These Guidelines are designed to:
- Complement the T‑Mobile’s Supplier Code of Conduct and T‑Mobile’s Supplier Policies.
- Guide suppliers to improve their sourcing practices and internal due diligence where necessary.
- Guide T‑Mobile in the implementation of our own policies and commitments as they relate to responsible sourcing.
The Guidelines further recognize that certain materials, particularly ones derived from natural resources, can pose severe risks associated with human rights and the environment based on their extraction, transportation, and trade. We therefore expect our suppliers to exercise additional due diligence on the source and custody of these materials and operate in a manner that:
- Protects the environment,
- Aligns with our commitment to human rights, equal opportunity, fair labor standards, and a safe and healthy workplace, and
- Includes participation in multi-stakeholder initiatives towards responsible sourcing.
These guidelines apply to all suppliers of materials procured by any authorized T‑Mobile employee, agent, or third party acting on behalf of T‑Mobile.
Minerals sourced in conflict regions
As a purchaser of electronics products, T‑Mobile is concerned about the human rights abuses and risks associated with the extraction, transport, and trade of certain minerals in the Democratic Republic of the Congo (DRC) and its adjoining countries. These trade minerals, referred to as “conflict minerals,” include columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives (which are currently limited to tantalum, tin, and tungsten), and any others that the U.S. Department of State determines are used to finance conflict in the DRC or an adjoining country. U.S. law requires companies to conduct due diligence on the source and chain of custody of any conflict minerals contained in products that they manufacture or contract to manufacture. In connection with such due diligence, T‑Mobile expects and relies upon our suppliers to conduct their own due diligence into their supply chains and provide us with accurate and complete information regarding the source and chain of custody of the conflict minerals supplied to T‑Mobile.
Suppliers are required to:
- Not use any conflict minerals that originated in the DRC or an adjoining country in the functionality or production of any products supplied to T‑Mobile unless they are from recycled or scrap sources.
- Avoid sourcing any materials from a region impacted or associated with human rights violations included in the World Bank’s Harmonized List of Fragile Situations (external) .
- Conduct their own due diligence into the source and chain of custody of any conflict minerals used in the functionality or production of products that they supply to T‑Mobile.
- Provide full transparency of the mineral supply chain back to the mining source, using a robust and verifiable traceability system.
- Respond to T‑Mobile’s inquiries related to conflict minerals in a timely manner and verify the source and chain of custody of any conflict minerals used in the functionality or production of products supplied to T‑Mobile, including but not limited to requests for information about:
- a. the country of origin and identity of smelters of conflict minerals
- b. supplier’s due diligence and risk management procedures regarding conflict mineral sourcing and traceability of data
- c. T‑Mobile’s supplier audits and disclosure obligations, including any reports that we must file with the U.S. Securities (external) and Exchange Commission (external)
- Adopt a conflict minerals policy and supplier due diligence practices consistent with U.S. law, the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas by the Organisation for Economic Co-operation and Development (OECD (external) ), and the United Nations Guiding Principles on Business and Human Rights.
Suppliers shall develop and implement the systems and tools to comply with these Guidelines as quickly as possible. In no case shall a supplier use any conflict minerals in the functionality or production of a product supplied to T‑Mobile without first having implemented such systems and tools.
T‑Mobile has an important role to play in the responsible sourcing of wood fiber-based products, including all paper and paperboard packaging material used by T‑Mobile. These Guidelines seek to ensure responsible sourcing of wood fiber paper and paperboard packaging for our operations.
Suppliers are expected to use wood fiber in the most efficient and optimal manner possible, and:
- Maximize the use of recycled fibers where these are the most environmentally and socially responsible options and where technical specifications and availability allow for their use.
- Work with suppliers to identify paper products and paperboard packaging that make the most efficient use of fiber inputs.
- Minimize the use of paper-based records.
To support these Paper Sourcing Guidelines, suppliers must participate in the Directed Paper Buy Program either by purchasing from stocks selected by T‑Mobile that meet these requirements above or by providing fully transparent reports on the paper or paperboard used.
For non-recycled products and materials suppliers should ensure that all virgin wood, pulp, and fibers used in the manufacture of paper products and paperboard packaging are procured from sources that:
- Comply with T‑Mobile’s Supplier Code of Conduct.
- Comply with all applicable laws and regulations of the countries in which they operate, especially those pertaining to wood harvesting, production, and transport processes.
- Avoid sourcing from a region impacted or associated with human rights violations included in the World Bank’s Harmonized List of Fragile Situations (external) .
Where a known or greater risk of forest conversion or deforestation is identified through OECD (external) or other NGO reporting, T‑Mobile will require suppliers to obtain certifications from independent organizations such as the Forest Stewardship Council to ensure that all virgin wood, pulp, and fibers used in the manufacture of paper products and paperboard packaging are procured from sources that:
- Do not engage in deforestation, defined as the conversion of natural forests to plantation or non-forest use such as agriculture or development.
- Protect source forests that are known to contain or are suspected of containing High Conservation Values1, including peatland ecosystems.
- Respect land tenure rights and the rights of indigenous and local communities to give or withhold their free, prior, and informed consent to operations on lands to which they hold legal, communal, or customary rights. New or existing conflicts, including conflicts resulting from a lack of free, prior, and informed consent should be managed and resolved through a transparent, balanced, and accessible dispute resolution process.
- Provide full transparency of the fiber supply chain back to the forest source, using a robust and verifiable traceability system.
Additionally, T‑Mobile will show preference to suppliers who demonstrate industry best practices in the following key areas:
- Mill and printer environmental performance, including but not limited to energy usage (amount and type), ink usage (amount and type), air and water emissions, bleaching processes (use of chlorine), and chemical waste disposal.
- Responsible forest management, including but not limited to good forest planning, minimization of impacts from road building and logging, protection of riparian and wetland areas, support for local communities, and responsible chemical usage.
- Inclusion and support of small landholders in the supply chain.
- Increasing energy-efficiency and reducing water use.
T‑Mobile will periodically audit suppliers for compliance with these Guidelines and may monitor performance against applicable laws, regulations, industry best practices, and NGO standards or reporting. Any deficiencies identified must be corrected timely. Any violations of these Guidelines, when applicable, may jeopardize your business relationship with T‑Mobile up to and including termination of that relationship.
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Concerns or suspected T‑Mobile Policy or Guideline violations may be reported to the T‑Mobile Integrity Line.
1 As defined by the High Conservation Value Network, https://www.hcvnetwork.org/.As adopted on 11/13/2017. Internal approver: VP, Technology Procurement & Bus Ops