Governance

At Corning, our nearly 170-year legacy of excellence in global manufacturing and innovative technology development is guided by a commitment to conducting business ethically and in compliance with all laws and regulations. Governance of our supply chain is integral to this philosophy, as we hold our supply chain partners to the same standards by which we judge ourselves.

All our suppliers are required to abide by our Supplier Code of Conduct and Corning’s Human Rights Policy to ensure that our global business network is conducted in a consistently legal and ethical manner. These standards form the foundation of a comprehensive process that includes compliance with all corporate policies and procedures, and an abiding belief in the integrity of our business network.

Corning has a dedicated supply chain sustainability team, which is part of the company's global supply management organization. The team is led by the Jeanne Estep, Director of Compliance and Sustainability, Global Supply Management. The team drives internal programs designed to ensure supply chain sustainability (social and environmental), with a particular focus on minimizing the risk of forced labor in the supply chain.

The team also collaborates with colleagues across Corning to provide ongoing oversight of the supplier management process (see Accountability).  This process provides Corning senior management with real-time data regarding supplier compliance and areas of needed improvement.  We continually seek input from internal and external stakeholders to further enhance our supply chain oversight and reporting processes and are committed to continuous improvement and transparency throughout our global network of supplier partners. Corning actively participates in key international organizations such as Supply Chain 50, Procurement Leaders, The Conference Board, Gartner, and National Association of Manufacturers.

The Corporate Relations Committee has responsibility for strategies and policies in the areas of public relations and reputation (including supply chain and human rights policies), employment policy and employee relations, government and public policy, and environmental and community responsibility.  The Corporate Relations Committee meets 5 times a year to discuss relevant topics.  To review our Corporate Governance Policies, Codes of Conduct and Ethics, Board of Directors, and Board Committee Charters, visit Corporate Governance.

In 2021, Corning’s supply chain was comprised of suppliers with 72 countries, with 85% of our suppliers in 9 countries (see graph on the left to view Corning’s top sourcing countries). By region, NA represents the largest share of our supplier base with 39.9% of suppliers.

Of the total supply base, 22.2% of the suppliers and 19.6% of the spend is in high risk countries (as identified by Amfori BSCI 6 factors scores lower than 60 https://www.amfori.org/resource/countries-risk-classification).These high-risk countries are determined, in part, by human rights related factors.  Based on our risk assessments, groups especially vulnerable to human rights impacts in these countries, including forced labor and restrictions on freedom of movement, include migrant workers, women and children. Excluding low risk categories (e.g. energy, professional services, import/export services), suppliers in high-risk countries represent 2.8% of Corning’s suppliers and 5.8% of spend. More specifically, Corning’s risk exposure in these high-risk countries by category is as follows:

Labor and human rights violations can be identified in all tiers of the supply chain but can be more difficult to detect with sub-tier suppliers. Corning takes all labor and human rights violations seriously, and all of Corning suppliers are required to adhere to the Supplier Code of Conduct and Human Rights Policy and ensure their suppliers do the same.

Employees of Corning, suppliers and other relevant external stakeholders can reach Corning through our Grievance Hotline (Country Code) +1-888-296-8173 or online at www.ethicspoint.com. We take information from workers at Corning, external stakeholders and throughout our supply chain very seriously. Our Grievance Hotline provides safe and easy channel for them to get in touch with us. Information we receive this way may result in additional site visits, audits, or other engagement with a supply chain partner at any time. All reports are reviewed by Corning’s Chief Compliance Officer to determine if the investigation of such a report is warranted. Corning’s Chief Compliance Officer shall periodically provide reports to the Audit Committee of the Board of Directors and to the company’s external auditor concerning any Reports received by the company and actions taken by the company in response to such reports.

For more information about the hotline reports received in the prior year, see here.

Corning is committed to high standards of business conduct within its own operations and throughout its supply chain. In line with this commitment, employees, suppliers and other external stakeholders have the right – and the duty – to raise, in good faith, concerns about improper business conduct without fear of retaliation in any form. See Speak Up Policy.

In 2019, all members of Corning’s Global Supply Chain Management team, from senior leadership to supply chain personnel, participated in human trafficking, forced labor and modern slavery awareness training. This training was designed to provide our leadership with the knowledge and skills to promote human rights compliance throughout our supply chain network. In addition, Corning’s Global Supply Management and Supply Chain organizations are educated on supply chain social responsibility issues such as human trafficking, forced labor, modern slavery, transparency, child labor and human rights to build awareness and ensure that Corning’s supply chains reflect our values and respect for human rights.  Supply Chain Social Responsibility training has been integrated into functional employee learning plans and new employee onboarding program.

In 2020, Corning launched an awareness training for its highest risk suppliers, including Corning’s contract manufacturers and mining suppliers.  The supplier training is enabling us to share and re-enforce our Supplier Code of Conduct, which includes our requirements and expectations on forced labor, human trafficking and responsible recruitment and ensure Corning’s supply chains reflect our Values and respect for human rights, as identified in our Supplier Code of Conduct and Statement on Efforts to Combat Human Trafficking and Slavery. The training builds our suppliers’ capacity to identify risks related to human trafficking and forced labour in their own operations, as well as further upstream with their suppliers and in their own supply chains.  Suppliers are required to demonstrate a proficient level of understanding of our standards and expectations in order to complete the training.

By the end of 2021, over 300 suppliers of Corning’s supply chain were trained on our human rights commitments including the prohibition of forced labor.  In 2022, we are expanding this training to a broader set of suppliers, including new suppliers.