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Suppliers Principles, p1: https://www.delltechnologies.com/asset/en-us/solutions/service-provider-solutions/legal-pricing/dell-supplier-principles.pdf

 

The Principles are applicable to Dell Technologies’ suppliers, including but not limited to final assembly, direct and sub-tier suppliers working within Dell Technologies’ supply chain, including suppliers’ workers, contractors, agents, and independent contractors, and sub-tier suppliers working within Suppliers’ supply chain (“Supplier(s)”).

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Suppliers Principles, p2 - "child labor is prohibited in all tiers of the supply chain."

all forms of forced labour prohibited at any tier of the supply chain, as well as recruitment fees

 

The Responsible Business Alliance Code of Conduct also includes provisions on forced labor and child labor (p.2), recruitment fees (p.3), wages and freedom of association (p.4).

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CAP toolkits designed by Dell especially help in addressing modern slavery risks relating to migrant workers.

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p.1,3,5,6

"The RBA Code, amongst other Dell policies, is incorporated into Dell’s Supplier Principles, to which all Suppliers are expected to agree as a condition of doing business with Dell. Dell considers each Supplier's conduct vis-a-vis the RBA Code and Supplier’s adherence to Dell’s Supplier Principles when awarding and/or renewing business with the Supplier. Dell adheres to the RBA Code and requires its Suppliers to adhere to Dell’s Supplier Principles, with the understanding that the obligations imposed may be more onerous than under applicable local law."

"Dell has published policies to define our commitment to international labor and human rights standards. These principles reinforce and strengthen our commitment to the rights of our employees, workers in our supply chain, and workers in the global community. Our policies, including the Dell Human Rights Policy, and other policies and principles referenced in this statement are available online on our Supply Chain Responsible Labor and ESG Policies, Positions & Guidelines pages."

"SUPPLIER CERTIFICATION: Compliance with Dell's Supplier Principles, which includes the Dell Vulnerable Worker Policy, is a contractual obligation for Suppliers. These Principles include requirements to directly address risks of forced labor and human trafficking. Compliance with these requirements is evaluated through the mechanisms referenced above. Suppliers are required to conduct a root cause analysis and develop a plan to address issues found during an audit within RBA-specified timelines, including findings associated with forced labor conditions."

"Suppliers need to understand their responsibility to effectively manage agents as well as bear the full cost of the recruitment process (i.e., at no point to have recruitment fees for workers). Suppliers cannot delegate the ownership and responsibility of implementing the 'no recruitment fees' policy to labor agents, even as individual tasks are delegated. This applies for the full journey of the worker from home country to final factory. If employees are found to have been paying recruitment fees to their employer or a third-party labor broker, Dell will work with Suppliers to repay the workers."

"Dell Technologies team members are required to complete annual Code training and adhere to our Code and standards, including adherence to the RBA Code, which sets out required protections against forced, bonded, or indentured labor, human trafficking and more."

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Since the company mentions suppliers and suppliers' suppliers are collectively suppliers. It has been considered that suppliers include beyond tier 1 suppliers.

pg. 1

"Dell Technologies Inc., on behalf of itself, Dell Inc. and its direct or indirect subsidiaries (“Dell”), is committed to social and environmental responsibility. As part of its commitment, Dell prohibits slavery and human trafficking in our operations and supply chain and works to minimize any associated risks. Irrespective of the circumstances, we will not tolerate forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons in any of our own business operations or by any of Dell’s suppliers, our supplier’s suppliers (collectively, “Suppliers”), or for any other purpose."