Quality In, Quality Out

Supplier Code of Business Conduct

Our Supplier Code of Business Conduct, which includes our Supplier Corporate Social Responsibility Standards, is referenced in our supplier agreements as a requirement of all suppliers.

Motorola Mobility - a Lenovo Company's Supplier code of Conduct is available in multiple languages.

Supplier Corporate Social Responsibility

We take a multi-pronged approach to helping our suppliers improve their Corporate Social Responsibility performance. This includes assessing and monitoring suppliers to our CSR Standards as well as providing programs to help suppliers develop the capability to improve their own performance over the long term. CSR is a factor in every sourcing decision made for every new product we design.

Monitoring and Assessment

Audit Program

Our supplier CSR audits assess compliance with the CSR Standards within Motorola Mobility, a Lenovo company’s Supplier Code of Business Conduct and local legal requirements. In addition to highlighting violations of our code, audits also raise supplier awareness of the issues and enable us to target improvements. We use pre-qualified auditors from independent 3rd party auditing firms to carry out our onsite auditing programs. The audit firms use standard audit protocols and report results using a standardized Motorola-specific rating matrix. We have an ongoing goal to audit every direct materials and final assembly supplier every 3 years (goal expanded in 2014 to include every supplier location relevant to Motorola parts and products). We also audit select indirect suppliers (e.g., outsourced service providers) using a risk-based approach.

Audit Finding Remediation

When we identify issues during an on-site audit, our process requires the supplier to develop an effective corrective action plan that addresses the root cause of the issue. The plan must specify a timely schedule for implementation - our guidelines on timing depend on the severity of the issue. We then schedule a closure verification audit within 6 to 12 months of the initial audit to verify closure of the findings identified.

Working with suppliers to improve labor and environmental conditions is crucial to our program. In most cases, we do not simply terminate contracts when issues are identified, because we believe that this can result in deteriorating conditions for workers. However, if a supplier does not meet corrective action deadlines or develop appropriate corrective action plans, we apply an escalating series of enforcement penalties if a supplier does not respond by taking necessary corrective actions.

Training

We deliver CSR training both to our internal employees to ensure awareness about CSR, as well as to our suppliers to help build their awareness about CSR issues.

We have developed an Android application for our internal supplier-facing employees called Supplier Eyes and Ears for Corporate Social Responsibility (SEE CSR). This app acts as a resource for supplier-facing MM employees when visiting a supplier site and provides resources on potential areas of concern for each CSR category - Labor, Ethics, Health & Safety, Environment. It includes CSR Team contact info with link to call or email immediately and a reporting mechanism when areas of concern are identified when engaging with a supplier. In 2014, we developed an open source Android and iOS app as a training resource to our suppliers.

Multi-Stakeholder Engagement

Responsible Business Alliance (RBA)

We are promoting higher standards across the industry. Lenovo’s membership in the Responsible Business Alliance (RBA) has enabled us to align our approach with industry best practice and contribute to change at an industry level.

Conflict Minerals

We have implemented a due diligence program to identify and trace tantalum, tin, tungsten and gold, (3TG) minerals in our supply chain, based on the procedures and tools provided by the RBA and the Organization for Economic Co-operation and Development (OECD) to address concerns about conflicts in regions which source these minerals.

Background

Our products, like virtually all consumer electronics, contain various metals, including tantalum, tin, tungsten and gold, (3TG) which originate in mines around the world. The 3TG metals have become known as "conflict minerals" because they are in part sourced from Eastern provinces of the Democratic Republic of Congo (DRC) where a decade-long civil war is continuing. Illegal armed groups control mines and transit routes to fund their violent operations.

In the U.S. the Dodd-Frank Act requires companies to file annual reports with the U.S. Securities and Exchange Commission (SEC) beginning 31st May 2014, indicating if they are using 3TG originating from the DRC or adjoining countries. A likely but unintended consequence of this regulation is a widespread withdrawal from trade with the DRC by U.S. companies.

Motorola Mobility – a Lenovo Company believes it is essential to establish validated, conflict-free sources of 3TG within the DRC and elsewhere so that these minerals can be procured in a way that contributes to economic growth and development in the region rather than to conflict. We are willing to partner with governmental organizations, industry groups and NGOs to achieve a solution.

A more complete briefing on conflict minerals is available from the NGO The Enough Project. A useful training presentation is available from the Responsible Minerals Initiative.

Our Program

Motorola Mobility - a Lenovo Company is implementing a due diligence program to identify and trace the 3TG minerals in our supply chain, based on the procedures and tools provided by the RBA and the Organization for Economic Co-operation and Development (OECD). The current status of our due diligence program is as follows:

Tracing 3TG in our supply chain using the RBA Mineral Reporting Template

We have adopted the RBA standardized reporting template and are requiring our suppliers to use this template as well. Currently, we have sent the template for completion to all of our production suppliers. We will integrate that data into an RBA tool documenting the overall progress of our supplier compliance program. We will continue to add supplier information to this database as they respond.

Under the Motorola Mobility – a Lenovo Company, Human Rights Policy and Responsible Minerals Initiative for responsible sourcing of minerals, suppliers shall exercise due diligence on the source and chain of custody of minerals used the manufacturing of their products, and make their due diligence measures available to customers upon request.

Identifying the smelters in our supply chain

Our suppliers should source only from certified conflict free smelters. To accomplish that objective, we are identifying the smelters in our supply chain based on the information gathered through the RBA reporting template. The Conflict Free Smelter Initiative maintains a list of smelters that have been certified as conflict free. We hope to see the process of certification proceed more quickly.

Motorola requires its suppliers to adhere to the OECD Due Diligence Guidance and we follow the guidance in our own due diligence program.

Dodd Frank compliance

Motorola Mobility – a Lenovo Company has been fully compliant with the SEC reporting requirements since June 2014.

Motorola Mobility – a Lenovo Company Goals

Ethics Hotline

Motorola Mobility – a Lenovo Company encourages individuals or suppliers who wish to report possible violations of our conflict minerals policy to contact us via one of the following channels. Submissions are strictly confidential and multiple languages are supported. We investigate all allegations of ethical misconduct and take corrective action when claims are substantiated.

Web

Log concerns at motorolamobility.ethicspoint.com.

Phone

In the U.S. or Canada: Call toll-free +1-800-230-2464

Outside the U.S. : Visit motorolamobility.ethicspoint.com for dialing instructions from your country.

Mail

Motorola Mobility
Office of Ethics and Compliance
222 W. Merchandise Mart Plaza, Suite 1800
Chicago, IL 60654
USA

Materials Disclosure and Legislation

We require our suppliers to disclose banned, controlled and reportable substances as well as recycled material content for each part supplied to Motorola Mobility – a Lenovo Company. We do this to fully understand and track the material content of our products, so we can control and improve the environmental profile of our products.

Our reporting requirements help us to comply with current laws, assess the impacts of future requirements and identify better alternatives to hazardous substances in our products.

W18 Reporting

Compliance with our Controlled and Reportable Material Disclosure Specification (W18) is required to qualify parts supplied to Motorola Mobility – a Lenovo Company.

Get Help With W18 Reporting

To help suppliers comply with the W18 specification, we provide additional resources and training.