2017 Modern Slavery Statement
Nest Labs, Inc. and Nest Labs (Europe) Ltd. (collectively, 'Nest') are committed to treating all workers with respect and dignity, ensuring safe working conditions and conducting environmentally responsible, ethical operations.
We are issuing this statement pursuant to the UK Modern Slavery Act and California Transparency in Supply Chains Act to disclose Nest's efforts to ensure that modern slavery is not taking place in our supply chains or business operations. This is our second statement, covering our 2017 financial year (January-December 2017).
Throughout this statement we reference 'modern slavery', which includes slavery, servitude, forced or compulsory labour and human trafficking.
Nest's structure, business and supply chain
Nest Labs, Inc. is a wholly owned subsidiary of Google LLC, which is, in turn, a wholly owned subsidiary of Alphabet Inc. ('Alphabet'). The ultimate parent undertaking of Nest Labs (Europe) Limited is also Alphabet, and its immediate parent undertaking is Google Ireland Holdings Unlimited Company. Google LLC and Google Ireland Holdings Unlimited Company are collectively referred to in this statement as 'Google'. Nest generates revenue primarily through the sale of its core products, which include the Nest Learning Thermostat, Nest Thermostat E, Nest Protect, Nest Cam Indoor, Nest Cam IQ indoor, Nest Cam Outdoor, Nest Cam IQ outdoor, Nest Hello and Nest Secure. Nest also generates revenue from selling services to end-user customers and enterprise customers. These services include Nest Aware, Rush Hour Rewards, Time of Savings, Seasonal Savings and Safety Rewards.
Nest does not have manufacturing facilities. Because of this, our anti-modern-slavery efforts require strong collaboration and engagement with the global suppliers that manufacture products on our behalf.
Internal management, accountability and programmes
Nest participates in Google's Anti-Modern-Slavery and Responsible Supply Chain Programmes and, as such, is subject to the policies and procedures associated with these programmes. Google's Chief Ethics and Compliance Officer continues to oversee a team focused on combatting modern slavery in the company's supply chains and business operations, including Nest's. The Chief Ethics and Compliance Officer provides quarterly updates on the status of the company's Anti-Modern-Slavery Programme to a Compliance Steering Committee, composed of senior executives from different areas within Google's business. In addition, the Chief Ethics and Compliance Officer provides regular updates on anti-modern-slavery efforts to the Audit Committee of Alphabet's Board of Directors. Regular updates on the status of the Responsible Supply Chain Programme – which includes addressing the risk of modern slavery – are provided to a Responsible Supply Chain Steering Team, composed of Google's Chief Ethics and Compliance Officer, and leaders from Google's and Nest's hardware product areas. Finally, while day-to-day compliance programme management is operated by Google, Nest-specific supply chain sustainability or modern-slavery compliance concerns are addressed in collaboration with Nest, including Nest's legal team.
Policies addressing ethical conduct and the prevention of modern slavery
As reported in our last statement, Nest is subject to Google's Code of Conduct (the 'Code') and adheres to Google's Supplier Code of Conduct (the 'Supplier Code') for our product suppliers, and research and development suppliers (collectively, 'hardware suppliers'). The Supplier Code sets standards designed to protect the health, safety and treatment of workers, including the prohibition of any form of modern slavery, including forced, bonded (including debt bondage) or indentured labour; involuntary prison labour; sex trafficking; and the slavery or trafficking of people. We hold our employees and suppliers to high standards. Any violation of our standards by a Nest employee can result in disciplinary action, including termination of employment. Any violation by a supplier can result in contract termination.
In 2017, we continued our efforts to ensure that we include modern-slavery-specific language in our contracts, requiring suppliers to:
- comply with human-trafficking, forced-labour and modern-slavery laws;
- implement anti-modern-slavery due-diligence processes for their own suppliers and business partners;
- extend similar anti-modern-slavery language to their suppliers and business partners;
- allow audits for instances of modern slavery; and
- allow us to terminate our agreements with them for any violation of their contractual obligations related to the eradication of modern slavery.
Furthermore, we received approval in 2017 from Google's Compliance Steering Committee to expand the types of supplier required to comply with our Supplier Code of Conduct. We began this effort in Q4 of 2017 and will continue expanding supplier engagement and education on our Supplier Code of Conduct throughout 2018.
As subsidiaries of Google, Nest's business operations and supply chains are increasingly aligning with Google's and, as such, continue to be regularly assessed for risk associated with modern slavery by Google's Responsible Supply Chain Team. The factors considered in these assessments are based on international standards described by the Universal Declaration of Human Rights and the International Labour Organization, as well as industry standards. Nest continues to work with Google's Responsible Supply Chain Team to evaluate and address modern-slavery risks, among other risks, presented by our hardware suppliers. For more information on Google's efforts to assess these risks (which assessment includes Nest's business operations and supply chains), please see the Google 2017 Modern Slavery Statement and Google's Responsible Supply Chain report, Creating a Responsible Supply Chain.
Due diligence and contracting
Nest's contracting practices are managed within Nest by Nest's legal team, in alignment with the policies and processes developed by Google regarding supplier conduct. Due diligence is conducted on Nest's direct hardware suppliers and vendors that are identified as having higher risk through the assessments described in the preceding section (collectively, the 'higher-risk suppliers').
In 2017, we worked to update and improve our questionnaire assessing the labour risks of our suppliers, which incorporates questions from The Slavery & Trafficking Risk Template (developed by the Social Responsibility Alliance) and the US Department of State's Responsible Sourcing Tool. As part of the due-diligence process, higher-risk suppliers complete a self-assessment questionnaire about their working conditions and management systems. The due-diligence process also includes supplier background checks, examination of labour-related red flags that appear in publicly available databases and media sources, and review of higher-risk suppliers' names against human-trafficking watch lists.
If red flags are discovered, extensive and documented follow-up is conducted to remediate those issues. In certain cases, Nest may decide to no longer pursue a relationship or to terminate the current relationship with a supplier.
Training in the Code reinforces the expectation that employees, temporary workers and contractors (collectively, 'workers') follow applicable laws and report concerns of illegal or unethical activity. Nest workers involved with Nest's supply chain and product procurement are trained to conduct due diligence to identify and avoid working with third parties that engage in modern slavery or other illegal practices. Nest workers who manage relationships with higher-risk suppliers identified in the Google risk assessment receive supplemental in-person training. In addition, in late 2016, an online training course was launched that includes anti-modern-slavery education for Nest workers in roles related to the management of hardware suppliers. This training helps workers to identify modern-slavery red flags, shares anti-modern-slavery best practices and instructs workers to report modern-slavery concerns.
Assessing and reporting on effectiveness
Periodic, independent third-party audits are performed at higher-risk Nest hardware and non-hardware suppliers' facilities. The audits include in-depth factory tours, meetings with management, on-site interviews with workers, document reviews and assessments of related areas, such as dormitories, cafeterias, wastewater treatment facilities and warehouses. The audit protocol is designed to assess suppliers' performance in the areas covered by the Supplier Code, including the risk of modern slavery. Any issues identified during the audit are investigated to determine their root causes and to develop corrective action plans. While our audits are not unannounced, our supplier managers are trained to report any concerns that they might observe on an ongoing basis. In 2017, Google published its first Responsible Supply Chain report, entitled Creating a Responsible Supply Chain, which includes Nest's business operations and supply chains within its scope. This report provides more detailed information about the above-mentioned audit and supplier engagement efforts.
In addition to audits, risk is assessed at Nest suppliers via direct engagement with workers through individual and group interviews, as well as tablet-based worker surveys.
Reporting concerns or raising issues related to modern slavery
Multiple options for reporting issues related to modern slavery are available to Nest workers, including a helpline that gives callers an option to report concerns anonymously, which is promoted through internal policies, communications and training. In addition, we strictly prohibit retaliation for raising concerns.
If a modern-slavery concern is raised through the helpline or other reporting channels, Google's Ethics and Compliance Team coordinates with appropriate stakeholders at Nest and at Google to investigate and address the issue. If a reported concern is substantiated, the corrective response may involve working with the supplier to ensure that the issue is addressed or, if that is not possible, terminating the supplier.
Modern slavery is a complex challenge that cannot be solved overnight. Our efforts to combat these practices are ongoing, evolving and continually improving. We made progress in 2017 and intend to continue our momentum in 2018.
This statement was approved by the Board of Directors of both Nest Labs, Inc. and Nest Labs (Europe) Ltd.
Board Member, Nest Labs, Inc.
Board Member, Nest Labs (Europe) Ltd.