CALIFORNIA SUPPLY CHAIN TRANSPARENCY STATEMENT
GoPro makes the world’s most versatile cameras, and we strive to do it responsibly. We are committed to achieving universal ethical trading standards throughout all parts of our supply chain. This includes a commitment to ensuring that workers are treated with respect and dignity, and that business operations and manufacturing processes are environmentally responsible and conducted ethically.
Accordingly, we require all suppliers to comply with our GoPro Supplier Corporate Social Responsibility Code of Conduct (the “Corporate Social Responsibility Code”). The Corporate Social Responsibility Code seeks to promote safe and fair working conditions, and urges our suppliers to go beyond legal compliance to advance social responsibility. Our Corporate Social Responsibility Code draws upon principles articulated in the Electronic Industry Code of Conduct, the Universal Declaration of Human Rights, and standards issued by organizations such as the International Labour Organization, Social Accountability International, and the Ethical Trading Initiative. Among other things, our Corporate Social Responsibility Code prohibits the use of underage labor, prohibits forced or prison labor, and mandates workplaces free of harassment or discrimination. Our suppliers are further required to comply with applicable laws and regulations in the rights of workers to form and join labor unions or workers organizations of their own choice.
GoPro maintains an internal compliance team whose members undergo on-the-job training on enforcement of our Corporate Social Responsibility Code, including ways to mitigate the risk of suppliers violating workplace laws. With an internal compliance team with deep knowledge of the requirements of our Corporate Social Responsibility Code, GoPro does not currently need third parties to conduct verifications of product supply chains to evaluate and address risks of human trafficking and slavery. As part of our verification process, we may conduct onsite visits, and our suppliers are otherwise contractually obligated to certify and warrant compliance with all laws, rules, and regulations of the countries in which they operate, which may include applicable laws on workplace conditions, slavery, and human trafficking. It is intended that this statement extends to the obligations set forth in section 54(12), UK Modern Slavery Act 2015 and GoPro shall, upon request, provide a statement of such steps it has taken, together with such other information a requestor may reasonably require in order to enable it to prepare a slavery and human trafficking statement in accordance with section 54, UK Modern Slavery Act 2015.
Once engaged to work with us, suppliers must actively monitor their own practices to ensure continuous compliance, which includes formal designation of one or more representatives who are responsible for ensuring compliance with our Corporate Social Responsibility Code. GoPro’s compliance team also conducts announced audits of suppliers to further ensure compliance, and we also reserve the right to subject suppliers to unannounced audits conducted by third parties. As part of our auditing process, we provide our suppliers with reports and if necessary, require corrective action to cure any compliance issues. Among other things, suppliers who do not resolve the issues to our satisfaction are subject to termination as a GoPro supplier and appropriate legal action.
As part of our commitment to fair working conditions, GoPro may update our Corporate Social Responsibility Code or other procedures as needed to ensure that our suppliers conduct business ethically and responsibly.
GoPro shall take reasonable steps to ensure that slavery and human trafficking (as such phrase is defined in section 54(12), UK Modern Slavery Act 2015) is not taking place in any of its supply chains or in any part of its own business. GoPro shall, at the Customer’s request, provide the Customer with a statement of such steps it has taken, together with such other information as the Customer may reasonably require in order to enable it to prepare a slavery and human trafficking statement in accordance with section 54, UK Modern Slavery Act 2015.
GoPro Supply Chain Code of Conduct
GoPro is strongly committed to conducting its business in a lawful and ethical manner, including engaging with suppliers that are committed to the same principles. We require suppliers in our manufacturing supply chain to comply with our Supply Chain Code of Conduct (the "Code"), which is detailed below.
GoPro also expects our suppliers to hold their suppliers and subcontractors to the standards and practices covered by our Code. Our products must be manufactured in a manner that meets or exceeds the expectations of GoPro and our customers as reflected in our Code.
GoPro is committed to achieving universal ethical trading standards throughout all parts of its supply chain, and to ensure that the working conditions in GoPro’s supply chain are safe, that workers are treated with respect and dignity, and that business operations and manufacturing processes are environmentally responsible and conducted ethically.
GoPro's Suppliers shall commit to achieve, in all of their activities, the required quality of the products and services, operate in full compliance with the laws, rules, and regulations of the countries in which they operate, strive for the highest standards of ethical conduct while dealing with employees, suppliers and customers. Suppliers must not only conform to the Code but also actively monitor its conformance to the Code and its standards in accordance with a Management System as described herein.
This Code is intended to promote safe and fair working conditions and an environmentally friendly manufacturing process, to make responsible sourcing decisions and to protect our mutual commercial interests.
The Code encourages Suppliers to go beyond legal compliance, drawing upon internationally recognized standards, in order to advance social and environmental responsibility and business ethics.
The Code is a mandatory requirement for all Suppliers throughout all parts of the GoPro supply chain.
GoPro's Suppliers will be subject to audits conducted by GoPro (and/or by external monitors) with or without notice, to assess compliance with this Code and practices. Violations of this Code may result in immediate termination as a GoPro Supplier and in appropriate circumstances, legal action.
Labor & Human Rights
Child Labor. GoPro will not tolerate the use of child labor. Our suppliers must engage workers whose age is the greater of: (i) 15, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. Furthermore, workers under the age of 18 must not perform hazardous work. GoPro supports the development of legitimate workplace apprenticeship programs that comply with applicable laws and this Code.
Involuntary Labor, Human Trafficking, and Slavery. Workers must not be forced to work against their will. Our suppliers must not use forced labor - slave, prison, indentured, bonded, or otherwise. Our suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice. Where workers are required to pay a fee in connection with obtaining employment, Suppliers shall be responsible for payment of all fees and expenses in excess of the amount of one month of the worker’s anticipated net wages. Such fees and expenses include, but are not limited to, expenses associated with recruitment, processing or placement of both direct and contract workers. Our suppliers must not require workers to surrender government issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing. Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker. Suppliers must ensure that each of its staffing or recruiting agencies comply with this Code and with the more stringent of the applicable laws of the country where work is performed and the worker’s home country.
Wages and Benefits. Our suppliers must pay their workers in a timely manner and provide compensation (including overtime pay and benefits) that, at a minimum, satisfy applicable laws. Suppliers must provide to their workers the basis on which workers are being paid in a timely manner via pay stub or similar documentation. Deductions from wages as a disciplinary measure are not permitted. Suppliers shall offer vacation time, leave periods, and holidays consistent with applicable laws and regulations.
Working Hours. Except in unusual or emergency situations, (i) suppliers must not require a worker to work more than 60 hours per week, including overtime, and (ii) each worker must be entitled to at least one day off for every seven-day work period. In all circumstances, working hours must not exceed the maximum amount permitted by law.
Anti-discrimination. Suppliers must commit to a workplace free of unlawful discrimination. Conditions of working must be based on an individual’s ability to do the job, not on personal characteristics or beliefs. Our suppliers must not discriminate on the basis of race, color, national origin, gender, sexual orientation, religion, disability, age, political opinion, pregnancy, marital or family status, or similar factors in hiring and working practices such as job applications, promotions, job assignments, training, wages, benefits, and termination. Suppliers must not subject workers or applicants to medical tests (i.e. pregnancy test) that could be used in a discriminatory manner.
Non Harassment. Suppliers shall commit to a workplace free of harassment. All workers must be treated with respect and dignity. Our suppliers must not engage in or permit physical, verbal, or psychological abuse or coercion, including threats of violence, sexual harassment, or unreasonable restrictions on entering or exiting work and residential facilities. Workers must be free to voice their concerns to GoPro or its auditors, and allowed to participate in the GoPro audit process, without fear of retaliation by supplier management.
Immigration Compliance. Our suppliers may only engage workers who have a legal right to work. If suppliers engage foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labor laws of the host country.
Freedom of Association. Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Our suppliers must respect the rights of workers to establish and join a legal organization of their own selection. Workers must not be penalized or subjected to harassment or intimidation for the non-violent exercise of their right to join or refrain from joining such legal organizations.
Safety and Health
Our suppliers must provide workers with a safe and healthy work environment, and suppliers must, at a minimum, comply with applicable laws regarding working conditions and with the standards below. GoPro recognizes that in addition to minimizing the incidence of work-related injury, illness and hazards; a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale.
Suppliers shall commit to creating safe working conditions and a healthy work environment for all of their workers in all aspects of its workplaces.
Occupational Safety & Injury. Suppliers must educate workers on safety procedures and also control worker exposure to potential physical safety hazards by implementing physical guards, barriers, and/or engineering and administrative controls. Workers must be informed and receive appropriate education in advance if they will be working with (or otherwise exposed to) hazardous or dangerous conditions or materials. In addition, workers must be given appropriate personal protective equipment and educated and trained on the proper use of such equipment. Suppliers must manage, track, and report occupational injuries and illnesses. Suppliers shall not discipline workers for raising safety concerns and workers shall have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns. Suppliers shall establish procedures and systems to prevent, manage, track, and report occupational injury and illness. Such procedures and systems shall encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their root causes, and facilitate the workers’ return to work.
Physically Demanding Work. Suppliers must continually identify, evaluate, and control physically demanding tasks to ensure that worker health and safety is not jeopardized.
Emergency Preparedness and Response. Suppliers must identify and plan for emergency situations and implement and train their workers on response systems, including emergency reporting, alarm systems, worker notification and evacuation procedures, worker training and drills, first-aid supplies, fire detection and suppression equipment, and unblocked exit facilities. Suppliers must maintain all facilities in good fire safety conditions with appropriate fire detection and suppression equipment, adequate exit facilities in accordance with the applicable laws and regulations or industry benchmark standards or relevant international standard. Suppliers shall incorporate C-TPAT security criteria into their business processes as described in the U.S. Customs website, www.cbp.gov.
Machine Safeguarding. Suppliers must implement a regular machinery maintenance program. Production and other machinery must be routinely evaluated for safety hazards.
Sanitation and Housing. Workers must be provided with reasonable access to clean toilet facilities and potable drinking water. If suppliers provide a canteen or other food accommodations, they must include sanitary food preparation, storage, and eating accommodations. If suppliers provide residential facilities for their workers, they must provide clean and safe accommodations. In such residential facilities, workers must be provided with emergency egresses, reasonable and secure personal space, entry and exit privileges, reasonable access to hot water for bathing, adequate heat and ventilation, and reasonable transportation to and from work facilities (if not reasonably accessible by walking).
Ergonomics. Suppliers shall identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling, heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks.
Sanitation, Dining and Dormitory. Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Supplier or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space with full respect to privacy and reasonable entry and exit privileges. For worker food provided by the Supplier or a third party agency, the Supplier shall manage and control food preparation and storage facilities in sound sanitation in accordance with applicable law.
Suppliers must be committed to the highest standards of ethical conduct when dealing with workers, suppliers, and customers to meet social responsibilities and to achieve success in the marketplace.
No Bribery. Our suppliers must not offer nor accept bribes or other means of obtaining undue or improper advantages to anyone for any reason, whether in dealings with governments or the private sector. Our suppliers must not induce GoPro employees to violate our Business Code of Conduct.
Anti-Corruption. Suppliers must comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and not offer anything of value, either directly or indirectly, to government officials in order to obtain or retain business. Suppliers must not make illegal payments to government officials themselves or through a third party. Suppliers must have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes) or other means to obtain an undue or improper advantage. Suppliers must uphold fair business standards in advertising, sales, and competition. All business dealings should be transparently performed and accurate procedures shall be implemented to ensure compliance with anti-corruption applicable laws.
Whistleblower Protections. Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. Suppliers must create a mechanism for workers to submit their grievances anonymously.
Disclosure of Information. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable. Suppliers must transparently perform, accurately record and disclose information regarding their business activities, structure, financial situation, and performance in accordance with applicable laws and regulations and prevailing industry practices.
Intellectual Property. Supplier must commit to respect intellectual property rights, and transfer of technology and know-how is to be done in a manner that protects intellectual property rights.
Protection of Identity and Privacy. Suppliers must maintain programs that ensure the confidentiality and protection of supplier and employee whistleblowers, and prohibit retaliation against workers who participate in such programs in good faith or refuse an order. Suppliers shall provide an anonymous complaint mechanism for workers to report workplace grievances in accordance with local laws and regulations. Suppliers must protect the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Participants are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
Community Engagement. Suppliers are encouraged to engage the community to help foster social and economic development and to contribute to the sustainability of the communities in which they operate.
Suppliers must adopt a management system to ensure compliance with applicable laws and this Code and to facilitate continual improvement.
Management Accountability and Responsibility. Suppliers must have designated representatives responsible for implementing management systems and programs that oversee compliance with applicable laws as well as this Code. Senior management must routinely review and assess the quality and efficiency of the management systems and programs. GoPro also expects our suppliers to hold their suppliers and subcontractors to the standards and practices covered by this Code.
Risk Management. Suppliers must establish a process to identify the environmental, health, safety, and ethical risks associated with their operational and labor practices. In addition, management must develop appropriate processes to control identified risks and ensure regulatory compliance.
Training. Management must maintain appropriate training programs for managers and workers to implement the standards in this Code and to comply with applicable legal requirements.
Communication and Worker Feedback. Suppliers must clearly and accurately communicate and educate workers about GoPro policies, practices, and expectations. GoPro may require suppliers to post this Code in a location accessible to their workers (translated into the appropriate local language(s)). In addition, GoPro encourages suppliers to partner with us to implement a process to assess workers' understanding of the standards and practices covered by this Code.
Documentation and Records. Suppliers must create, retain, and dispose of business records in full compliance with applicable legal requirements along with appropriate confidentiality to protect privacy.
Audits and Assessments. Suppliers shall conduct periodic self-evaluations to ensure compliance with this Code and with applicable laws and regulations. Suppliers shall conduct periodic evaluations to ensure that its subcontractors and its next-tier suppliers are complying with this Code and with applicable laws and regulations.
Our suppliers must comply with applicable environmental laws. GoPro encourages our suppliers to implement systems that are designed to minimize the impact on the environment by the supply chain system, the production process, and the products themselves.
Environmental Permits and Recordkeeping. Suppliers must obtain and keep current all required environmental permits, approvals, and registrations and follow applicable operational and reporting requirements.
Effective Management and Disposal of Hazardous Substances. Suppliers must effectively identify and manage the safe handling, movement, storage, and disposal of chemicals and other substances that pose a threat to the environment, including providing workers with appropriate training on the safe-handling and disposal of hazardous substances. Suppliers must also monitor and control wastewater or solid waste generated from operations before disposing in accordance with applicable laws. In addition, suppliers must characterize, monitor, control, and treat regulated air emissions before discharging in accordance with applicable laws.
Continuous Improvement. GoPro encourages our suppliers to continuously improve and reduce waste. GoPro welcomes suggestions and feedback from its suppliers to improve GoPro's own operations and processes.
Material Substance Restrictions and Regulations. Supplier must identify the chemicals and other materials posing a hazard if released to the environment and manage to ensure their safe handling, movement, storage, use, recycling or reuse and disposal. Suppliers shall comply with the most up-to-date version of GoPro Environmental Requirements (970-01019-000) and with any applicable laws and regulations prohibiting or restricting the use or handling of specific hazardous substances. Suppliers shall comply with applicable laws and regulations regarding prohibition or restriction of specific substances and hazardous substances including labeling for recycling and disposal.
Conflict Minerals. Conflict Minerals are minerals mined in the conditions of armed conflict and human rights abuses, notably in the eastern provinces of the Democratic Republic of Congo (DRC) and adjoining countries. In July 2010, US President Barack Obama signed the “Dodd-Frank Wall Street Reform and Consumer Protection Act” that includes section 1502(b) on Conflict Minerals. The Securities and Exchange Commission (SEC) adopted a rule mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Section 1502) to require companies to publicly disclose their use of conflict minerals that originated in the Democratic Republic of the Congo (DRC) or an adjoining country. These minerals are Tin, Tantalum, Tungsten and Gold, also known as 3T&G that are mined in conditions of armed conflict and human rights abuses, mostly in the eastern provinces of the Democratic Republic of the Congo and 7 adjoining countries (Angola, Burundi, Sudan, Tanzania, Rwanda, Uganda and Zambia). GoPro as a publicly traded company is subject to this Rule.
GoPro supports the Conflict Minerals ruling and has partnered with Conflict Free Sourcing Initiative (CFSI) team to collaboratively develop industry standards in collecting the sourcing information related to ‘Conflict Minerals”. GoPro’s Suppliers must meet this policy to be in compliance with GoPro’s Supplier Code of Conduct. This policy defines GoPro’s due diligence requirement and expectation of our supply chain for Conflict Minerals. This applies to all GoPro suppliers, their subcontractors and their next tier suppliers producing goods for use in GoPro’s products or providing services in connection with GoPro products and services.
GoPro Conflict Minerals Policy and Supplier Requirements
GoPro is committed to sourcing components and materials from companies that share our values around human rights, ethics and environmental responsibility. We expect all of our suppliers to abide by the requirements of our Supplier Code of Conduct, which prohibits human rights abuses and unethical practices. We also require all suppliers to comply with applicable legal standards and requirements. On August 22, 2012, the U.S. Securities and Exchange Commission issued the final conflict minerals rule under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Rule”). The Rule requires publicly traded companies to investigate and report annually on the presence of Conflict Minerals in their products. The term “Conflict Minerals” refers to tin, tantalum, tungsten and gold. Congress enacted the Rule because of concerns that the exploitation and trade of these minerals by armed groups is helping to finance conflict in the Democratic Republic of the Congo (“DRC”) or adjoining countries Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (collectively with DRC, the “Covered Countries”), contributing to an emergency humanitarian crisis.
GoPro supports the goal of ending violence, human rights violations and environmental devastation in the Covered Countries. We are committed to complying with any requirements applicable to our Company under the Rule, and expect our suppliers to provide materials to GoPro that are conflict-free. We strive to work cooperatively with our supply chain partners in implementing Conflict Minerals compliance programs. GoPro requires all of our suppliers to engage in the due diligence described in this policy and to provide completed Conflict Minerals declarations using the Conflict Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template. We may reconsider our willingness to partner with suppliers that fail to provide full and timely disclosures in accordance with this policy. GoPro expects suppliers to steer their supply chain towards using only conflict-free smelters. A list of smelters that have been audited for compliance with the CFSI conflict-free smelter program is available on the CFSI website, which is continuously updated as more smelters are audited. We request all suppliers using smelters that are not yet verified as conflict-free to address these smelters with a request to participate in the CFSI conflict-free smelter program or otherwise switch to an already audited smelter.
Suppliers / Partners are required to implement processes to undertake:
(1) a reasonable inquiry into the country of origin of Conflict Minerals incorporated by the supplier or by any of its manufacturers or suppliers into any materials provided to GoPro, to determine if there is reason to believe that Conflict Minerals may have originated in a Covered Country;
(2) if such inquiry determines there is reason to believe that Conflict Minerals from the Covered Countries are present in any materials provided to GoPro, due diligence to determine the source and chain of custody of the Conflict Minerals in the supplier’s supply chain, including the facilities in which they were processed as necessary, to determine if any of these minerals directly or indirectly financed or benefited armed conflict in the Covered Countries;
(3) appropriate risk assessment and mitigation actions in connection with its country-of-origin inquiry and due diligence process, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
If the supplier does not know the original source of the minerals, the supplier agrees to cooperate with GoPro, including disclosing from whom the supplier purchased the minerals and urging others to disclose such information, so that the original source of minerals can be accurately determined and reported. The supplier shall comply with all laws regarding the sourcing of minerals, including, without limitation, the Rule and other laws prohibiting the sourcing of minerals from mines controlled by combatants. Without any further consideration, Supplier shall provide such further cooperation as GoPro may reasonably require in order to meet any obligations it may have under conflict minerals laws, including, without limitation, under the Rule. Interested parties can report improper activities in violation of the Conflict Minerals Policy at firstname.lastname@example.org .
Air Management. Supplier shall characterize, manage, monitor, control and treat air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals, and combustion by-products generated from operations, as required by applicable laws and regulations prior to discharge.
Corrective Action. Suppliers' compliance with this Code is subject to GoPro’s review, including third-party auditing of work and residential facilities and conducting confidential worker interviews. Suppliers must provide prompt access to their facilities and workers during any audit. We require suppliers to promptly provide a detailed remediation plan and take corrective actions for deviations from this Code, and GoPro will track suppliers’ remediation efforts. GoPro may (without liability) terminate its relationships with any supplier found to be in violation of this Code, including for denying prompt access to our auditors.
Code of Conduct Last Updated: April 11, 2017
GoPro employees who manage our manufacturing supply chain receive training on our Code. GoPro also has a training program for our manufacturers on our Code and supply chain standards. Our independent third-party auditors periodically conduct both unannounced and announced on-site audits of our manufacturers. GoPro aspires to audit our manufacturers before GoPro begins ordering products, and we require all of our suppliers to meet the standards in our Code as a condition of doing business with us. GoPro's agreements require our suppliers to comply with supply chain standards, which, among other things, include laws regarding slavery and human trafficking. GoPro employees are subject to internal accountability standards, which include disciplinary measures up to and including termination, for failing to follow GoPro requirements regarding our audits.
Suppliers interested in doing business with GoPro are invited to register their information and capabilities in our Supplier registration database. If our procurement team decides that our contracting needs align to the products or services your business offers, we will contact you regarding next steps.