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TG Submission

NSF 426 TG 13 – Corporate Responsibility

TG 13 status summary:The Task Group recommends the following topics for inclusion in Section 13 of the NSF server standard: environmental management systems, environmental reporting, compliance with occupational health and safety (OH&S) performance standards, and conflict minerals. The TG has completed its work on 6 criteria (listed as TG recommendations) and requests feedback on the criteria topics/language still under development, in particular, the OH&S and GRI reporting criteria.
Criterion Number and Title / Points
(optional criteria only) / Status* / Reference
document
Prerequisite Criteria

13.1.1 Environmental Management System (EMS) (Corporate)

/ N/A / TG Recommendation / None
13.1.2 Environmental reporting / N/A / Still under development
13.1.3Public disclosure of use of conflict minerals in products / N/A / TG Recommendation
13.1.4Manufacturer compliance with occupational health and safety performance standards - ANSI Z10 or OHSAS 18001 / N/A / Still under development
Optional Criteria

13.2.1 Environmental Management System (EMS) Certification (Corporate)

/ 1 / TG Recommendation / None

13.3.1 Public Reporting of Toxics Release Data (Corporate)

/ 1 / TG Recommendation / None
13.4.1Conflict minerals sourced only from validated conflict free smelters / 1 / TG Recommendation
13.4.2 Participation in in-region conflict-free sourcing program / ? / TG Recommendation
13.5.1Supply chain compliance with occupational health and safety performance standards - ANSI Z10 compliance or OHSAS 18001 / At least 2 / Still under development
13.5.2 Compliance with additional occupational health and safety performance standards / ? / Still under development / See hyperlinks in draft criterion

*For status, identify one of the following categories:

  • TG Recommendation
  • Options for JC Consideration
  • Still Under Development

13 Corporate Responsibility

13.1 Prerequisites

13.1.1 Environmental Management System (EMS) (Corporate) (TG Recommendation)

Manufacturer shall have formal, self-declared, EMS for those parts of the company that have significant responsibility for the design and manufacturer of all products declared to conform to this standard. The EMS shall meet the requirements of ISO 14001. Certification to either ISO 14001 or EMAS meets this requirement.

13.1.2 Environmental Reporting (Corporate)(Still Under Development)

Manufacturer shall publicly report the EMAS Key Performance Indicators annually associated with the company’s operations. Manufacturer may report for either the entire company level or for those parts of the company that have significant responsibility for the design and manufacturer of all products declared to conform to this standard. The annual reporting shall include goals, targets and objectives for the current year, and the previous year. Performance against these goals and targets shall be included for the previous year.

Annual public reporting shall include at least two annual public disclosures or documentation of a program to collect data on an annual basis. The option to provide documentation of a data collection program is available only for the initial two years the manufacturer declares products to conform to this standard. Manufacturer’s website shall either provide the annual disclosure or a link to a public repository containing the disclosure.

Manufacturer shall publicly report key indicators of corporate environmental and social responsibility performance, including at least the following:

[Note to JC: We think this list is probably too long and needs to be reduced, but we have not done that yet. Also, note that reporting here, using GRI indicators, would be at the corporate level, not just on the server impacts]

1 / Materials / Materials Used by Weight or Volume
2 / Percentage of materials used that are recycled input
TG 7 is working on this
3 / Energy / Energy consumption within the organization
4 / Energy Intensity
5 / Reduction of Energy Consumption
6 / Water / Total water withdrawal by source
7 / Percentage of water recycled and reused
8 / Emissions / Direct GHG emissions (Scope 1)
9 / Energy indirect GHG emissions (Scope 2)
10 / Emissions of ozone-depleting substances (ODS)
11 / DO WE WANT TO ADD: NOxSOx
12 / Transport / Impact of transporting workforce and materials used
13 / Products and Services / Initiatives to mitigate environmental impacts
14 / Percentage of products sold that are reclaimed
15 / Waste / Total weight of waste by type and disposal method
16 / Occupational Health & Safety / Rates of injury, disease, lost days, absenteeism, fatalities
17 / Local communities / Operations with implemented community engagement
18 / Forced and Compulsory Labor / Operations with risk for forced or compulsory labor
19 / Child Labor / Operations with risk for incidents of child labor
20 / Supplier Assessment for Labor Practices / Percentage of new suppliers screened with labor practice criteria
21 / Significant impacts for labor practices in supply chain and action
22 / Supplier Assessment for Impacts on Society / Percentage of new suppliers screened using criteria for impacts on society
23 / Significant negative impacts on society in supply chain
24 / Supplier Environmental Assessment / Percentage of new suppliers that were screened using environmental criteria
25 / Significant actual and potential negative environmental impacts in the supply chain and actions taken

Data shall be reported consistent with the Specific Standard Disclosures in the current Global Reporting Initiative (GRI) Guidelines. A full report ‘in accordance’ with the GRI Guidelines is not required, but would meet this prerequisite if the report included all required indicators. Performance against these indicators shall be reported annually and data must be from within the last two years. In addition to performance against indicators, the manufacturer shall identify its five year goals for each indicator, explain their importance to the company and to its values, and describe the company’s progress toward these goals or its prior set of five-year goals (i.e., if it has just started along the path for its next five-year goals).

Required:

A)The manufacturer shall report on performance of its own operations against indicators 1 – 19 for its own operations, and

B)The manufacturer shall report on indicators 20-23 for its whole supply chain.

C)The manufacturer shall report on goals and a timetable for when it will be reporting against indicators 1-19 for these parts of its supply chain:

  1. Manufacturers of storage devices used in its products,
  2. Manufacturers of principle semiconductor devices used in its products and
  3. Manufacturers of primary circuit boards used in its products

Optional:

A)The manufacturer reports on performance against indicators 1-19 by these parts of its supply chain:

  1. Manufacturers of storage devices used in its products, or
  2. Manufacturers of principle semiconductor devices used in its products, or
  3. Manufacturers of primary circuit boards used in its products

[Note to JC: This may look like it will result in too many points. But it is our intention to develop a scoring grid that groups several of the performance indicators together]

13.1.3 Public disclosure of use of conflict minerals in products (Corporate) (TG Recommendation)

Manufacturers shall publicly disclose use of conflict minerals in their products and sources of these minerals, as follows:

  • Manufacturers shall disclose annually whether any “conflict minerals” that are “necessary to the functionality or production of a product manufactured by such person,” and which did not come from recycled or scrap sources,originated in the Covered Countries, and make that disclosure publicly available on the manufacturer’s public website.
  • If the manufacturer’s conflict minerals originated in the Covered Countries after January 31, 2013, that manufacturer must publish a Conflict Minerals Report on its public website, that:
  • Includes a description of (including a specific list of)the products manufactured or contracted to be manufactured that are not DRC conflict free, the facilities used to process the necessary conflict minerals in those products, the country of origin of the necessary conflict minerals in those products, and the efforts to determine the mine or location of origin with the greatest possible specificity
  • Includes a description of the measures taken by the manufacturer to exercise due diligence on the minerals’ source and chain of custody, This due diligence must conform to a nationally or internationally recognized due diligence framework, if such a framework is available for the conflict mineral;
  • Explains the efforts made to determine the mine or location of origin with the greatest possible specificity.
  • Has been audited by an independent, private sector auditor who must be named on the manufacturer’s website.
  • For companies that are registered to the U.S. Securities and Exchange Commission, compliance with SEC Rule 1502 satisfies this criterion.

Informational Note: <Place holder for reference>

13.1.4 Manufacturer compliance with occupational health and safety performance standards- ANSI Z10 or OHSAS 18001(Still Under Development)

Compliance with ANSI Z10 2012, Occupational Health and Safety Management Systems, or OHSAS 18001 shall be incorporated into the manufacturer’s ISO 14001 management system and audited every _??__ or compliance with withOHSAS 18001.

Informational Note: For OHSAS 180001, see

13.2 Environmental Management System (Optional)

13.2.1 Environmental Management System (EMS) Certification (Corporate) (TG Recommendation)

EMS specified in 13.1.1 shall be third party certified to either ISO 14001 or EU EMAS.

13.3 Reporting Toxics Release Data (Optional)

13.3.1 Public Reporting of Toxics Release Data (Corporate) (TG Recommendation)

Manufacturer shall publicly report annually toxics release data for the following three different types of components for servers (main storage device, i.e. hard drive; principle semiconductor device; and circuit board)from major componenteach of the top three suppliers (by spend) for each component.Reporting shall include at least the name of the company, the specific locations of the releases, and the identity and volume for each release. The reported data shall be for chemicals listed on the:

U.S. EPA Toxics Release Inventory, or

United Nations, or the applicable country’s, Protocol on Pollutant Release and Transfer Registry

The data collected from the three suppliers can be for their entire company or the specific part of the company that manufactures an identified component in a registered productincluding…(need to specifycomponents). If there are less than three suppliers for each component, every supplier for the component needs to provide data.

Manufacturer’s website shall either provide the annual disclosure or a link to a public repository containing the disclosure.

13.4 Conflict mineral sourcing (Optional)

13.4.1 Conflict minerals sourced only from validated conflict free smelters(TG Recommendation)

Manufacturers have determined the source of all conflict minerals used in all their products and determined that they are from either:

  1. recycled or scrap sources or
  2. smelters and/or refiners which have been determined to be Conflict Free by the Conflict Free Sourcing Initiative, and appear on CFSI’s list of validated smelters and refiners.

Informational Note: For CFSI list, see

13.4.2Participation in in-region conflict-free sourcing program(TG Recommendation)
Manufacturer supports and participates in one of the in-region conflict free controlled chain-of- custody sourcing programs such as Solutions for Hope, or Conflict Free Tin Initiative, which are committed to sourcing the minerals from conflict free sources in the region. (X points)

Note: This should be worth the most points in this section.

Questions:
Are there any others of these programs?
If we were to define what additional programs would qualify here, how would we define them?

13.5 Compliance with occupational health and safety performance standards (Optional)

13.5.1 Supply chain compliance with occupational health and safety performance standards - ANSI Z10 compliance or OHSAS 18001(Still Under Development)

Manufacturer shall ensure compliance through contractual agreement with ANSI Z10 or OHSAS 18001 for the 3 largest suppliers (based on total spend) for each of three main components (main storage device, i.e. hard drive; principle semiconductor device; and largest circuit board). (X points)

Manufacturer shall receive additional credit of (X points) for making all audit results public.

13.5.2Compliance with additional occupational health and safety performance standards(Still Under Development)

  1. Manufacturer shall demonstrate compliance with TCO Sustainable IT Certification(X points)

See

  1. Manufacturer shall ensure compliance through contractual agreement with TCO Sustainable IT Certification for the 3 largest suppliers (based on total spend) for each of three main components (main storage device, i.e. hard drive; principle semiconductor device; and largest circuit board). (X points)
  1. Manufacturer shall ensure compliance with SA 8000 Health & Safety provisions for the 3 largest suppliers (based on total spend) for each of three main components (main storage device, i.e. hard drive; principle semiconductor device; and largest circuit board). (X points)

See SA 8000 Health & Safety provisions:

  1. Manufacturer shall ensure compliance with ILO Program on Safety and Health at Work and the Environment (Safe Work) for the 3 largest suppliers (based on total spend) for each of three main components (main storage device, i.e. hard drive; principle semiconductor device; and largest circuit board). (X points)

See ILOProgram on Safety and Health at Work and the Environment (Safe Work):

  1. Manufacturer shall ensure compliance with C170 - Chemicals Convention, 1990 (No.170), Article 12 - Exposure for the 3 largest suppliers (based on total spend) for each of three main components (main storage device, i.e. hard drive; principle semiconductor device; and largest circuit board). (X points)

See C170 - Chemicals Convention, 1990 (No.170), Article 12 - Exposure

Definitions for Conflict Minerals criteria:

  1. Conflict minerals are defined as
  2. columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, unless the U.S. Secretary of State determines that additional derivatives are financing conflict in the Democratic Republic of the Congo or an adjoining country; or
  3. Any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
  4. This is the definition from SEC Rule 1502. Obviously it’s U.S. centric, since it mentions the US Secretary of State by name, but that might be ok here.
  5. Covered countries are
  6. DRC Conflict Free means that a product does not contain conflict minerals necessary to the functionality or production of that product that directly or indirectly finance or benefit armed groups, [see definition below] in the Democratic Republic of the Congo or an adjoining country. Conflict minerals that a manufacturer or its supplier obtains from recycled or scrap sources, [see definition below], are considered DRC conflict free.
  7. Armed groups means an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 (22 U.S.C. 2151n(d) and 2304(b)) relating to the Democratic Republic of the Congo or an adjoining country. [Note: These refer to U.S. Statutes. Is that a problem?]
  8. “Necessary to the functionality or production of a product” means
  9. OECD guidelines for due diligence are those described in a document titled, “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.” This is a reference to put into the standard
  10. Recycled or scrap sources are those as defined by the OECD in “OECD, DUE DILIGENCE GUIDANCE FOR RESPONSIBLE SUPPLY CHAINS OF MINERALS FROM CONFLICT-AFFECTED AND HIGH-RISK AREAS, 12 n.2 (2011), available at It says, “(“Recycled metals are reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing. Recycled metal includes excess, obsolete, defective, and scrap metal materials which contain refined or processed metals that are appropriate to recycle in the production of tin, tantalum, tungsten and/or gold. Minerals partially processed, unprocessed or a bi-product from another ore are not recycled metals.”).

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