At Autodesk, we are working to design a better world where all people live well and within the limits of the planet. Human rights are fundamental to living well, and we embrace our responsibility and opportunity to respect and promote human rights across our business.
Demonstrating our commitment, we endorse the United Nations Global Compact and the human rights and labor principles it includes.
Consistent with Autodesk’s culture of ethical behavior, integrity, and respect, we work to continually refine our business practices to reflect our commitment to human rights. Below are our policies and activities related to human rights as they affect our employees, our suppliers and business practices, and our customers.
We support and value our diverse workforce and do not tolerate any form of discrimination or harassment of our employees, contractors, or temporary workers anywhere in the world, including during our selection process. Our Code of Business Conduct (CoBC) conveys our values and expectations for business conduct in a broad range of areas, including equal opportunity and nondiscrimination.
To protect employee health and safety, our injury and illness prevention program covers employee and visitor safety issues, such as evaluation of workplace hazards, accident investigations, and compliance with safe and healthy work practices. We have also established site-specific emergency response plans.
Employees who suspect a violation of the law, our CoBC, or any other Autodesk policy can report their concerns without fear of retaliation. (See hotline details in our CoBC.)
OUR SUPPLIERS AND BUSINESS PARTNERS
In early 2013, we established our Partner Code of Conduct, which outlines the standards and practices we expect our resellers and distributors to follow while conducting business with or on behalf of Autodesk. The code specifies that business partners must support internationally recognized human rights and comply with all applicable laws and regulations regarding health and safety in the workplace, the eradication of human trafficking and slavery, and the elimination of child labor. In addition, we expect our partners to support fair labor practices, including the freedom to associate, and to provide a work environment that is free from harassment and discrimination. A violation of the Partner Code of Conduct constitutes a breach of agreement with Autodesk and may result in action up to and including termination of status as an Autodesk partner.
Although the Partner Code of Conduct does not currently apply to suppliers, we value suppliers who have made commitments to human rights principles and demonstrate strong labor practices. Some of our major suppliers have well-established policies and programs in this area.
Autodesk and its subsidiaries worldwide respect the rights of our customers and website visitors and our obligations with regard to privacy and personal information. Our Privacy Statement explains how we collect, store, use, share, transfer, and retain personal information. All of our employees, contractors, and subsidiaries are required to abide by our Privacy Statement. They also must adhere to more detailed internal policies regarding Autodesk’s overall data protection requirements and privacy principles.
Autodesk encourages our customers to promote human rights, including when appropriate through the use of our products. Autodesk does not support the use of our products in a way that harms human rights. For more information, see Autodesk’s Statement on Human Rights related to the California Transparency in Supply Chains Act of 2010.
CALIFORNIA SUPPLY CHAINS ACT
Slavery and Human Trafficking Policy Statement
On January 12, 2012, the California Transparency in Supply Chains Act of 2010 went into effect in California. This law requires retailers and manufacturers with annual worldwide gross receipts over $100 million (USD) to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods. The law was designed to increase transparency and allow consumers to make more informed decisions about the products they purchase.
As primarily a software company, Autodesk does not have an extensive manufacturing base or supply chain for tangible goods. However, our company is committed to promoting and protecting human rights wherever we do business. We expect our suppliers and other business partners to be committed to ethical behavior, to comply with all applicable laws and regulations, and to take action to promote the eradication of human trafficking and slavery. We will continue to work with our suppliers and refine our own requirements and processes to reinforce our commitment to human rights and a culture of ethical behavior, integrity and respect.
Autodesk has adopted a Code of Business Conduct that conveys our values and business conduct expectations, including compliance with all applicable laws and regulations. The Autodesk Code of Business Conduct is generally either incorporated by reference into agreements with suppliers or conveyed separately as an expectation for a continued business relationship. Our supplier contracts also generally contain representations or covenants of compliance with all applicable laws and regulations, and in some cases specify laws and employment standards related to manufacturing activities.
In addition, we expect procurement partners to adopt and abide by Autodesk Policy Guidelines for Suppliers, which include provisions for (1) the support of internationally recognized human rights; (2) compliance with all laws and regulations regarding health and safety in the workplace, the eradication of human trafficking and slavery, and the elimination of child labor; and (3) the promotion of fair labor practices, including the freedom to associate, and a work environment that is free from harassment and discrimination. These Guidelines are also generally incorporated by reference into procurement contracts. Our distribution partners are expected to adopt and abide by a similar provision in our Autodesk Partner Code of Conduct.
To further evaluate and address the risk of human trafficking and slavery in our supply chain, Autodesk has initiated a supplier verification program. Through this program, Autodesk sends suppliers questionnaires to assess their awareness of and compliance with the foundational principles of the California Transparency in Supply Chains Act. This program allows Autodesk to evaluate areas of risk as well as opportunities for education within its supply organization. Autodesk does not use a third party to conduct this program.
Due to Autodesk’s limited manufacturing role, our company has not traditionally conducted supplier audits on these matters. But as noted above, compliance with laws promoting the eradication of human trafficking and slavery is an expectation for Autodesk suppliers. And as part of Autodesk’s verification program, we request that suppliers disclose the extent and manner of any compliance audits conducted in their own direct supply chains. We will continue to evaluate best practices in our industry and our own processes as our business evolves.
As noted above, Autodesk has implemented a verification program in its supply chain. Through this program, we ask suppliers to certify that their company is in compliance with all relevant slavery and human trafficking laws in the countries in which they are doing business.
Autodesk expects all of its employees and its suppliers to comply with Autodesk’s Code of Business Conduct. Violations of the Code can be grounds for termination of employment and can constitute a breach of contract for applicable suppliers. Autodesk reserves the right to terminate business with any procurement partner that violates our Policy Guidelines for Suppliers, including provisions against slavery and human trafficking.
Autodesk also encourages employees, partners, suppliers and the general public to report any potential violations of the Code of Business Conduct or Code of Ethics through the Autodesk Ethics and Compliance Hotline at 855-822-9535 or via the web at www.autodesk.ethicspoint.com.
Every Autodesk employee must complete annual training on the Autodesk Code of Business Conduct, and must expressly certify compliance with its provisions. Autodesk has also initiated a specialized training program for employees with procurement and supply chain management roles to provide guidance on identifying and responding to supply chain issues including slavery, human trafficking, and child labor.
CONFLICTS MINERALS POLICY
Integrity is one of Autodesk’s core values. We believe that running our business with integrity includes managing our supply chain in an ethical and socially responsible way and promoting and protecting human rights wherever we do business.
Although we are primarily a software company and the vast majority of our products and services are software, we do manufacture a limited number of hardware products. Like many companies in the technology industry, we are concerned by reports that trade in conflict minerals mined in the Democratic Republic of the Congo and adjoining countries (the “Covered Countries”) may be funding violent militias that have committed atrocities in those countries. These minerals include tin, tungsten, tantalum, and gold, each of which is often used in electronics.
Autodesk supports industry-wide efforts to encourage responsible sourcing of conflict minerals and transparency in supply chains, including efforts by the Electronic Industry Citizenship Coalition, which has established supply chain standards to promote social, ethical, and environmental responsibility. Furthermore, in 2012, the U.S. Securities and Exchange Commission adopted a rule pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires publicly-traded companies to disclose whether the products they manufacture or contract to manufacture contain necessary conflict minerals that originate from the Covered Countries, and, if so, to disclose information about the source and chain of custody of those conflict minerals (the “conflict minerals rule”).
Autodesk continues to comply with the conflict minerals rule, and we are committed to working with our direct suppliers to ensure transparency in our supply chain. We expect our direct suppliers to assist us in our ongoing compliance and due diligence efforts by providing all necessary information using the Conflict Minerals Reporting Template developed by the Conflict-Free Sourcing Initiative. Autodesk will evaluate the information provided by its suppliers and to the extent those responses indicate a risk that the supplier is not complying with this Policy, Autodesk’s management reserves the right to evaluate the supplier relationship and take any appropriate action. Finally, we have implemented a conflict minerals due diligence program that is designed to conform, in all material respects, with the due diligence framework set forth in the Organisation for Economic Co-operation and Development’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.”