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“We identify salient human rights risks through our own risk analysis and through the channels we maintain with key stakeholders and partners. These include supplier employee interviews and surveys; consultations with human rights, labor, and environmental industry experts; expert groups we convene on specialized emerging human rights topics; United Nations and U.S. government labor and human rights reporting and consultations; media reports; results of our supplier assessments; discussions with supplier management teams; and incident reports received through our partners around the world” pg. 5

We also continue to expand and strengthen our labor recruitment due diligence for workers recruited domestically. This includes conducting field visits and interviews with labor agencies to see their recruitment processes first-hand, and conducting focused investigations into supplier hiring processes. In FY2021, we conducted 146 audits and investigations, including monitoring job postings and hiring events on social media channels to identify non-compliant practices, such as discriminatory job listings, the illegal hiring of students and interns, and the non-payment of sign-on bonuses. p. 6

Throughout 2020-2021, despite the challanges and travel restrictions due to COVID-19, we were able to have independent, third-party assessments conducted at supplier sites in multiple countries, and the teams verified key documentation, investigated hiring practices, and conducted extensive interviews with workers in local languages. In FY2021, we conducted more than 1,100 assessments, and found no instances where anyone was forced to work in our supply chain. p. 7

We use independent, third-party audits to assess risks at smelter and refiner sites...In CY2021, we removed 12 smelters and refiners from our supply chain, including those that were not willing to participate in or complete a third-party audit, or that did not otherwise meet our requirements p. 8

Assessments, also known as audits, are one of several methods we use to measure compliance with our requirements. Assessments conducted be independent, third-party auditors, provide a snapshor of a suppliers' performance...In FY2021, despite the ongoing challenges presented by the COVID-19 pandemic, we increased the number of supplier employees interviewed as part of the assessment process to 87,626 - a 34 percent increase over 2020. We consider retaliation in any form to be a core violation, and last year more than 42,230 follow-up pone calls were made in order to verify that those supplier employees participating in interviews were not retaliated against. In this reporting period, 1,177 independent, third-party assessments were conducted in 52 countries, including 886 Code of Conduct assessments and 291 smelter and refiner assessments. Every year, we also conduct unannounced assessments and unannounced visits in response to workers' grievances and allegations...In FY2021, we conducted 211 unannounced assessments and investigations where the supplier facility was provided no advance notice of our arrival. p. 9