No specific incident/CAP available

CAP mentioned in the statement and detailed on p.67 of the ESG report

Page 5:

"Any allegations of modern slavery or modern slavery risks received through these mechanisms are fully investigated immediately by Dell. Methods to research allegations include unannounced visits by our social and environmental responsibility (SER) specialists and/or third-party auditors. Depending on the nature of any findings, SER specialists work with Suppliers to develop corrective action plans to address modern slavery risks and/or remediate instances of modern slavery. In cases of severe (priority and/or major) findings, Suppliers may be required to complete a third-party closure audit to resolve the issue."

p.5,6

"Any allegations of modern slavery or modern slavery risks received through these mechanisms are fully investigated immediately by Dell. Methods to research allegations include unannounced visits by our social and environmental responsibility (SER) specialists and/or third-party auditors. Depending on the nature of any findings, SER specialists work with Suppliers to develop corrective action plans to address modern slavery risks and/or remediate instances of modern slavery. In cases of severe (priority and/or major) findings, Suppliers may be required to complete a third-party closure audit to resolve the issue."

"Where recruitment fees either to the Supplier or a labor broker have been used, we work with Suppliers to return recruitment fees and pay direct remedies to affected workers."

"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."

"Progress in addressing these issues is regularly reported across Dell's procurement organization through monthly reports, executive visibility, and quarterly business reviews with Suppliers. Closure audits are conducted to confirm priority and major findings have been resolved. Dell reserves the right to take any and all available actions against Suppliers for violations of Dell’s Vulnerable Worker Policy, including without limitation the reduction of business, frequent required onsite compliance auditing at Supplier's expense (including but not limited to dormitories, canteens, storage, and common areas), employee compensation at Supplier's expense, and/or termination of Dell's contract with the Supplier."