2021 Owens Corning Sustainability Report | Expanding Our Social Handprint | Human Rights & Ethics | 278 Implementing Our Human Rights Framework We support our human rights commitments through our comprehensive compliance framework, which includes our human rights policy and the supporting policies and documents listed in the previous section. We also have a number of mechanisms in place to ensure that our high standards for integrity are upheld as we do business. ■ Upholding High Standards for Suppliers Owens Corning seeks to partner with businesses that share our commitment to human rights. We expect our suppliers, customers, and other businesses around the world to uphold the principles in our human rights policy. We also expect them to adopt similar policies in their business practices and within their own relationships with subcontractors and others. For all entities that directly provide goods or services to Owens Corning, our Supplier Code of Conduct holds them accountable to applicable laws and principles of ethical business. The code is explicitly consistent with our human rights policy and includes, for example, expectations related to human trafficking and the sourcing of conflict minerals. Our sourcing and supply chain leaders are responsible for managing human rights issues among our suppliers. They use our Supplier Code of Conduct as a reference to select suppliers, measure their performance, train them, and assess risks. We conduct annual human rights assessments via a survey for our key suppliers, which comprise 74% of our sourcing managed spend this year. Over the past three years, 131 suppliers were assessed for impacts on society and labor practices. None of these suppliers were found to have potential of actual significant negative impacts on society, human rights, labor practices, or the environment. ■ Training Employees on Human Rights Training is one of the core tenets of Owens Corning’s compliance program. One hundred percent of our staff employees are trained on and provide written acknowledgement of the Code of Conduct and anti- corruption and anti-bribery policy. Our Code of Conduct and Business Conduct Policies are extensions of our corporate values, which is why we require 100% compliance. To support compliance, the Code of Conduct and Business Conduct Policies are provided to all employees and are available in 16 languages via our internal network. We also expect all our facilities to display materials that highlight our human rights policies. In the case of acquisitions, the integration team will distribute physical copies of the Code of Conduct and Business Conduct Policies to the new plant staff, as they do not have immediate access to Owens Corning online systems. To ensure compliance, internal training is essential. All staff employees are enrolled in the Code of Conduct training course at hire and annually thereafter, are required to certify their compliance, and are given an opportunity to disclose nonconformance. Special attention is given to personnel in key groups such as sales, environmental, safety, and security teams. In addition, managers are expected to lead by example and ensure that these policies are incorporated into the way employees interact each day with customers, colleagues, suppliers, and the public. This year, our 5,695 staff employees, which make up about 28% of our employees worldwide, collectively received 4,218 hours of human rights training. ■ Industrial Relations Owens Corning makes use of a variety of formal and informal processes to address and resolve labor practices at each facility. All labor practice concerns raised by employees are resolved, typically through a peer review or grievance process at the local level. Occasionally, local grievances require additional input at the divisional or corporate level, and if still not resolved, are definitively decided by a neutral arbitrator. Although the company does not compile the number of grievances or complaints filed by employees/ unions at each plant each year, it is not unusual for each facility to resolve dozens of such labor concerns each year. In 2021, we had two labor concerns across Owens Corning’s U.S. operations that required the use of an arbitrator to reach a final disposition (i.e., grievance withdrawn, granted, or settled). In the unfortunate event that one of the above mechanisms of resolution is unsuccessful, an employee may choose to proceed with legal action or file a complaint with a local agency. These are handled through Owens Corning’s legal department following the same guidelines of investigation, remediation, and non-retaliation policies. In considering human rights issues, we have identified women, LGBTQ+, people of color, and other underrepresented populations as vulnerable groups. We have created employee affinity groups within Owens Corning to address the specific risks and needs of these populations — learn more about them in the Inclusion & Diversity chapter .
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