Apple

Supplier Responsibility

Audit Procedure

v. 1.3

Table of Contents

1. Introduction.................................................................................................................. 3

2. Audit Context.............................................................................................................. 3

3. Audit Protocol.............................................................................................................. 5

4. SAQ Validation Checklist............................................................................................ 5

5. Facility Selection.......................................................................................................... 5

6. Audit Schedule............................................................................................................. 5

7. Audit Team................................................................................................................... 5

8. Audit Team Preparation............................................................................................... 6

9. Supplier Notification.................................................................................................... 8

10. Opening Meeting........................................................................................................ 8

11. Facility Tour............................................................................................................... 8

12. Investigation............................................................................................................... 9

13. Facility Scoring......................................................................................................... 10

14. Special Findings....................................................................................................... 10

15. SAQ Validation........................................................................................................ 11

16. Closing Meeting....................................................................................................... 11

17. Draft Audit Report................................................................................................... 11

18. Audit Report Approval............................................................................................ 12

19. Draft Corrective Action Plan (CAP)........................................................................ 12

20. CAP Approval.......................................................................................................... 13

21. CAP Closure............................................................................................................. 13

22. Appendices and References:.................................................................................... 13

23. Version History........................................................................................................ 14

1. Introduction

Apple is committed to ensuring the highest standards of social responsibility in everything we do. The objective of Apple’s Supplier Social and Environmental Responsibility (SER) program is to ensure that Apple’s suppliers provide safe working conditions, treat employees fairly, and use environmentally responsible manufacturing processes wherever Apple products are made. This is achieved through a variety of initiatives that measure, monitor and improve the CSR of Apple’s suppliers. Apple’s SER audit program is one such initiative.

This document describes Apple’s SER audit process in more detail.

2. Audit Context

This audit should be considered as part of an overall process starting with a supplier’s commitment to Apple’s Supplier Code of Conduct and ending with continuous improvement of the supplier’s CSR performance. This is a summary of the process:

The audit process is undertaken in accordance with the following principles:

q The philosophy of the audit is a joint and collaborative effort between the supplier and the audit team.

q The purpose of the audit is to identify areas of good and poor practices and performance in the areas of labor and human rights, worker health and safety, environmental protection and business ethics.

3. Audit Protocol

The audit is conducted using Apple’s SER Audit Protocol. This protocol defines the questions to be answered in the course of the audit, and the scores to be assigned based on the answers. This protocol is maintained by Apple’s Social and Environmental Responsibility Program Manager (“Program Manager”).

4. SAQ Validation Checklist

The audit provides an opportunity to validate the facility’s original answers to the Self-Assessment Questionnaire (SAQ). A facility’s accuracy in rating itself on the SAQ will be used in future years in determining the risk ranking of each facility.

Validation of the Self-Assessment Questionnaire is conducted using the SAQ Validation Checklist. This checklist provides the facility’s original responses to particular SAQ questions, and sources that the auditors can reference to confirm the accuracy of these answers.

5. Facility Selection

Facilities may be selected for an audit based on risk assessments (meta-data as well as Self-Assessment Questionnaires) as well as ongoing developments (negative events, changes in operations).

6. Audit Schedule

The Program Manager develops a proposed audit schedule and garners the approval of the following affected parties:

7. Audit Team

The audit is conducted by approved third-party audit firms, internal Apple staff, or a combination thereof. The audit is led by a Lead Auditor, who is responsible for the timely and successful completion of the audit. Apple’s SER Program Manager and the Lead Auditor agree to an audit team that is appropriate in size and expertise, as follows:

Team Size: The size of the audit team is sufficient to complete the audit in the scheduled time-frame (usually 1 – 3 days), given such considerations as the physical size of the facility, number of workers, manufacturing process complexity, and whether the engagement is a first audit or follow-up audit.

Team Expertise: The audit team must include individuals with expertise in the full range of issues covered by the audit protocol (human and labor rights, worker health and safety, environmental protection, and business ethics).

Individual Expertise: Each individual member of the audit team must be an experienced auditor. If an inexperienced member is assigned to the audit team, he or she must be trained as described in “Audit Team Preparation” below.

8. Audit Team Preparation

The team prepares for the audit as follows:

Training: If there are any individuals who do not have experience conducting audits, they are trained in the following basic auditing skills:

- Reviewing documents

- Conducting interviews

- Conducting visual inspections

- Documenting findings

Company Research: The Apple SR Audit Representative conducts a search for press related to recent social responsibility activity related to the company/facility being audited. Recommended sources of information include:

· Supplier’s corporate web page

· http://www.ethicalcorporation.com/

· http://www.google.com/

· http://www.sustainability-index.com/

· http://www.calvert.com/

· http://www.iccr.org/

Issues Orientation: Auditors must be familiar with the region, country, and industry of the supplier, and aware of the social, labor, environmental, ethical and health and safety issues most relevant to the sector. If necessary, the Lead Auditor or Program Manager provides training to ensure all members are oriented to these issues.

SAQ Validation Checklist: The Lead Auditor fills in the facility’s original answers to the SAQ questions on the SAQ Validation Checklist.

Auditor Assignments: The Lead Auditor assigns each individual to the scope of issues that he or she will be covering in the audit, including which portions of the audit protocol and which portions of the SAQ Validation Checklist each auditor will cover.

Note: It is recommended that the Apple Audit Representative conduct the Management Systems portion of the audit, to allow for a richer discussion with facility management about improvement opportunities.

Audit Protocol General Information: The Lead Auditor completes the “General Information” tab of the audit protocol.

Tool Review: The audit team reviews the Apple Supplier Code of Conduct, this SER Audit Procedure, their assigned sections of the SER Audit Protocol and SAQ Validation Checklist, and any other materials or tools that they will be using to conduct this audit.

Facility Background: The audit team reviews the facility’s completed Supplier Self-Assessment Questionnaire and any previous audit reports.

Audit Plan: To improve the efficiency of the on-site evaluation, each auditor prepares an audit plan covering their assigned sections and areas; the Lead Auditor approves these plans. The plans consider:

- Physical locations to be inspected

- Documents to be reviewed; see “Planning Sample Sizes” below.

- Personnel to be interviewed; see “Planning Sample Sizes” below.

- Key questions and areas of discussion

- Estimated time requirements

Logistics: The Lead Auditor ensures that the auditors have made sufficient arrangements for travel and accommodations for the audit.

Planning Sample Sizes

9. Supplier Notification

In most cases, Apple notifies the supplier of the audit at least 2 weeks prior to the audit; in some cases a shorter notice period may be appropriate. This notification is usually provided by the Global Supply Manager who has a relationship with that supplier. See Appendix A for a template notification letter.

10. Opening Meeting

The purpose of the opening meeting is for the audit team, Apple management, and supplier management to align on important aspects of the audit, such as the process, scope, schedule, logistics, and facility-specific rules for the audit team.

This meeting has two primary goals:

· To align the audit team, Apple management, and supplier management on the purpose, process, scope, schedule, and logistics of the audit; and

· To create a cooperative atmosphere for conducting the audit.

The opening meeting includes at least the following participants, in person or by phone:

· Facility senior management (plant manager, Apple client contact)

· Facility Human Resources manager

· Facility Environment, Health, Safety manager

· Facility Maintenance manager

· Lead Auditor and audit team

· Apple Procurement Global Supply Manager

· Apple Procurement Regional representative

· Apple SER representative

Appendix B provides a template agenda for this meeting.

11. Facility Tour

After the opening meeting, facility management provides a tour of the facility to the audit team. The purposes of the tour are to:

· orient the audit team to the facility

· identify operational areas to be inspected later in detail; and

· familiarize the audit team with the resources they will need over the course of the audit (files, work space, amenities, etc.)

12. Investigation

For the duration of the audit, the audit team performs document reviews, management interviews, employee interviews, and visual inspections in order to assess the facility’s conformance to the Apple Supplier Code of Conduct (CoC). The audit protocol provides suggested documents, interviewees, and inspection targets to assess conformance with each line item from the CoC. Below are general guidelines for performing these investigations:

Document Review

Given the time constraints of the audit, it may not be feasible for the auditors to review all relevant documents. The auditors should therefore ensure that the number and type of documents reviewed are sufficient to provide an accurate assessment of the facility’s status and to defend the findings if necessary. Below are recommendations for selecting documents for review:

Procedure Versions: The auditor should review the most current version of any procedures.

Time-Frame for Records: Unless otherwise stated, the time-frame is one year before the audit date; records should cover this full range.

Representativeness: Documents should be representative of all aspects of facility operations, as follows:

Management: Documents should cover all departments, business units, etc.

Product Lines: If the facility makes multiple products for Apple, documents for all Apple product lines should be reviewed

Shifts: Documents should cover all shifts (days, swings, nights, weekends)

Employee Demographics: Documents should represent all types of employees at the facility and should be balanced with respect to the demographic mix (age, gender, seniority, status (permanent/temporary/trainee), etc.)

Typical & Atypical Conditions: Documents should reflect both typical operating conditions (normal production), as well as atypical operating conditions (emergencies, ramp-ups, seasonal peaks, etc.)

Sample Size: Sample size should have been determined in the pre-audit preparation; see Section 8 for details on selecting sample size.

Interviews

The audit team selects workers for interview throughout the audit. Interviewees are drawn from a range of workers including permanent, temporary, subcontract labor, security, cleaners, food preparation, etc. The pool of workers to be interviewed should include new workers at less skilled positions, workers from various departments and shifts, and workers of both genders. This should include worker representatives as appropriate.

Confidentiality: The worker interviews must be conducted in a confidential space. Supplier management is asked not to be present during these interviews. Worker input must be confidential and the supplier company should agree at a senior level that they will encourage workers to be open and honest during interviews and actively protect any interviewed worker.

Languages: Language problems may exist and interpreters may be required.

Sample Size: Sample size should have been determined in the pre-audit preparation; see Section 8 for details on selecting sample size.

Observation

To the greatest extent possible, observations should cover all facilities, equipment, operation types, shifts, etc. Sufficient details (equipment number, room number, etc.) should be noted with any findings to defend the finding and allow follow-up.

Audit Team Meetings

The audit team meets frequently throughout the audit to exchange information and gauge the audit’s progress. The audit team typically meets at the beginning and end of each day to discuss findings, exchange information, determine audit follow-up trails and strategies, and note areas that need attention.

13. Facility Scoring

As the audit progresses, the auditors assign scores to each line item in the audit protocol, accompanied by sufficient detail to ensure thorough understanding of the findings and to defend the findings if necessary. The Lead Auditor works with each audit team member to ensure the uniformity and accuracy of these scores as well as to ensure that sufficient details are provided.

14. Special Findings

Generally the audit team does not disclose findings until the end of the audit. There are two exceptions to this rule:

Imminent Threat: If an auditor discovers a condition that poses an immediate threat to human health, life, or the environment, he/she should notify the Lead Auditor immediately who will convey the situation to facility management and to Apple SER.

Severe Personal Criminal Liability: Definitions of and consequences for criminal behavior differ vastly from one country to another. Out of respect for the serious consequences that could result from certain types of discoveries, Apple has arranged a special review process for any potential findings related to certain types of issues. If any of these issues arise during the course of the audit, the findings should be disclosed immediately to Apple SER, who will consult with Apple Legal.

· Any finding related to Involuntary Labor.

· Any finding related to sexual harassment under “Harsh Treatment and Harassment”.

· Any finding related to improper disposal or release of chemically hazardous, biohazardous, or radioactive substances or waste (covered by CoC provisions “Hazardous Substance Management and Restrictions”, “Wastewater and Solid Waste Emissions”, and “Air Emissions”.

· Any violations related to the prohibition or restrictions of specific substances, covered by CoC provision “Hazardous Substance Management and Restrictions”.

· Any finding related to Corruption, Extortion, or Embezzlement.

· Any finding related to bribery under No Improper Advantage.

15. SAQ Validation

To conduct the SAQ validation, auditors review the facility’s original answers to the SAQ and then compare against current information as recommended in the SAQ Validation Checklist. Auditors note whether the question was answered accurately on the facility’s original SAQ response, or whether current information contradicts the facility’s original response.

16. Closing Meeting

The closing meeting is held at the end of the last day of the audit. This meeting should involve the same invitees as the opening meeting. At the end of the meeting, Apple SER obtains a signature from facility management agreeing to the summary of the findings.

Appendix C provides a template for the closing meeting agenda.

17. Draft Audit Report

Within five working days of the audit closing meeting, the third-party auditors provide Apple SER with the draft audit protocol and summary table.

Within two working days, the Apple SER audit lead finalizes the information in the audit protocol. The completed protocol serves as a draft audit report. The Apple SER audit lead distributes this draft audit report to facility management and the Program Manager.

18. Audit Report Approval

Facility management responds back to the Lead Auditor within five working days of receiving the draft report. If the facility agrees with the draft, the report is finalized. If the facility disagrees with any aspects of the report, the facility and the Lead Auditor work to resolve within five working days. If they cannot reach agreement within that week, the Program Manager makes a judgment and the report is finalized.

The Program Manager distributes the final audit report to facility management and the GSM.

The Program Manager instructs the Lead Auditor to have his/her team destroy all paper and electronic copies of working papers and draft reports.

19. Draft Corrective Action Plan (CAP)

The facility provides a draft Corrective Action Plan (CAP) to the GSM within ten working days of receiving the final audit report, using the template provided by Apple (Appendix F). The process for developing this CAP consists of doing the following for each finding from the final audit report:

· Conducting a root cause analysis of each finding

· Proposing a corrective action

· Proposing a preventive action

Root Cause Analysis: The facility must identify a root cause for each audit finding. Root cause analysis is intended to identify the underlying cause of any problem, failure, or nonconforming condition. Many widely accepted methods exist to conduct such analyses; the facility is responsible for selecting its own methodology. The facility should have documented procedures for whatever root cause analysis method it selects. For each finding in the Findings table of the audit report, the root cause that has been identified should be listed in the Root Cause column of the CAP.

Corrective Actions: Corrective actions are intended to remedy a specific situation in an immediate sense; they are not long-term solutions that will prevent recurrence of a particular problem. An example of a corrective action is shown below. For each finding in the audit report, the CAP must describe the specific corrective action(s) that the facility intends to take (or has already taken) along with a target completion date and responsible party.

Preventive Actions: Preventive actions are intended to prevent recurrence of a finding by addressing the systemic conditions that gave rise to the original finding. An example of a preventive action is shown below. For each finding in the audit report, the CAP must describe the specific preventive action(s) that the facility intends to take (or has already taken) along with the target completion date and responsible party.

Example

20. CAP Approval

The Program Manager reviews and approves the CAP within five working days of receiving it. Subject-matter experts (such as EHS staff, Legal staff, or auditors) may be consulted. The Program Manager and GSM discuss any disputes with facility management. If this group is not able to reach resolution, Apple’s SER Senior Manager makes a judgment and the CAP is finalized.

21. CAP Closure

The GSM maintains communication with the supplier on a regular basis (at least monthly) to track the closure of the corrective action plan. The Program Manager uses data from the GSMs to provide periodic status reports to Apple management.

Once all of the corrective and preventive actions for a particular facility have been closed out, the facility senior management sends the GSM a closure certification. A template for this certification is provided in Appendix D.

22. Appendices and References:

· Appendix A: Facility Notification Template

· Appendix B: Opening Meeting Agenda

· Appendix C: Closing Meeting Agenda

· Appendix D: Closure Certification Template

· Appendix E: Audit Milestones Timeline

· Appendix F: Summary Table Template

· Appendix G: Audit Logistics Sheet

· Appendix H: Post-Audit Communications Templates

· Appendix I: Auditors Ethics Guidelines

· Appendix J: Logistics E-Mail Templates

· Appendix K: GSM Talking Points Template

· Appendix L: Opening Meeting Slides Template

· Appendix M: Closing Meeting Slides Template

· Appendix N: Management Interview Schedule Template

· Audit Protocol

· SAQ Validation Checklist

· Apple Supplier Code of Conduct

· Apple’s Regulated Substances Specification, 069-0135

23. Version History

v. 1.2 June 13, 2007

· Revised Section 14 “Special Findings” to allow Apple SER to decide whether the finding should be included in the audit report & closing meeting.

· Revised sample size guidance and moved it from Section 13 (Investigation) to Section 8 (Audit Team Preparation).

· Revised the instructions for Closing Meeting in Section 16 to require the plant manager’s signature on the Summary Findings in the closing meeting.

· Revised timeline for Draft Audit Report in Section 17 to reflect the 5-day turn-around for third-party auditors and the 2-day turn-around for Apple SER.

· Converted timelines from weeks to working days for all post-audit milestones.

v. 1.3

· Changed name from “Apple Supplier SER Audit Procedure” to “Apple Supplier Responsibility Audit Procedure”.

· Revised Section 8 as follows:

- Added requirement that Apple SR Audit Rep conduct company research.

- Added recommendation that Apple SR Audit Representative be assigned to Management Systems portion of audit.

· Made revisions to harmonize SR audit protocol with Quality audit procedures, including:

- Section 12 Investigation: Deleted requirement for obtaining photo permission from Apple procurement.

- Section 14 Special Findings: Deleted requirement not to reveal special findings to anyone else.

- Other minor changes.