Commitment and Governance
NVIDIA discloses that it has a program to combat people human trafficking, for which the Senior Manager of HR Operations is responsible. The company states that all employees are required to complete training on its Code of Conduct (which includes reference to forced labor). It discloses that 'relevant employees took several RBA [Responsible Business Alliance] Learning Academy courses', and that it assigned RBA Learning Academy courses to its suppliers, including those on forced labor, hiring and working with migrant workers, working hours, and wages. NVIDIA also discloses that it is a full member of the RBA.
Traceability and Risk Assessment
NVIDIA discloses some information on its suppliers, noting that its manufacturers of semiconductor wafers are Taiwan Semiconductor Manufacturing Company and Samsung and that its two main contract manufacturers are Foxconn and BYD. The company discloses a list of its smelters and refiners of 3TG (tin, tungsten, tantalum, gold), as well as the countries of origin of 3TG in its supply chains. In addition, NVIDIA states that it has integrated RBA risk assessment tools into its supplier management practices, and that it has conducted a risk assessment on its strategic suppliers.
NVIDIA states that it has "reviewed eight VAP [Validated Audit Process of the RBA] audits of strategic suppliers" and that its "two main contract manufacturers completed VAP or customer-managed audits". The VAP includes a review of relevant documents, such as working hour records and payroll, formal and informal interviews with workers which are conducted privately, and visits to production facilities and related worker housing. NVIDIA states that one of the common findings of their audits included non-compliance with working hour standards.