who use its products, and recyclers who handle its products at the end of the
products’ useful life. This commitment to the safety of workers, customers and
recyclers has driven Apple to lead the electronics industry in phasing out hazardous
substances from its products.' The Company has been working in this strategy
during the last years with the aim of identify hazardous materials, evaluate the
hazardous potential along the life of products (production, use, recycling,
elimination), eliminate the use of the most dangerous materials and develop safety
protocols to safe manipulation of specific materials. Part of this work are the
following documents: Material Impact Profile; A Protocol for Prioritizing Chemicals
of Concern in the Electronics Industry.
However, part of this evidence comes from a source dated 2016. No more recent
evidence found of specific proactive action taken to tackle a salient human rights
Indicator Code Indicator name Score (out of 2) Explanation
risk or impact. [Integrating Toxicological Assessments in Material Selection,
09/2016] & [Material Impact Profiles, 2019: apple.com]
Score 2
• Not Met: Meets all requirements under score 1
• Not Met: Involve stakeholders in decisions about actions
B.2.4 Tracking the The individual elements of the assessment are met or not as follows:
effectiveness of Score 1
actions to • Not Met: System for tracking or monitor if actions taken are effective: The
Company indicates in its ESG Report 2021: 'We’re committed to continually
respond to
assessing our progress and incorporating what we learn into our work. We track
human rights
and measure our performance across a range of areas, and apply the lessons we
risks and learn to continually improve. ' However, no further information was found
impacts 0 describing its system(s) for tracking or monitoring the actions taken in response to
human rights risks and impacts and for evaluating whether the actions have been
effective or have missed key issues or not produced the desired results. [ESG
Report 2021, 2021: s2.q4cdn.com]
• Not Met: Lessons learnt from checking system effectiveness
Score 2
• Not Met: Meets both requirements under score 1
• Not Met: Involve stakeholders in evaluation of actions taken
B.2.5 Communicating The individual elements of the assessment are met or not as follows:
on human Score 1
rights impacts • Not Met: Provides two examples of comms with stakeholders
0
Score 2
• Not Met: Describe challenges to effective comms and how it is working to
address them
C. Remedies and Grievance Mechanisms (20% of Total)
Indicator Code Indicator name Score (out of 2) Explanation
C.1 Grievance The individual elements of the assessment are met or not as follows:
channel(s)/mec Score 1
hanism(s) to • Met: Channel accessible to all workers: Company's Business Conduct Policy reads:
'Apple’s external helpline (apple.ethicspoint.com) also allows employees and
receive
external parties to report concerns with the option of remaining anonymous,
complaints or
where permissible under applicable laws. The external helpline provides local, toll-
concerns from free phone numbers that connect employees and external parties to a multilingual
workers reporting service'. [Business Conduct Policy, 10/2020: apple.com]
Score 2
• Met: Channel is available in all appropriate languages and workers aware: As
indicated above, 'The external helpline provides local, toll-free phone numbers that
connect employees and external parties to a multilingual reporting service'. In
addition, the Company indicates in its SR 2022: 'All Apple employees and interns
are required to complete mandatory annual Business Conduct training, […] We
2
offer additional resources for employees to address questions and concerns,
including the Business Conduct Helpline and the Business Conduct website, which
allow employees to report concerns anonymously'. [Business Conduct Policy,
10/2020: apple.com] & [Supplier Responsibility 2022 Progress Report, 2022:
apple.com]
• Met: Describe how workers in the supply chain have access to grievance
mechanism: In its Supplier Code of Conduct, the Company indicates: 'Supplier shall
ensure that Workers have an effective mechanism to report Grievances and that
facilitates open communication between management and Workers.' [Supplier
Code of Conduct & Standards, 01/2022: apple.com]
• Met: Expect Suppliers to convey expectation to their own suppliers: The Code
applies to 'Apple suppliers and their subsidiaries, affiliates, and subcontractors
(each a “Supplier”) providing goods or services to Apple, or for use in or with Apple
products'. [Supplier Code of Conduct & Standards, 01/2022: apple.com]
C.2 Grievance The individual elements of the assessment are met or not as follows:
channel(s)/mec Score 1
hanism(s) to • Met: Grievance mechanism for community: The Company's Business Conduct
Policy reads: 'Apple’s external helpline (apple.ethicspoint.com) also allows
receive
employees and external parties to report concerns with the option of remaining
complaints or
1 anonymous, where permissible under applicable laws. The external helpline
concerns from provides local, toll-free phone numbers that connect employees and external
external parties to a multilingual reporting service'. The FAQ document included on its
individuals and Ethics Point website indicates: 'EthicsPoint is a comprehensive and confidential
communities reporting service created by NAVEX Global to assist employees who wish to
anonymously report misconduct or policy violations.' In addition, it indicates in its
Indicator Code Indicator name Score (out of 2) Explanation
ESG Report 2021: 'Apple’s external helpline is available to employees and external
parties to report concerns, and also provides the option of anonymous reporting,
where permissible'. [Business Conduct Policy, 10/2020: apple.com] & [ESG Report
2021, 2021: s2.q4cdn.com]
Score 2
• Not Met: Describes accessibility and local languages and stakeholder awareness:
Its ESG Report 2021 reads: 'The external helpline is available 24/7, and provides a
multilingual reporting service with local, toll-free numbers'. However, no further
information describing how it ensures that all affected external stakeholders at its
own operations are aware of the grievance mechanism (e.g., specific
communication(s)). [ESG Report 2021, 2021: s2.q4cdn.com]
• Not Met: Communities access mechanism direct or through suppliers
• Not Met: Expect supplier to convey expectation to their own suppliers
C.3 Users are The individual elements of the assessment are met or not as follows:
involved in the Score 1
design and • Met: Engages users to create or assess system: In its Supplier Responsibility 2019
Progress Report, the Company indicates: 'Direct feedback from supplier employees
performance of
helps us to better understand their experience so we can work with suppliers to
the
identify opportunities for improvement. In 2019, we partnered with workplace
channel(s)/mec rights experts to deploy mobile surveys that measure supplier employees’ general
hanism(s) satisfaction at work; the extent to which they felt their workplace rights were
respected; management's responsiveness to grievances; and their rating of
workplace amenities such as food service, facilities, and living conditions.' In
addition, it states in its 2019 Progress Report: 'In order to verify the effectiveness of
channels, we interview numerous supplier employees during annual assessments in
1.5
their local language without their managers present. These interviews seek to
ensure that supplier employees have received training and are aware of proper
channels to voice concerns'. [Supplier Responsibility 2019 Progress Report, 2019:
apple.com] & [Supplier Responsibility 2020 Progress Report, 05/2020: apple.com]
• Not Met: Examples (at least two) of how they do this
Score 2
• Met: Engages with potential or actual users on the improvement of the
mechanism: As indicated above, the Company engaged workers in the supply chain
including questions about operation of grievance mechanisms. [Supplier
Responsibility 2019 Progress Report, 2019: apple.com] & [Supplier Responsibility
2020 Progress Report, 05/2020: apple.com]
• Not Met: Provides user engagement example (at least two) on improvement
C.4 Procedures The individual elements of the assessment are met or not as follows:
related to the Score 1
mechanism(s)/c • Not Met: Response timescales and how complainants will be informed
• Not Met: Describe support (technical, financial,etc) available for equal access by
hannel(s) are
0 complainants
equitable,
Score 2
publicly • Not Met: Describe types of outcome to complainant through use of mechanism
available and • Not Met: Escalation to senior/independent level
explained
C.5 Prohibition of The individual elements of the assessment are met or not as follows:
retaliation for Score 1
raising • Met: Public statement prohibiting retaliation: In its Business Conduct Policy, the
Company states: ' Apple will not retaliate—and will not tolerate retaliation—
complaints or
against any individual for reporting a good-faith concern or complaint to a
concerns
manager, People, Legal, Business Assurance and Audit, Finance, or Business
Conduct, or for participating in the investigation of a concern or complaint. We do
not tolerate knowingly false reporting.' In addition, it indicates in its ESG Report
2021: 'Apple’s external helpline is available to employees and external parties to
report concerns, and also provides the option of anonymous reporting, where
0.5 permissible.' [Business Conduct Policy, 10/2020: apple.com] & [ESG Report 2021,
2021: s2.q4cdn.com]
• Not Met: Practical measures to prevent retaliation: The Company indicates in its
Ethics Point FAQ document: 'Unless you identify yourself, all reports received
through EthicsPoint are anonymous. NAVEX values your right to privacy and will
not disclose any information that would identify you without your express
permission or unless legally required to do so. In most European countries,
anonymous allegations can only be used for accounting and internal controls
issues, including fraud, inaccurate records, auditing and other financial matters.'
However, no further evidence describing additional measures to prevent retaliation
was found. [Ethics Point FAQ, N/A: secure.ethicspoint.com]
Indicator Code Indicator name Score (out of 2) Explanation
Score 2
• Not Met: Company indicate it will not retaliate against workers/stakeholders
• Not Met: Expects suppliers to prohibit retaliation against workers/stakeholders:
In its Supplier Code of Conduct, the Company indicates: 'Supplier shall protect
whistleblower confidentiality and prohibit retaliation.' However, the grievance
channel is not open to other stakeholders beyond workers. [Supplier Code of
Conduct & Standards, 01/2022: apple.com]
C.6 Company The individual elements of the assessment are met or not as follows:
involvement Score 1
with state- • Not Met: Complainants not asked to waive rights
• Not Met: Company does not require confidentiality provisions
based judicial
0 Score 2
and non-
• Not Met: Will work with state based non judicial mechanisms
judicial • Not Met: Example of issue resolved (if applicable)
grievance
mechanisms
C.7 Remedying The individual elements of the assessment are met or not as follows:
adverse Score 1
impacts • Met: Describes how remedy has been provided: In its Supplier Responsibility
2020 Progress Report, the Company indicates: 'If debt-bonded labor is found, we
require remediation through the immediate return of personal identity documents
and direct remedy, meaning suppliers repay the employees for any fees paid. We
then verify that repayments were made in full and on time through an independent
auditor.[…] $32.3M Recruitment fees repaid by suppliers to 36,599 supplier
employees since 2008. […] $1.3M Recruitment fees repaid to 462 supplier
employees in 2019'. [Supplier Responsibility 2020 Progress Report, 05/2020:
apple.com]
Score 2
• Met: Changes to systems, processes and practices to stop similar impact: The
Company discloses information about the changes to prevent debt-bonded labor:
'In 2019 […] we continued mapping the higher-risk migration corridors for foreign
contract workers in our supply chain using our own data and information from the
ILO and the U.S. State Department in order to more deeply understand challenges
at the source of labor recruitment. We also convened an expert group of leading
government policymakers, non-governmental organizations, and researchers to
further strengthen our efforts. We also spoke directly to migrant workers and labor
1.5 agents in our supply chain to better understand their experiences. […] we
strengthened our partnership with the International Organization for Migration
(IOM) […] and began to integrate labor agent audits into our responsible labor
recruitment program. Consulting closely with stakeholders and the IOM, we
created the Responsible Recruitment Due Diligence Toolkit (“the Toolkit”).' In
addition, in its 2019 Progress Report, it indicates: 'In 2018, we went further to
prevent debt-bonded labor in our supply chain, and steps were taken to limit the
amount of subcontracting for custodial staff in our retail stores. We also mapped
the primary geographic corridors where foreign contract workers enter our supply
chain and where they work. As a result, programs were put in place to strengthen
debt-bonded labor prevention in high-risk regions. In 2018, we also worked closely
with suppliers that hire foreign contract workers to implement stricter standards to
assess the labor brokers who provide personnel to their facility. These efforts
included implementing enhanced training on topics required by our Code, such as
conducting worker interviews and self-assessments. This capability building effort
enables suppliers to conduct more comprehensive due diligence in their labor
supply chain, and to ensure no recruitment fees are charged.' [Supplier
Responsibility 2019 Progress Report, 2019: apple.com] & [Supplier Responsibility
2020 Progress Report, 05/2020: apple.com]
• Not Met: Describe approach to monitoring implementation of agreed remedy
• Not Met: Approach to learning from incident to prevent future impacts
C.8 Communication The individual elements of the assessment are met or not as follows:
on the Score 1
effectiveness of • Not Met: Number grievances filed, addressed or resolved and outcome achieved:
The Company reports in its SR 2022: 'In 2021, the reports we received from
grievance
supplier employees via hotlines included issues related to wages and benefits,
mechanism(s)
0 employee relations, amenities at supplier facilities, workforce stability, and health
and and safety. After further investigation of the reports we received, approximately 40
incorporating percent of them uncovered violations of our Code. In each case, we investigated
lessons learned and worked directly with the suppliers to drive improvement and correct any
compliance issues found.' However, no further information with respect the total
number of human rights grievances received, addressed or resolved from internal
Indicator Code Indicator name Score (out of 2) Explanation
and external stakeholders was found. [Supplier Responsibility 2022 Progress
Report, 2022: apple.com]
• Not Met: How lessons from mechanism improve management system
Score 2
• Not Met: Evaluation of the channel/mechanism and changes made as result
• Not Met: Describes procedures to address delays of outcomes agreed with
stakeholders
D. Performance: Company Human Rights Practices (25% of Total)
Indicator Code Indicator name Score (out of 2) Explanation
D.4.1.b Living wage (in The individual elements of the assessment are met or not as follows:
the supply Score 1
chain) • Not Met: Discloses living wage requirements in supplier code or contracts: The
Company indicates in its Supplier Code of Conduct: 'Supplier shall pay at least the
minimum wage and provide any benefits required by law and/or contract. Supplier
shall compensate workers for overtime hours at the legal premium rate.' However,
0 no reference found to living wage, covering basic needs of employees and families
or dependants, and some discretionary income. [Supplier Code of Conduct &
Standards, 01/2022: apple.com]
• Not Met: Improving living wage practices of suppliers
Score 2
• Not Met: Assessment of number affected by payment below living wage
• Not Met: Provides analysis of trends demonstrating progress
D.4.2 Aligning The individual elements of the assessment are met or not as follows:
purchasing Score 1
decisions with • Not Met: Avoids business model pressure on HRs (purchasing practices)
• Not Met: Practices adopted to pay suppliers in line with agreed timeframes
human rights
0 • Not Met: Review own operations to mitigate negative impact
Score 2
• Not Met: Meets all requirements under score 1
• Not Met: Examples of how it assessed, addressed and change purchasing
practices
D.4.3 Mapping and The individual elements of the assessment are met or not as follows:
disclosing the Score 1
supply chain • Met: Identifies direct and indirect suppliers back to manufacturing sites (factories
or fields): The Company indicates in its 'Combat Human Trafficking' Statement
2020: 'In 2010, we were one of the first companies to map minerals in our supply
chain from supplier manufacturing sites back to the smelter and refiner level for
tin, tantalum, tungsten, and gold (“3TG”). In 2014, we started mapping our cobalt
supply chain.' See below how the Company discloses a list including materials,
manufacturing and assembly sites. [Statement on Efforts to Combat Human
1.5
Trafficking and Slavery in Supply Chain 2020, 03/2021: apple.com]
Score 2
• Met: Discloses names and locations of significant parts of SP and why: The
Company discloses its Supplier List: 'The Apple Supplier List represents 98 percent
of our direct spend for materials, manufacturing, and assembly of our products
worldwide for fiscal year 2020.' The list includes suppliers' names and location.
[Supplier List FY 2020, 2021: apple.com]
• Not Met: Discloses which direct or indirect suppliers is involved in higher-risk
activities
D.4.4.b Prohibition of The individual elements of the assessment are met or not as follows:
child labour: Score 1
Age verification • Met: Child Labour rules in codes or contracts: The supplier code indicates:
Supplier shall employ only Workers who are at least 15 years of age, or the
and corrective
applicable minimum legal age for employment, or the applicable age for
actions (in the
completion of compulsory education, whichever is highest. […] Supplier shall
supply chain) establish and implement appropriate age documentation and verification
1.5 management systems to ensure that Underage Workers are not working on site.
The systems shall cover Supplier’s operations, Third Party Employment Agencies,
and Qualified Educational Programs.[…] If any Active Underage Worker, Historical
Underage Worker, or Terminated Underage Worker is found either through an
external audit or self-review, Supplier shall notify Apple immediately and shall
implement a remediation program as directed by Apple'. The document includes
details of the different steps for remediation. [Supplier Code of Conduct &
Standards, 01/2022: apple.com]
Indicator Code Indicator name Score (out of 2) Explanation
• Met: How working with suppliers on child labour: The Company indicates: 'We
also continued to partner with Pact, an international development organization, to
deliver rights awareness training to miners, youth, and community officials in
artisanal and small-scale mining (ASM) communities in the DRC. In 2021, Pact
organized 72 neighborhood committee meetings reaching over 31,987 community
members — including more than 15,000 children — on a range of human rights
issues, with a heavy focus on raising awareness about child labor'. [Supplier
Responsibility 2022 Progress Report, 2022: apple.com]
Score 2
• Not Met: Assessement of number affected by child labour in supply chain
• Met: Analysis of trends in progress made: Each year the Company discloses
information about the number of child labour cases found in its Supplier
Responsibility Reports. For instance in its Supplier Responsibility 2020 Progress
Report, the Company indicates that it uncovered one case of Underage Labor. It
also states: 'Based on the reduction in age-related violations over the last seven
years, our efforts to educate suppliers and to work closely with them on Code
requirements have driven significant progress in this area'. Despite not presenting
year-on-year figures, the Company explains analyses the trend over the last ones.
[Supplier Responsibility 2020 Progress Report, 05/2020: apple.com]
D.4.5.b Prohibition of The individual elements of the assessment are met or not as follows:
forced labour: Score 1
Recruitment • Met: Debt and fees rules in codes or contracts: In its Supplier Responsibility
Standard, the Company indicates: 'Workers shall not be required to pay employers’
fees and costs
or their agents’ recruitment fees or other similar fees to obtain their employment.
(in the supply
If such fees are found to have been paid by Workers, such fees shall be repaid to
chain) the worker. […] Deposits from Workers are prohibited unless required by
Applicable Laws and Regulations. […] Personal loans to Workers or job seekers
under circumstances where repayment terms could be construed as debt bondage
or forced labor are prohibited'. [Supplier Code of Conduct & Standards, 01/2022:
apple.com]
• Met: How working with suppliers on debt & fees: The Company indicates:
'Consulting closely with stakeholders and the IOM, we created the Responsible
Recruitment Due Diligence Toolkit (“the Toolkit”). The Toolkit offers suppliers and
labor agents a comprehensive “how-to” guide with practical tools covering six core
1.5 areas: embedding responsible recruitment into policies and management systems;
identifying and assessing risks; preventing and mitigating risks; tracking
implementation and results; communicating how risks are addressed; and
providing access to remediation. […] We began holding training sessions on the
Toolkit in those countries where the most prevalent migration corridors in our
supply chain exist, including Malaysia, Singapore, and the Philippines. […] We also
strengthened our pre-departure orientation (PDO) training for labor agencies and
civil society organizations that are certified by the government to carry out PDO
sessions across all industries'. [Supplier Responsibility 2020 Progress Report,
05/2020: apple.com]
Score 2
• Met: Assessment of the number affected by payment of recruitment fees: The
Company discloses in its SR Report 2022: '$33.2M in recruitment fees paid back by
suppliers to 37,322 of their employees since 2008' [Supplier Responsibility 2022
Progress Report, 2022: apple.com]
• Not Met: Analysis of trends in progress made
D.4.5.d Prohibition of The individual elements of the assessment are met or not as follows:
forced labour: Score 1
Wage practices • Not Met: Requirement for suppliers to pay workers in full and on time in codes or
contracts
(in the supply 0
• Not Met: How working with supply chain to pay workers regularly and on time
chain)
Score 2
• Not Met: Assessment of the number affected by failure to pay directly
• Not Met: Provides analysis of trends demonstrating progress
Indicator Code Indicator name Score (out of 2) Explanation
D.4.5.f Prohibition of The individual elements of the assessment are met or not as follows:
forced labour: Score 1
Restrictions on • Met: Free movement rules in codes or contracts: In its Supplier Responsible
Standards, the Company indicates: 'Workers shall retain possession or control of all
workers (in the
identity documents, such as passports, identity papers, travel documents, and
supply chain)
other personal legal documents. Supplier shall not require surrender of Workers’
original identity documents, withhold Workers’ original identity documents, or
restrict Workers’ access to original identity documents for any reason. […] All
Workers shall have the right to freely enter into and to terminate their
0.5 employment. […] Supplier shall not confine or restrict Worker’s freedom of
movement inside the place of production or Supplier-provided facilities [...]
Suppliers shall not have direct control of, or access to, Worker bank accounts other
than to make direct deposits of compensation'. [Supplier Code of Conduct &
Standards, 01/2022: apple.com]
• Not Met: How working with suppliers on free movement
Score 2
• Not Met: Assessment of the number affected by retaining docs or restricting
movement
• Not Met: Provides analysis of trends demonstrating progress
D.4.6.b Freedom of The individual elements of the assessment are met or not as follows:
association and Score 1
collective • Met: FoA & CB rules in codes or contracts: In its Supplier Responsible Standards,
the Company indicates: ' Supplier shall freely allow Workers’ lawful rights to
bargaining (in
associate with others, form, and join (or refrain from joining) organizations of their
the supply
choice, and bargain collectively, without interference, discrimination, retaliation, or
chain) harassment.' They also indicate that 'Where Applicable Laws and Regulations
substantially restrict freedom of association, Supplier shall allow alternative means
for Workers to individually and collectively engage with Supplier, including
processes for Workers to express their Grievances and protect their rights
regarding working conditions and terms of employment'. [Supplier Code of Conduct
& Standards, 01/2022: apple.com]
• Met: How working with suppliers on FoA and CB: The Company reports in its SR
2022: 'In 2021, we continued our partnership with the ILO, including in Vietnam
where we worked to help educate and raise awareness among our suppliers about
1
new worker protections and labor reforms being implemented across the country,
including requirements related to freedom of association and collective bargaining'.
[Supplier Responsibility 2022 Progress Report, 2022: apple.com]
Score 2
• Not Met: Assessment of the number affected by restrictions to FoA and CB in the
SP
• Not Met: Provides analysis of trends demonstrating progress: Each year the
Company discloses some information about freedom association and collective
bargaining non-compliances found during audits. For example, in SR 2019, the
Company indicates that 'A lower percentage of assessment violations were found
relating to anti-harassment, prevention of underage labor, and freedom of
association and collective bargaining.' However, no evidence found of
trends/analysis demonstrating evolution over time. No new relevant evidence
found in latest review. [Supplier Responsibility 2019 Progress Report, 2019:
apple.com] & [Supplier Responsibility 2022 Progress Report, 2022: apple.com]
D.4.7.b Health and The individual elements of the assessment are met or not as follows:
safety: Score 1
Fatalities, lost • Met: Sets out clear Health and Safety requirements: The Company indicates:
'Supplier shall identify, evaluate, and manage occupational health and safety
days, injury,
hazards through a prioritized process of hazard elimination, substitution,
occupational
engineering controls, administrative controls, and/or personal protective
disease rates equipment'. The Company sets out Health and Safety requirements in its Supplier
(in the supply Responsibility Standards, including the following topics: Regulatory Permits;
chain) 0.5 Occupational Health and Safety Risk Assessment; Machine Guarding; Electrical
Safety; Lockout/Tagout; High Risk Tasks; Chemical Management; Industrial
Hygiene; Medical Surveillance; Personal Protective Equipment (PPE); Ergonomics;
Combustible Dust; Training and Communication; and Documentation. [Supplier
Code of Conduct & Standards, 01/2022: apple.com]
• Not Met: Injury rate disclosures and lost days (or near miss disclosures) for the
last reporting period
• Not Met: Fatalities disclosures for lasting reporting period
• Not Met: Occupational disease rates for the last reporting period
Indicator Code Indicator name Score (out of 2) Explanation
Score 2
• Met: How working with suppliers on H&S: The Company indicates in its SR 2020:
'If we identify non-compliance with our Standards during an assessment, we hold
our suppliers accountable and work collaboratively through tailor-made Corrective
Action Plans, online training materials, and on-site coaching. Through this direct
engagement, we provide solutions for technical problems, close gaps in
management systems, and help to develop a sustainable culture of safety. In 2013,
we launched the Apple Environmental Health and Safety Academy (“EHS
Academy”). Over a four-year period, EHS managers from over 270 supplier sites in
China took courses and implemented projects to improve their site’s performance
across a number of critical areas, including chemical management, emergency
preparedness, and safety equipment. […] In 2019, we launched the Environmental
Health and Safety Leadership Workshop (“the Workshop”), which provides training
to supplier management teams on how to act as role models for best practices in
creating safe, healthy workplaces as well as ways to better engage and
communicate with their employees on safety-related topics. The Workshop has
received positive feedback from supplier management teams and is continuing to
scale to new facilities.' In addition, in its SR 2022: 'In addition to audits and ongoing
capability-building,
we consistently look for opportunities to engage earlier and prevent issues before
they materialize. In 2020, we set out to proactively improve safety by mapping risks
related to machine safety across our supply chain, and identifying those high-
priority suppliers that required additional support. In 2021, 212 supplier sites
received customized support in order to improve capabilities related to assessing
the safety of machinery during their procurement processes, conducting safety
reviews before machine sign-off, and instruction on how to safely operate
machines during production and maintenance.' [Supplier Responsibility 2020
Progress Report, 05/2020: apple.com] & [Supplier Responsibility 2022 Progress
Report, 2022: apple.com]
• Not Met: Assessment of the number affected by H&S issues in the SP
• Not Met: Provide analysis of trends in progress made
D.4.8.b Women's rights The individual elements of the assessment are met or not as follows:
(in the supply Score 1
chain) • Met: Women's rights in codes or contracts: The Supplier Responsibility Standards
include some provisions related to women's rights, such as: 'Supplier shall not
Discriminate against any Worker based on race, color, age, gender, […], gender
identity [...] in hiring and employment practices. […] Supplier shall have a system to
discipline supervisors, managers, or Workers who engage in any Physical Abuse,
Sexual Harassment or sexual abuse, Psychological Harassment, or Verbal
Harassment or Verbal Abuse, through measures such as compulsory counselling,
warnings, demotions, and terminations or any combination thereof, regardless of
whether such action was intended as a means to maintain labor discipline. […]
Security Practices. All security practices shall be gender appropriate and
nonintrusive. […] Pregnancy and Nursing Mothers Anti-Discrimination. Supplier
shall comply with all Applicable Laws and Regulations regarding pregnancy and
postnatal employment protections, benefits, and pay. Supplier shall make
0.5 reasonable accommodations for nursing mothers unless prohibited by Applicable
Laws and Regulations. Supplier shall not (i) refuse to hire an applicant for a non-
Hazardous position or (ii) terminate a Worker’s employment solely based on the
Worker’s pregnancy or nursing status. Supplier shall not prohibit female Workers
from becoming pregnant nor threaten female Workers with adverse employment
consequences, including dismissal, loss of seniority, or deduction of wages, in order
to discourage them from becoming pregnant. […] Pregnancy and Medical Testing
Supplier shall not require pregnancy tests or Medical Tests, including but not
limited to Hepatitis B or HIV, either as a condition for employment or as a
requirement for continued employment. […]' [Supplier Code of Conduct &
Standards, 01/2022: apple.com]
• Not Met: How working with suppliers on women's rights
Score 2
• Not Met: Assessment on the number affected by discrimination or unsafe
working conditions
• Not Met: Provide analysis of trends in progress made
Indicator Code Indicator name Score (out of 2) Explanation
D.4.9.b Working hours The individual elements of the assessment are met or not as follows:
(in the supply Score 1
chain) • Met: Working hours in codes or contracts: Its Supplier Code of Conduct includes a
provision with respect Working hours: 'A workweek shall be restricted to 60 hours,
including overtime, and workers shall have at least one day off every seven days
except in emergencies or unusual situations. Regular workweeks shall not exceed
48 hours. Supplier shall follow all applicable laws and regulations with respect to
working hours and days of rest, and all overtime must be voluntary. [Supplier Code
of Conduct & Standards, 01/2022: apple.com]
• Not Met: How working with suppliers on working hours: The Company indicates
in its SR 2022 Progress Report: 'One example of how we’ve driven improvements in
supplier capability and performance is in compliance with our working hours
standard. We review working hours as part of our assessments and implement
Corrective Action Plans as needed. In addition, for nearly 10 years, we have
0.5 monitored the working hours of more than 1.5 million workers on a weekly basis,
and validated the reporting of working hours through focused audits. In FY2021,
our suppliers achieved 95 percent compliance with our working hours
requirements, a 2 percent increase from the previous year.' However, this
subindicator looks for evidence of working with manufacturing suppliers to
proactively improve their performance. Current evidence seems to focus in
monitoring compliance and application of corrective measures where non-
compliances are found. [Supplier Responsibility 2022 Progress Report, 2022:
apple.com]
Score 2
• Not Met: Assessment of number affected by excessive working hours
• Met: Provide analysis of trends in progress made: See above. In FY2021, 'suppliers
achieved 95 percent compliance with our working hours requirements, a 2 percent
increase from the previous year'. [Supplier Responsibility 2022 Progress Report,
2022: apple.com]
D.4.10.a Responsible The individual elements of the assessment are met or not as follows:
mineral Score 1
sourcing: • Met: Due diligence in accordance with OECD Guidance in supplier contracts: The
Supplier Responsibility Standards that 'Suppliers shall develop an appropriate
Arrangements
management system to conduct due diligence in accordance with the standards set
with suppliers
out in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
and from Conflict-Affected and High-Risk Areas (the “OECD Guidance”) and other
smelters/refine applicable international standards [...]'. In addition, the Company indicates in its SR
rs in the 2021: 'Suppliers are required to adhere to our Code and Standards'. [Supplier Code
mineral of Conduct & Standards, 01/2022: apple.com] & [Supplier Responsibility 2021
resource supply Progress Report, 2021: apple.com]
chains • Not Met: Works with smelters/refiners and suppliers to build capacity: The
Company indicates in its Conflict Minerals Report 2021: 'We provide annual 3TG
due diligence training webinars to suppliers that have reported 3TG to Apple. In
addition, our SupplierCare portal provides suppliers with access to online training
materials (in multiple languages) that focus on Apple’s due diligence expectations
0.5
and requirements for 3TG reporting. [...] In addition to conducting our own supply
chain due diligence, we work closely with third party audit programs — in
particular, the RMI and the London Bullion Market Association (“LBMA”)—to
identify risks at the smelter, refiner, and mining levels and to help strengthen
industry auditing and certification bodies. The Risk Readiness Assessment (“RRA”)
— developed by Apple in 2016 and widely adopted by industry via the RMI in 2018
— continued to be utilized by downstream companies and upstream refiners and
mining companies, with 366 RRAs completed as of December 31, 2021, compared
with 341 completed as of 2020. The Copper Mark, an assurance framework for
responsible copper production, also applied the RRA as part of its criteria to assess
copper producers at 31 sites, an increase from 16 in 2020. Apple continues to use
the RRA on a targeted basis through these industry platforms to assess risks in our
global supply chain, with a particular focus on new smelters and refiners that enter
our supply chain and on additional minerals beyond 3TG.' It is not clear, however,
how it works with smelters/refiners in capacity building activities. [Conflict
Minerals Report 2021, 2022: apple.com]
Indicator Code Indicator name Score (out of 2) Explanation
Score 2
• Met: Contractual requirement to disclosure smelter/refiner information: See
above about adherence requirement. In its Supplier Responsible Standards
document, the Company includes some provision related to the Reporting of the
Due Diligence Process: 'Suppliers shall provide evidence of their Supply Chain
mapping and verification or audit of identified Material Processors according to
specific risks and Relevant Materials: Conflict issues pertaining to tin, tantalum,
tungsten, and gold shall be reported to Apple twice annually […]; Cobalt and other
Relevant Mineral Supply Chain mapping shall be reported annually […]' [Supplier
Code of Conduct & Standards, 01/2022: apple.com]
• Met: Contractual requirement covers all minerals: See above. Requirement refers
to 3TG, cobalt and other relevant mineral. In addition, in its SR 2020 Progress
Report, the Company states: ' In 2018, we expanded the scope of our Responsible
Sourcing Standard to include all materials. […] We also map and conduct due
diligence on other materials such as mica, titanium, and lithium.' [Supplier Code of
Conduct & Standards, 01/2022: apple.com] & [Supplier Responsibility 2020
Progress Report, 05/2020: apple.com]
D.4.10.b Responsible The individual elements of the assessment are met or not as follows:
mineral Score 1
sourcing: Risk • Met: Risk identification and disclosure in line with OECD Guidance: One activity to
identify risks consists in requiring suppliers utilizing 3TG to submit an industry-wide
identification
standard Conflict Minerals Reporting template. Suppliers are also required ‘to
and responses
inform Apple immediately if they identify certain high risks included in Annex II of
in mineral the OECD Due Diligence Guidance, such as conflict or human rights risks associated
supply chain with 3TG.' It also indicates: '[...] we work closely with third party audit programs—
in particular, the RMI and the London Bullion Market Association (“LBMA”)—to
identify risks at the smelter, refiner, and mining levels and to help strengthen
industry auditing and certification bodies. The Risk Readiness Assessment
(“RRA”)— developed by Apple in 2016 and widely adopted by industry via the RMI
in 2018—continued to be utilized by downstream companies and upstream refiners
and mining companies, with 366 RRAs completed as of December 31, 2021,
compared with 341 completed as of 2020'. Previous conflict mineral report also
indicated that RRA includes assessment categories related to how smelters and
1.5
refiners trat artisanal and small-scale mining formalization. It also indicates that
(RRA) helps assessing risks in its supply chain beyond those associated with conflict,
such as social, environmental and human rights risks. [Conflict Minerals Report
2021, 2022: apple.com]
• Met: Identification of smelter/refiners and OECD Guidance: In addition, it
indicates that it collects and processes 'data provided by suppliers through their
completion of the CMRT to map our supply chain to the smelter and refiner level
and, to the extent available, to the mining level. […] Apple believes third party
audits remain foundational to robust due diligence systems. In particular, third
party audits play a significant role in providing assurance that smelters and refiners
have appropriate due diligence systems in place, while helping to ensure that
operations and sourcing practices are aligned with the OECD Due Diligence
Guidance, and do not support conflict, including in the DRC or adjoining countries.
Since 2015, we have continued to reach a 100 percent rate of participation in third
party audit programs by identified smelters and refiners in our supply chain'.
[Conflict Minerals Report 2021, 2022: apple.com]
Indicator Code Indicator name Score (out of 2) Explanation
Score 2
• Met: Discloses smelters/refiners judged in line with OECD Guidance: The
Company discloses its Smelters and refiners reported in Apple’s supply chain List in
its Conflict Mineral Report 2021. In addition, it indicates: 'As of December 31, 2021,
based on our due diligence efforts, including the information provided by our
suppliers, Apple believes that the smelters and refiners listed in Annex I were used
to process 3TG in our products at some point during 2021.Through our smelter and
refiner identification and validation process, we have identified a total of 265
smelters and refiners that processed 3TG in our supply chain during 2021. Of these
265 smelters and refiners: 12 were removed including those that: previously
participated in but subsequently stopped participating in a third party audit
program; were not willing to participate in or complete a third party audit within
given timelines; exceeded third party audit corrective action plan timelines; or
failed to meet Apple’s Supplier Code, Responsible Sourcing Standard, or 3TG
mineral requirements; 253 remained in Apple’s 3TG supply chain as of December
31, 2021. [...] Of all 253 smelters and refiners of 3TG determined to be in our
supply chain as of December 31, 2021, Apple found no reasonable basis for
concluding that any such smelter or refiner sourced 3TG that directly or indirectly
financed or benefited armed groups in the DRC or an adjoining country. Of these
253 smelters and refiners, 30 are known to be directly sourcing from the DRC or an
adjoining country, of which 100 percent continued to participate in a third party
audit as of December 31, 2021 which involves a review of the traceability of the
smelter’s or the refiner’s 3TG, as well as a validation of its due diligence systems
and country of origin information. The foregoing does not include smelters and
refiners indirectly sourcing from the DRC or adjoining countries by acquiring 3TG
from these 30 smelters and refiners.' As indicated above, Apple continued to
achieve a 100 percent rate of participation in third party audits since 2015. [Conflict
Minerals Report 2021, 2022: apple.com]
• Not Met: Risk identification and disclosure covers all minerals: The Company's
Conflict Mineral Report 2021 is focused only in 3TG minerals (see Annex I: Smelter
and Refiner Lists) [Conflict Minerals Report 2021, 2022: apple.com]
D.4.10.c Reporting on The individual elements of the assessment are met or not as follows:
responsible Score 1
sourcing of • Met: Describes mineral risk management plan for supply chain: The Company
describes the following as Strategy to Respond to Identified Risks: 'we implement
minerals
our due diligence program and conduct supply chain analysis by leveraging
information gained from independent research, engaging with civil society groups
and rightsholders, analyzing third party audits, and working directly with smelters
and refiners to respond to risks identified in our supply chain. We closely monitor
completion of third party audits and corrective action plans by the smelters and
refiners in our supply chain.. [...] we analyze incident data provided by ITSCI and
RCS Global Group’s Better Mining program (“Better Mining”), two upstream
traceability and due diligence programs that monitor tin, tantalum, and tungsten
mines in the DRC and across the African Great Lakes region. We work with these
programs to help develop their incident review processes, and review and monitor
incidents generated through their respective reporting systems, including reviewing
corrective actions and confirming incidents are closed in accordance with the
programs’ criteria. [...] Innovating Responsible Gold Sourcing: Apple is pioneering
industry-leading traceability mechanisms for recycled materials to build a supply
0.5 chain of exclusively recycled gold. In 2021, for the first time, we used 100 percent
certified recycled gold in an Apple product: the plating of the main logic board and
the wire in the front and rear cameras for iPhone 13.[...] In 2021, we continued to
fund and scale the Salmon Gold project with Tiffany & Co., led by RESOLVE, a
sustainability non-profit. The Salmon Gold project works with small-scale miners
and Indigenous Peoples in remote regions of the Yukon, Alaska, and British
Columbia to support a mining practice that helps restore rivers and streams so that
salmon and other fish can thrive. Since RESOLVE first introduced the Salmon Gold
project in 2017, the organization has connected local placer miners,
environmentalists, and government agencies to mitigate the damage done by
historic mining activities. The gold mined from this project is then traced from its
origin to a refiner in Apple’s supply chain using blockchain technology.'. [Conflict
Minerals Report 2021, 2022: apple.com]
• Not Met: Monitoring, tracking and whether better risk prevention/mitigation
over time
• Not Met: Disclose better risk prevention/mitigation over time
Score 2
• Not Met: Suppliers and stakeholders engaged in risk management strategy
• Not Met: Risk management and response processes cover all minerals
E. Performance: Responses to Serious Allegations (20% of Total)
Indicator Code Indicator name Score (out of 2) Explanation
E(1).0 Serious • Area: Working Hours; forced labour
allegation No 1
• Headline: Wistron iPhone plant accused of labour laws violations

• Story: On December 12, 2020, workers of Wistron, an Apple’s iPhone assembly

contractor, rioted in a plant near the Indian city of Bengaluru over unpaid wages.
Local media report that around 2,000 staff protested at not having been properly
paid for months, and that iPhones may have been looted and the factory
damaged. The factory opened in August 2020 and was thought to assemble the
iPhone SE and iPhone 12. Apple outsourced Indian iPhone assembly to the
Taiwanese company Wistron, which in turn outsourced recruitment and payroll to
Indian companies. The India companies were accused of not paying staff promptly
or properly for several months. Videos made by employees inside the factory
showed men breaking security cameras, windows and other equipment with rods
and sticks. Police allegedly arrested 149 people over the violence.

On December 21, 2020, press sources reported that an enquiry following the
uprising initiated by the state government of Karnataka in southern India found
violations of labour laws by Wistron Corporation. Workers alleged management
declined their request of payment of back wages, which have accumulated for
three months or more for some even as they are forced to work 12-hour shifts.
The investigation by the state Department of Factories, Boilers, Industrial Safety &
Health found that the Company had illegally increased working hours from 8 hours
to 12 hours a day and did not pay the stipulated overtime wages. Furthermore, the
Company was allegedly guilty of non-payment of wages on time according to
Karnataka laws. The report also alleged that the Company's attendance monitoring
system undercounted the number of hours worked by employees.
[Deccan Herald, 14/12/2020, ''Apple probing possible supplier rules violations by
Wistron Corp's Bengaluru facility: Report'': deccanherald.com] [Reuters News,
13/12/2020, ''Apple probes supplier after workers at Wistron plant in India
rampage'': reuters.com] [The Register, 14/12/2020, ''iPhone factory workers riot
over unpaid wages in India'': theregister.com] [business-standard, 22/12/2020,
''Top cop to oversee probe into violence at Wistron's manufacturing facility''
: business-standard.com]
E(1).1 The company The individual elements of the assessment are met or not as follows:
has responded Score 1
publicly to the • Met: Public response: In response to the allegation, the Company stated in an
email that: "We have teams on the ground and have immediately launched a
allegation
detailed investigation at Wistron's Narasapura facility". Adding, it was dedicated to
ensuring everyone in its supply chain was treated with dignity and respect.
[Reuters News, 13/12/2020: reuters.com]
1
Score 2
• Not Met: Detailed response: The Company stated that Wistron had failed to
implement proper working hour management processes, which "led to payment
delays for some workers in October and November”. However, the company did
not respond to the allegation on the illegal increase of working hours from 8 hours
to 12 hours a day. Thereby, the company did not address all aspects of the
allegation in detail. [Reuters News, 19/12/2020,: reuters.com]
E(1).2 The company The individual elements of the assessment are met or not as follows:
has Score 1
investigated • Not Met: Engaged with stakeholders: The Company stated: "We have teams on
the ground and have immediately launched a detailed investigation at Wistron's
and taken
Narasapura facility. [...] Our main objective is to make sure all the workers are
appropriate
treated with dignity and respect, and fully compensated promptly". However,
action there is no indication that the company or the supplier engaged with the affected
stakeholders as part of the investigation. [Reuters News, 19/12/2020:
reuters.com]
0
• Not Met: Identified cause: The Company stated that Wistron had failed to
implement proper working hour management processes, which "led to payment
delays for some workers in October and November”. However, the company did
not present investigative results on the causes underlying the illegal increase of
working hours from 8 hours to 12 hours a day. [Reuters News, 19/12/2020:
reuters.com]
Score 2
• Not Met: Identified and implemented improvements: Wistron said it is re-
structuring its teams and setting up 24-hour hotlines for employees to make
Indicator Code Indicator name Score (out of 2) Explanation
anonymous complaints. “Apple has sent a strong message to its suppliers, telling
them unequivocally that they need to adhere to its standards". However, Apple
has no own improvements and what Winstron has done does not qualify for
Apple. [Reuters News, 19/12/2020: reuters.com]
• Not Met: Stakeholder input to steps taken
E(1).3 The company The individual elements of the assessment are met or not as follows:
has engaged Score 1
with affected • Met: Provided remedy: Wistron said it was working hard to raise standards and
fix issues at the factory. It said it had paid all workers and introduced new hiring
stakeholders to
and payroll systems. [Reuters News, 19/12/2020: reuters.com]
provide for or
• Not Met: Evidence for lack of Impact or link
cooperate in 2
Score 2
remedy(ies) • Met: Remedy satisfactory to stakeholders: The CHRB did not find information
suggesting the affected stakeholders were dissatisfied with the remedy.
• Met: Remedy delivered: Winstron said it had paid all workers and introduced
new hiring and payroll systems.
• Not Met: Independent remedy process used
E(2).0 Serious • Area: Forced labour
allegation No 2
• Headline: Apple among companies accused of using suppliers linked to forced
labour in China

• Story: On March 1st, 2020, the Australian Strategic Policy Institute (ASPI)
released a report called "Uyghurs for sale" that named Apple among 83 companies
benefiting from the use of potentially abusive labour transfer programmes.
According to the report, more than 80,000 Uighur residents and former detainees
from the north-western region of Xinjiang, China have been transferred to
factories, implicating global supply chains. It is alleged that Muslim minorities are
working in forced labour conditions across the country. The ASPI report said that
workers live in segregated dormitories, are required to study Mandarin and
undergo ideological training. In addition, the think tank said that the workers were
allegedly transferred out of Xinjiang between 2017 and 2019 and claimed that
people are being effectively "bought" and "sold" by local governments and
commercial brokers. The ASPI used open-source public documents, satellite
imagery, and media reports, allowing to identify 27 factories in nine Chinese
provinces that have used labourers. The research found up to 560 Xinjiang workers
were transferred to work several factories including to Foxconn Technology, that
supplies brands such as Amazon, Apple, Dell, Google, Huawei and Microsoft. Other
factory implicated is O-Film Technology which supplies Apple, Huawei, Lenovo and
Samsung with camera and touchscreen components. ASPI researchers stated:
"This report exposes a new phase in China's social re-engineering campaign
targeting minority citizens, revealing new evidence that some factories across
China are using forced Uighur labour under a state-sponsored labour transfer
scheme that is tainting the global supply chain". The report calls on companies
mentioned to "conduct immediate and thorough human rights due diligence on its
factory labour in China, including robust and independent social audits and
inspections."

On July 20, 2020, O-Film subsidiary Nanchang, an Apple supplier, was one of the
eleven companies blacklisted by the U.S. Department of Commerce's Bureau of
Industry and Security over alleged human rights abuses involving Uighur Muslims
in China. According to the U.S. Department of Commerce, the O-Film subsidiary
was named on the list "in connection with the forced labour of Uighurs and other
Muslim minority groups in western China". Companies on the list must apply for
special licenses to access U.S. technologies.

On August 10, 2020, press reported that Apple imported clothes, probably
uniforms for staff in stores, from Changji Esquel Textile, a company that was facing
US sanctions over forced labour at a subsidiary firm in China’s Xinjiang region. The
US government in July 2020 imposed sanctions on Changji Esquel Textile, a unit of
textile Esquel group, along with 10 other Chinese companies for alleged human
rights violations in the Xinjiang region, including forced labour. The sanctions bar
the companies from buying US technology and other goods.
According to the press, a month before the sanctions were announced, Esquel had
sent a shipment of women’s cotton and elastane knit shirts to “Apple Retail
stores” in California, as the database run by the global shipping information
provider Panjiva showed. In 2018, a presentation at an industry conference by
Esquel’s chief executive highlighted Apple as a “major customer” of the firm’s
Indicator Code Indicator name Score (out of 2) Explanation
Vietnam arm, providing pictures of blue and red staff uniforms produced in its
factories. Those units were not on the sanctions list, but the shirts they produced
likely included cotton grown in Xinjiang, the region where Chinese authorities’
persecution of mostly Muslim minorities has included forced labour. Further notes
listed five locations where the firm operated inside Xinjiang. One was Changji, the
location of the sanctioned subsidiary.

On December 29, 2020, press sources reported that an investigation by the

Washington Post and the Tech Transparency Project, revealed that Companies
including Apple, Amazon and Tesla are sourcing parts from a Chinese supplier that
allegedly uses forces Muslim labour. The Tech Transparency Project found
documents detailing how Lens Technology, Apple’s supplier, uses “thousands of
Uyghur workers from the predominantly Muslim region of Xinjiang” in its factories.
Lens Technology is one of at least five companies connected to Apple's supply
chain that have now been linked to alleged forced labour from the Xinjiang region.
In the beginning 2020, Congress introduced a bill that would keep goods made
with forced labour in the Uyghur region of China from entering the US and that
companies would be held responsible for such human rights violations. The bill
passed in the House back in September 2020. The Washington Post alleged Apple
paid to lobby Congress to essentially water down the bill.

On May 10, 2021, press sources and two human rights groups reported that seven
companies that supplied products or services to Apple are linked to alleged forced
labour involving Uyghurs and other oppressed minorities in China. The
investigation reportedly found that at least five of those companies received
thousands of Uyghur and other minority workers at specific factory sites or
subsidiaries that supplied for Apple. The revelation stands in contrast to Apple’s
assertions in 2020 that it has not found evidence of forced labour in its supply
chain. According to press sources, among the seven Apple suppliers linked to
suspected forced labour, only one operated in Xinjiang. The others reportedly
operated elsewhere in China and received thousands of Uyghurs and other ethnic
Muslim minorities as workers through state-run poverty alleviation programs.
Human rights groups and Uyghur refugees said that these programs are coercive;
if the workers refuse to go along, they are sent to jail.

On September 27, 2021, the Campaign for Accountability (CfA), a non-profit group,
has reportedly filed a formal complaint with US Customs and Border protection
over Apple’s alleged use of forced labor in China. The CfA’s Tech Transparency
Project (TTP) cites the Tariff Act of 1930 in its complaint against Apple, which
"prohibits the importation of merchandise mined, produced or manufactured,
wholly or in part, in any foreign country by forced or indentured labor – including
forced child labor. Such merchandise is subject to the exclusion and/or seizure,
and may lead to a criminal investigation of the importer(s)." "This research is
based on hard evidence: Chinese-language media reports, government
announcements, and even videos posted online," said the CfA in a statement. "Yet
in the face of such detailed allegations raised by TTP and others, Apple has
consistently refused to acknowledge the problem, repeatedly issuing the same
blanket denial about its suppliers' use of minority Uyghur laborers." The CfA seeks
a Withhold Release Order "that prevents the importation of Apple products linked
to forced labor." It says Apple is in contravention of the Tariff Act of 1930, which
prohibits importing merchandise made under these conditions.
[The Guardian, 01/03/2020, ''China transferred detained Uighurs to factories used
by global brands – report'': theguardian.com] [Business and Human Rights
Resource Centre, 10/03/2021, ''China: Apple suppliers accused of using alleged
"forced labour from Xinjiang"; Apple claims it has not found supporting evidence'':
business-humanrights.org] [The Guardian, 10/08/2020, ''Apple imported clothes
from Xinjiang firm facing US forced labour sanctions'': theguardian.com]
[Engadget, 29/12/2020, ''Apple, Amazon and Tesla supplier accused of using
forced labor'': engadget.com
E(2).1 The Company The individual elements of the assessment are met or not as follows:
has responded Score 1
publicly to the • Met: Public response: After the release of ASPI's report, an Apple spokesman,
allegation 1 Josh Rosenstock, told the Washington Post: "Apple is dedicated to ensuring that
everyone in our supply chain is treated with the dignity and respect they deserve.
We have not seen this report but we work closely with all our suppliers to ensure
our high standards are upheld."
Indicator Code Indicator name Score (out of 2) Explanation
In testimony to Congress in July 2020, Apple CEO Tim Cook said the company
"wouldn’t tolerate forced labor" and "would terminate a supplier relationship if it
were found."
In a statement to The Information's article, Apple said that "looking for the
presence of forced labor is part of every assessment we conduct in every country
where we do business." It added that "despite the restrictions of Covid-19, we
undertook further investigations and found no evidence of forced labor anywhere
we operate. We will continue doing all we can to protect workers and ensure they
are treated with dignity and respect." [The Guardian, 01/03/2020:
theguardian.com] [The Washington Post, 20/11/2020, "Apple lobbies against
Uighur forced labor bill": washingtonpost.com] [Business and Human Rights
Resource Centre, 10/03/2021, ''China: Apple suppliers accused of using alleged
"forced labour from Xinjiang"; Apple claims it has not found supporting evidence'':
business-humanrights.org]
Score 2
• Not Met: Detailed response: After the revelation that Apple imports clothes from
Changji Esquel Textile, the Company said in a statement: “Esquel is not a direct
supplier to Apple but our suppliers do use cotton from their facilities in Guangzhou
and Vietnam. We have confirmed no Apple supplier sources cotton from Xinjiang
and there are no plans for future sourcing of cotton from the region.” However,
the spokesman declined to say where those factories source their raw cotton.
An Apple spokesperson told that the company confirmed Lens Technology “has
not received any labor transfers of Uyghur workers from Xinjiang.” The company’s
supplier progress report states that Apple conducted 1,142 “assessments” across
its entire supply chain in 49 different countries in 2019 to enforce its Supplier Code
of Conduct and the Supplier Responsibility Standards. In November, Apple
spokesperson Josh Rosenstock told the Post that the company “conducted a
detailed investigation with our suppliers in China and found no evidence of forced
labor on Apple production lines.” However, the Company declined to tell whether
Lens and O-Film were among the companies it audited. In general, Apple has never
publicly acknowledged its ties to the suppliers accused of forced labor and has not
publicly listed the suppliers that it works with. There is not evidence that Apple has
publicly commented the filing of the complaint by Campaign for Accountability
(CfA) with U.S. Customs and Border Protection over Apple’s continued use of
forced labor in products it ships to and sells in the United States. In addition, Apple
has not responded to the letter sent by the UN Working Group on Business and
Human Rights on March 12, 2021 on the allegation of Uyghur forced labour in
Apple's supply chain. Overall, the company responded in very general terms and
did not address the allegation in detail. [The Washington Post, 20/11/2020, "Apple
lobbies against Uighur forced labor bill": washingtonpost.com] [Campaign for
Accountability, 27/09/2021, "Campaign for Accountability Files Customs and
Border Protection Complaint over Apple’s Use of Forced Labor":
campaignforaccountability.org] [Letter of the Working Group on Business and
Human Rights (OTH 58/2021), 12/03/2021: spcommreports.ohchr.org] [Supplier
Responsibility 2020 Progress Report, 05/2020: apple.com]
E(2).2 The Company The individual elements of the assessment are met or not as follows:
has appropriate Score 1
policies in place • Not Met: Engaged with stakeholders: Apple spokesperson Josh Rosenstock told
the Post that the company “conducted a detailed investigation with our suppliers
in China and found no evidence of forced labor on Apple production lines.”
However, there is no evidence suggesting that the company engaged with the
affected stakeholders. The CHRB is aware of difficulties companies may face in
attempts to engage directly with Uyghur workers affected by forced labour,
however, there is no evidence that the company attempted to engage with other
possible sources such as exile Uyghur organisations. [The Washington Post,
20/11/2020, "Apple lobbies against Uighur forced labor bill": washingtonpost.com]
0 • Not Met: Identified cause: Apple said that “looking for the presence of forced
labor is part of every assessment we conduct in every country where we do
business.” It added that “despite the restrictions of Covid-19, we undertook
further investigations and found no evidence of forced labor anywhere we
operate.” However, the company does not present investigative results on the
underlying causes of the events concerned. [Apple Insider, 10/05/2021, "Seven
Apple suppliers linked to Chinese forced labor programs": appleinsider.com]
Score 2
• Not Met: Identified and implemented improvements: Bloomberg reported that
Apple is thought to have terminated its contracts with O-Film over the concerns a
few months ago. However, the company has never publicly acknowledged this
move. In addition, both The Information and The Washington Post revealed that
Indicator Code Indicator name Score (out of 2) Explanation
Apple paid to lobby Congress to water down the bill approved by the US Congress
to keep goods made with forced labor in the Uyghur region of China from entering
the US. The company did not publicly acknowledge this allegation. In general,
there is no publicly available evidence that the company made changes to its
management systems, policies and supply chain following the events and their
human rights impacts. [BNN Bloomberg, 17/03/2021,"Apple is said to cut off
Chinese supplier over Xinjiang labour": bnnbloomberg.ca] [The Information,
"Apple Lobbied U.S. Congress on Uighur Slave Labor Bills": theinformation.com]
[The Washington Post, 20/11/2020, "Apple is lobbying against a bill aimed at
stopping forced labor in China": washingtonpost.com]
• Not Met: Stakeholder input to steps taken
E(2).3 The Company The individual elements of the assessment are met or not as follows:
has taken Score 1
appropriate • Not Met: Provided remedy
• Not Met: Evidence for lack of Impact or link: The Company stated: "we
action
undertook further investigations and found no evidence of forced labor anywhere
we operate.” However, Apple did not provide sufficient evidence to prove the
0 company is not linked to the impact. [The Washington Post, 20/11/2020, "Apple is
lobbying against a bill aimed at stopping forced labor in China":
washingtonpost.com]
Score 2
• Not Met: Remedy satisfactory to stakeholders
• Not Met: Remedy delivered
• Not Met: Independent remedy process used
E(3).0 Serious • Area: Child labour
allegation No 3
• Headline: Apple accused of being complicit in child labour in the DRC

• Story: On December 15th, 2019, a legal complaint was filed in the U.S. District
Court of Washington D.C. by human rights NPO International Rights Advocates, on
behalf of 14 families from the Democratic Republic of Congo (DRC), against Tesla,
Microsoft, Alphabet, Dell and Apple. The lawsuit accuses the companies of aiding
and abetting in the death and serious injury of children who were reportedly
working in cobalt mines operated by Kamoto Copper Company, owned by
Glencore.

The complaint alleges that the defendants have known for a "significant period of
time" that Congo's mining sector "is dependent upon children". The claim further
alleged that cobalt from the Glencore-owned mines was then sold to Umicore,
which in turn sells battery-grade cobalt to Apple, Google, Tesla, Microsoft and Dell.
These companies, according to the complaint, should have the ability to overhaul
their cobalt supply chains to ensure safer working conditions.

The lawsuit alleges that the children, some as young as 6 years old, were forced by
their families' extreme poverty to leave school and work in cobalt mines owned by
Glencore. According to the complaint, six of the fourteen children were killed in
tunnel collapses, while others suffered life-altering injuries, including paralysis.
Some children were working six days a week and allegedly paid as little as USD
1.50 per day.

The defendants replied with a motion to dismiss, arguing they did not violate the
TVPRA as the child labour occurred only in their supply chain which is not the same
as a venture. Furthermore, they argued that the children affected by the mine
collapse were not forced into work by direct threats of force or harm by the
employer. According to their argument the TVPRA does not include economic
pressure in its definition of forced labour. In a third argument, the defendants
deny a sufficient degree of knowledge of the issue. The court dismissed the case in
November 2021. In the ruling the judge found that the harm claimed by the
plaintiffs was not traceable to any of the defendants. Furthermore, the judge did
not find a violation of the law cited and voiced doubts regarding the
extraterritoriality of the TVPRA. The plaintiffs appealed this decision, therefore,
the search for remedy continues.
[CBS News, 17/12/2019, ''Apple, Google, Microsoft, Tesla and Dell sued over child-
mined cobalt from Africa'': cbsnews.com] [Reuters, 16/12/2019, ''Tesla, Apple
among firms accused of aiding child labor in Congo'': reuters.com] [Clifford
Chance, 07/12/2021, ''Testing the US Trafficking Victims Protection Act: Doe v.
Apple'': cliffordchance.com] [Sky News, 17/12/2019, ''Tesla and Apple among tech
giants accused of aiding child labour in DRC'': news.sky.com
Indicator Code Indicator name Score (out of 2) Explanation
E(3).1 The Company The individual elements of the assessment are met or not as follows:
has responded Score 1
publicly to the • Met: Public response: Apple told CBS News the company has "led the industry by
establishing the strictest standards for our suppliers and are constantly working to
allegation
raise the bar for ourselves, and the industry." The company added that since 2016,
it has published a full list of cobalt refiners every year, all of which participate in
third-party audits. "If a refiner is unable or unwilling to meet our standards, they
1
will be removed from our supply chain," Apple said, adding that it removed six
cobalt refiners in 2019. [CBS News, 17/12/2019: cbsnews.com]
Score 2
• Not Met: Detailed response: The company does not address the individual cases
of the lawsuit in question. It also does not engage with the alleged conditions of
the children, the dangers of child labour in mining, or expressly recognises the
issue of child labour as such.
E(3).2 The Company The individual elements of the assessment are met or not as follows:
has appropriate Score 1
policies in place • Not Met: Engaged with stakeholders
• Not Met: Identified cause
Score 2
• Not Met: Identified and implemented improvements: Although the company
0
indicates it has removed refiners for being unable to meet its standards, it is
unclear which standards they are and whether the refiners in question have been
removed for child labour related violations. There is no further evidence of a
review of management systems following the allegation. [CBS News, 17/12/2019:
cbsnews.com]
• Not Met: Stakeholder input to steps taken
E(3).3 The Company The individual elements of the assessment are met or not as follows:
has taken Score 1
appropriate • Not Met: Provided remedy
• Not Met: Evidence for lack of Impact or link
action 0
Score 2
• Not Met: Remedy satisfactory to stakeholders
• Not Met: Remedy delivered
• Not Met: Independent remedy process used
E(4).0 Serious • Area: Right to security of persons
allegation No 4
• Headline: Apple and others named as supplier North Mara Gold Mine faces
allegations of pollution and violence in Tanzania

• Story: On June 18th, 2019, news outlets in several countries simultaneously

released the results of investigations by a consortium of journalists, Forbidden
Stories, into human rights and environmental abuses at Barrick Gold's North Mara
gold mine in Tanzania, confirming six years of investigations, reported on yearly by
MiningWatch Canada, into assaults on men, women and children by the mines
private security and by police contracted by the mine. There have been injury
cases including loss of limbs, broken bones, and internal injuries. Additionally, the
consortium highlighted attacks on journalists who have tried to report on human
rights abuses at the mine. At least a dozen local and foreign reporters were
censored or threatened, and this is why Forbidden Stories has decided to
investigate Acacia Mining's activity in the mine. The consortium also exposed how
the gold from this mine is refined in India and Switzerland before being sold to,
among others, international electronic companies. In June 2019, at the annual
shareholders meeting, human rights campaigners called for independent and
transparent assessment of grievance claims and an end to the memorandum of
understanding with police."
[The Guardian, 18/06/2019, ''Murder, rape and claims of contamination at a
Tanzanian goldmine'': theguardian.com] [Ghana Business News, 19/06/2019,
''Green Blood: A Tanzanian gold mine that silences journalists'':
ghanabusinessnews.com] [The Guardian, 18/06/2019, ''Tech firms to check
suppliers after mining revelations in Tanzania'': theguardian.com]
E(4).1 The Company The individual elements of the assessment are met or not as follows:
has responded Score 1
publicly to the • Not Met: Public response: The company responded stating it was "deeply
committed to the responsible sourcing of materials that go into its products". The
allegation 0
company added that "if a refiner is unable or unwilling to meet our standards, they
will be removed from our supply chain." It said it had stopped working with 60
refiners and would continue investigating and holding supply chains to the highest
standards. However, no acknowledgement of the allegation could be found as it is
Indicator Code Indicator name Score (out of 2) Explanation
unclear whether the 60 refiners were in any way connected to the allegation. [The
Guardian, 18/06/2019: theguardian.com]
Score 2
• Not Met: Detailed response: No acknowledgement of the allegation could be
found as it is unclear whether the 60 refiners were in any way connected to the
allegation.
E(4).2 The Company The individual elements of the assessment are met or not as follows:
has appropriate Score 1
policies in place • Not Met: Engaged with stakeholders: Following the publication of the allegation,
Apple, Nokia and Canon said they would ask MMTC-PAMP to look into the claims,
and the refinery announced it would assess its gold supply chain from Tanzania
and arrange for a site visit by an independent expert, Synergy Global Consulting
Ltd.
The visit took place on 19-21 November 2019, however, the visitors were allowed
to talk only to local residents vetted by the mine. Furthermore, "the mine said
there was a security issue offsite so we suggested some victims go to mine office
and speak to the assessor there. Then they said there was not enough time in the
schedule. So the assessor spoke to none of the human rights victims, [or] lawyers
of victims''

According to the auditor, they had "spoken to a variety of stakeholders, including

local community representatives. Following the trip [...] there was also an
interview with an international NGO." In a response to Raid the auditor admitted
that there had been no engagement with affected stakeholders.

Barrick Gold, the company operating the mine, claims it has been conducting
stakeholder and community engagement since taking over the operations.
However, this claim does not expressly include the engagement with affected
stakeholders. [The Guardian, 13/07/2020, ''Gold trade body urged to suspend
refinery over alleged abuses in Tanzania'': theguardian.com] [Synergy,
0 10/07/2020, ''Response to RAID article "LBMA Should Suspend Gold Refiner
MMTC-PAMP"'': media.business-humanrights.org] [Barrick, 10/08/2020, ''Solid
Operating Performance Maintains Production Within Guidance'': barrick.com]
[Barrick, N/A, ''Human Rights Report'': s25.q4cdn.com]
• Not Met: Identified cause: The executive summary of the auditor's report
included no evaluation of historical claims. Instead the summary said the focus of
the assessment was to look forwards rather than backwards because a new
management team had been put in place at the mine. Therefore, the summary
does not identify the underlying causes of the impacts. Even though the auditor
told The Guardian that the full report ''would include a review of historical
allegations against the mine based largely on third-party information, such as
newspaper articles and evidence collected by civil society groups and lawyers'' the
CHRB could not access the full report to verify these claims.

Barrick Gold also states that the violations took place under the management of
the previous operator and does not present an analysis of underlying causes. [The
Guardian 13/07/2020: theguardian.com] [Synergy, 05/2020, ''MMTC-PAMP North
Mara Gold Mine Assessment - Executive Summary'': mmtcpamp.com] [Barrick,
10/08/2020: barrick.com]
Score 2
• Not Met: Identified and implemented improvements: There is no information
available that indicates Apple has made changes to its management systems after
the allegations or after the publication of the report by Synergy Global Consulting
Ltd.
• Not Met: Stakeholder input to steps taken
E(4).3 The Company The individual elements of the assessment are met or not as follows:
has taken Score 1
appropriate • Not Met: Provided remedy [Raid, 07/2020, ''Analysis of synergy assessment
north mara gold mine update'': raid-uk.org] [Raid, 16/12/2021; ''Will Barrick Gold's
action
CEO go beyond rhetoric to deliver justice for victims of police killings at Tanzania
mine?'': raid-uk.org] [Responsible Mining Fpundation, 14/08/2020, ''More
0 Tnaznian human rights victims join UK legal action against Barrick'':
responsibleminingfoundation.org]
• Not Met: Evidence for lack of Impact or link
Score 2
• Not Met: Remedy satisfactory to stakeholders
• Not Met: Remedy delivered
• Not Met: Independent remedy process used
Indicator Code Indicator name Score (out of 2) Explanation
E(5).0 Serious • Area: Working hours
allegation No 5
• Headline: Apple's supplier accused of relying on students working illegal
overtime to build iPhone X in China

• Story: On November 21, 2017, press sources reported that Apple relies on
students working illegal overtime to build its iPhone X, through its contractor
Foxconn, which is the sole assembler and manufacturer of this iPhone model in
China.

According to press reports, a group of 3,000 students worked at the factory as part
of a three-month period called “work experience”, which was a pre-requisite for
them to graduate. Students routinely worked 11-hour days assembling Apple's
flagship smartphone, which constitutes illegal overtime for student interns under
Chinese law. The students earned between CNY 3,000 (USD 453) to CNY 4,000 per
month. This includes overtime pay; most of them agree to put in the extra hours
the report said.

Chinese labour law forbids student interns from working more than 40 hours per
week, which means Companies are not allowed to ask them to work overtime.

On September 8, 2019, China Labour Watch (CLW) published a report accusing

Apple and its partner Foxconn of breaching numerous Chinese labour laws at the
Zhengzhou Foxconn factory. The report is based on a CLW undercover
investigation.

On December 9, 2020, press reported that Apple ignored breaches of China’s

temporary worker law in its supply chain for years because it was concerned about
increased costs and product launch delays. Foxconn, Pegatron, and Quanta
Computer, three of Apple’s major assembly partners, faced difficulties complying
with the law between 2013 and 2018. The rule stated that only 10% of a workforce
could be temporary. According to the press, in 2014, more than half of a surveyed
362 suppliers broke the temporary worker law, and in March 2015, 81 of 184
Apple suppliers reportedly topped the 10% threshold. That continued in parts of
2016, 2017 and 2018. In 2014, Apple gave suppliers two years to mitigate the
issues, but by 2016 little progress had been made.

Apple executives reportedly knew that its production strategy increased demand
for temporary staff, known as dispatch workers. After Apple commissioned a two-
year study with Pegatron, Apple researchers recommended raising salaries,
building better dorms, reducing the use of dispatch workers and not hiring
workers younger than 23 years old. However, Apple executives were allegedly
reluctant to push Pegatron to make changes as they wanted to let supply and
demand determine China’s labor market conditions.
[The Guardian, 21/11/2017, ''Apple under fire over reports students worked
illegal overtime to build iPhone X'': theguardian.com] [CNET, 09/09/2019, ''Apple,
Foxconn acknowledge relying on temporary workers in China too much'':
cnet.com] [iMore, 09/12/2020, ''Apple accused of ignoring supplier labor law
breaches in China'': imore.com] [China Labor Watch, 08/09/2019, ''iPhone 11
Illegally Produced in China: Apple Allows Supplier Factory Foxconn to Violate Labor
Laws'': chinalaborwatch.org]
E(5).1 The Company The individual elements of the assessment are met or not as follows:
has responded Score 1
publicly to the • Met: Public response: In response to the allegation, the company stated: “During
the course of a recent audit, we discovered instances of student interns working
allegation
overtime at a supplier facility in China. We’ve confirmed the students worked
voluntarily, were compensated and provided benefits, but they should not have
been allowed to work overtime". [The Guardian, 21/11/2017: theguardian.com]
2
Score 2
• Met: Detailed response: In response to the allegation, the company stated:
“During the course of a recent audit, we discovered instances of student interns
working overtime at a supplier facility in China. We’ve confirmed the students
worked voluntarily, were compensated and provided benefits, but they should not
have been allowed to work overtime". [The Guardian, 21/11/2017:
theguardian.com]
Indicator Code Indicator name Score (out of 2) Explanation
E(5).2 The Company The individual elements of the assessment are met or not as follows:
has appropriate Score 1
policies in place • Met: Engaged with stakeholders: The company stated: "To make sure our high
standards are being adhered to, we have robust management systems in place
beginning with training on workplace rights, on-site worker interviews, anonymous
grievance channels and ongoing audits". [CNBC, 29/09/2019, "Apple denies claims
it broke Chinese labor laws in iPhone factory": cnbc.com]
• Not Met: Identified cause: The company stated: "When we find issues, we work
with our suppliers to take immediate corrective action. We looked into the claims
by China Labor Watch and most of the allegations are false". However, while the
0.5 company did admit to the working hour violations, it does not present
investigative results of the causes underlying this issue. [CNBC, 29/09/2019:
cnbc.com]
Score 2
• Met: Identified and implemented improvements: The company stated: "A team
of specialists are on site at the facility working with the management on systems
to ensure the appropriate standards are adhered to". [The Guardian, 21/11/2017:
theguardian.com]
• Not Met: Stakeholder input to steps taken: There is no evidence suggesting that
the views of affected stakeholders were taken into account in the improvement of
the company policies.
E(5).3 The Company The individual elements of the assessment are met or not as follows:
has taken Score 1
appropriate • Met: Provided remedy: The company stated: "We have confirmed all workers are
being compensated appropriately, including any overtime wages and bonuses, all
action
overtime work was voluntary and there was no evidence of forced labor. We did
find during our investigation that the percentage of dispatch workers exceeded
our standards and we are working closely with Foxconn to resolve this issue".

With regard to the child labourers working illegal overtime the company said
"When we found that some students were allowed to work overtime, we took
1.5 prompt action." [CNBC, 29/09/2019: cnbc.com]
• Not Met: Evidence for lack of Impact or link
Score 2
• Not Met: Remedy satisfactory to stakeholders: The company stated ''We did find
during our investigation that the percentage of dispatch workers exceeded our
standards and we are working closely with Foxconn to resolve this issue",
indicating that there is a group of affected stakeholders that has not been
provided remedy.
• Met: Remedy delivered: There is no information available suggesting that the
remedies the company has agreed to provide have not been delivered as agreed.
• Not Met: Independent remedy process used
E(6).0 Serious • Area: Health & safety
allegation No 6
• Headline: Apple among leading electronics firms fall short in protecting female
workforce from exposure to hazardous chemicals in the Philippines

• Story: On 25 January, 2021, Swedewatch published a follow-up report to its

report of 23 June, 2020, that presented Swedewatch's research on exposure of
female workers to toxic chemicals in factories in the Philippines.

The manufacturing of ICT products in the Philippines takes place in Special

Economic Zones (SEZs) where working conditions are often poor and the social and
legal protections for workers insufficient. Women interviewed for this report work
in poorly ventilated rooms where they are exposed to chemicals with well-known
hazardous effects. The laws in place to protect them are not sufficiently
implemented and the women state that they work without appropriate protective
equipment and safety instructions. The workers describe severe effects on their
health and the health of their unborn children; effects that to a large degree
corresponds with the known effects of the chemicals used in the processes. In fact,
for the women interviewed in this study, cancer and miscarriages are so common
that they have become the norm. Swedwatch’s research thus indicates that the
human rights of the workers are severely impacted. Companies sourcing ICT
components and products from the Philippines are linked to these impacts
through their business relationships.

The follow-up report takes into account company responses to the issues raised.
Indicator Code Indicator name Score (out of 2) Explanation
[Business and Human Rights Resource Centre, 25/01/2021, ''Philippines: Leading
electronics firms fall short in protecting female workforce from exposure to
hazardous chemicals; incl. co. Comments'': business-humanrights.org] [Briefing,
25/01/2021, "Hazardous chemicals in ICTmanufacturing and the impacts on
female workers in the Philippines": swedwatch.org]
E(6).1 The Company The individual elements of the assessment are met or not as follows:
has responded Score 1
publicly to the • Not Met: Public response: The CHRB was not able to access the response
provided to Swedewatch as the link provided on the Swedewatch website is not
allegation
working. However, the report stated that: "Apple expressed an intention to take
part in the survey, yet at the time of reply the briefing paper had already been
finalized. But according to its supplier list, which is available online, the company
has suppliers in the Philippines. The Apple Environmental Report 2020 outlines the
work Apple is doing with regards to chemicals. In it, the company states that it
works closely with suppliers to minimise workers’ harmful exposure to chemicals.
However, Swedwatch could not find any detailed information about the
0 company’s HRDD in the Philippines or the three substances identified in Toxic
Tech. The Apple Environmental Report 2020 names 'Smarter Chemistry' as one of
three focus areas and includes a commitment to minimise exposure to harmful
chemicals, integrate smarter chemistry innovation in the manufacture and design
of products, and to 'drive 100 percent transparency of chemical use in our supply
chain and products'. Apple is a member of CEPN and the RBA". [Briefing,
25/01/2021: swedwatch.org]
Score 2
• Not Met: Detailed response: The CHRB was not able to access the response
provided to Swedewatch as the link provided on the Swedewatch website is not
working. Information found elsewhere was not detailed enough to be considered
adequate for this datapoint.
E(6).2 The Company The individual elements of the assessment are met or not as follows:
has appropriate Score 1
policies in place • Not Met: Engaged with stakeholders
0 • Not Met: Identified cause
Score 2
• Not Met: Identified and implemented improvements
• Not Met: Stakeholder input to steps taken
E(6).3 The Company The individual elements of the assessment are met or not as follows:
has taken Score 1
appropriate • Not Met: Provided remedy
• Not Met: Evidence for lack of Impact or link
action 0
Score 2
• Not Met: Remedy satisfactory to stakeholders
• Not Met: Remedy delivered
• Not Met: Independent remedy process used

Disclaimer A score of zero for a particular indicator does not mean that bad practices are present. Rather it means that we
have been unable to identify the required information in public documentation.

See the 2020 Key Findings report and the 2019 technical annex for more details of the research process.

The Benchmark is made available on the express understanding that it will be used solely for general information
purposes. The material contained in the Benchmark should not be construed as relating to accounting, legal,
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investment objectives. The material contained in the Benchmark does not constitute a recommendation to take
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The CHRB is part of the World Benchmarking Alliance (‘WBA’).The material in the Benchmark has been put
together solely according to the CHRB methodology and not any other assessment models in operation within any
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No representation or warranty is given that the material in the Benchmark is accurate, complete or up-to-date.
The material in the Benchmark is based on information that we consider correct and any statements, opinions,
conclusions or recommendations contained therein are honestly and reasonably held or made at the time of
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only and may change without notice. Any views expressed in the Benchmark only represent the views of WBA,
unless otherwise expressly noted.

While the material contained in the Benchmark has been prepared in good faith, neither WBA nor any of its
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As WBA, we want to emphasise that the results will always be a proxy for good human rights management, and
not an absolute measure of performance. This is because there are no fundamental units of measurement for
human rights. Human rights assessments are therefore necessarily more subjective than objective. The Benchmark
also captures only a snap shot in time. We therefore want to encourage companies, investors, civil society and
governments to look at the broad performance bands that companies are ranked within rather than their precise
score because, as with all measurements, there is a reasonably wide margin of error possible in interpretation. We
also want to encourage a greater analytical focus on how scores improve over time rather than upon how a
company compares to other companies in the same industry today. The spirit of the exercise is to promote
continual improvement via an open assessment process and a common understanding of the importance of the
UN Guiding Principles on Business and Human Rights.

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