Ford Motor Company Limited (Company) – Slavery and Human Trafficking Statement for the Financial Years 2015 and 2016
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
Supply Chain Overview
The automotive supply chain is one of the most complicated of any industry. There are often six to ten levels of suppliers between an automaker and the source of raw materials that enter the manufacturing process.
The breadth, depth and interconnectedness of the automotive supply chain make it challenging to effectively manage business and sustainability issues. Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. As customers, however, we play an active role in supplier development and have adopted various means to clearly communicate our expectations to our suppliers. Supply Chain Standards
In our standard production procurement process, we issue purchase orders that incorporate our Global Terms and Conditions (GT&Cs). The GT&Cs are further supplemented by our web-guides, which expand on our expectations and suppliers’ obligations on specific topics. For example, our Social Responsibility and Anti-Corruption Web-Guide outlines our prohibition of child labor, forced labor (including human trafficking), physical disciplinary abuse and any infraction of the law. Our Environmental Web-Guide sets out environmental requirements, including the elimination of materials of concern and increasing the use of sustainable materials whenever technically and economically feasible.
Internally, we have adopted Policy Letter 24, our Code of Human Rights, Basic Working Conditions and Corporate Responsibility, to address workplace issues such as working hours, child labor, forced labor, nondiscrimination, freedom of association, health and safety and the environment. This policy applies to our own operations, and we encourage businesses throughout our supply chain to adopt and enforce similar policies in their own operations. Furthermore, we seek to identify and do business with companies that have aligned standards consistent with Policy Letter 24, including working to cascade these expectations throughout their own supply chain. Slavery and Human Trafficking
Slavery and forced labor can take many forms, including human trafficking or child labor. Ford’s Policy Letter 24: Code of Human Rights, Basic Working Conditions and Corporate Responsibility, clearly states that we will not tolerate forced labor (including human trafficking) or child labor in our operations and we conduct internal audits of our manufacturing locations to ensure compliance. Our processes include actions to safeguard against human rights abuses (including forced labor and human trafficking) in our supply chain, including:
- Our Global Terms and Conditions forbid the use of forced labor, child labor and physically abusive disciplinary practices. Our definition of forced labor is inclusive of human trafficking as outlined in our Policy Letter 24: Code of Human Rights, Basic Working Conditions and Corporate Responsibility. Ford’s purchase orders require suppliers to certify compliance with our prohibition of forced labor, child labor and physical disciplinary abuse as part of our Global Terms and Conditions that govern the purchase by Ford of goods and services from suppliers. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered and/or noncompliance is not addressed in a timely manner.
- We regularly assess risk related to human trafficking and forced labor associated with our supply base. Our preliminary assessment is based upon geography, the commodity purchased, supplier quality performance and the nature of the business transaction. Ford performs this risk assessment with input from external stakeholders. In 2014, as a result of this analysis, we added Indonesia to our list of high-priority countries, increasing the total to 22 countries. The high-priority country list, combined with our training and assessment history in a given country and engagement with our regional buying community, is used to prioritize our training and assessment efforts.
- We conduct training and build capability.
- We regularly conduct internal training on our Policy Letter 24: Code of Human Rights, Basic Working Conditions and Corporate Responsibility with our Global Purchasing staff, including management and supplier quality teams. Additional training is conducted regarding our Supply Chain Sustainability Program, including coverage of the Code and our Global Working Conditions Program.
- Ford requires suppliers in high-risk countries to attend training to increase their awareness of Ford’s requirements and legal requirements, including those related to forced labor and child labor.
We regularly conduct audits of at-risk Tier 1 supplier factories to monitor compliance with Ford expectations and legal requirements.
These audits are independent and generally announced. We choose which facilities to audit based upon our risk assessment as described above. If any issues are identified during an audit, the supplier is required to prepare a corrective action plan and resole all violations within an agreed upon time period.
The board of directors of the Company delegated approval of this statement on its behalf to the Chairman and Managing Director of the Company, at its board meeting on 3rd
Chairman and Managing Director
Ford Motor Company Limited