This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Goodyear UK’s slavery and human trafficking statement for the financial year ended 31 December 2021. This statement sets out the steps taken by Goodyear UK to address the risk of modern slavery and human trafficking in its business and supply chain.
STRUCTURE, BUSINESS, AND SUPPLY CHAINS
Goodyear’s Global Business and Supply Chains
Goodyear is one of the world’s largest tyre companies. It manufactures its products in 57 manufacturing facilities in 23 countries and has marketing operations in almost every country around the world. It employs approximately 72,000 full-time and temporary associates worldwide. Its two Innovation Centres in Akron, Ohio and Colmar-Berg, Luxembourg strive to develop state-of-the-art products and services that set the technology and performance standard for the industry. For more information about Goodyear and its products, go to www.goodyear.com/corporate.
Goodyear’s end-to-end supply chain is comprised of suppliers based throughout the world that provide a wide range of products and services related to the development, manufacturing, marketing and distribution of tyres for most applications.
Goodyear UK is a company incorporated in England and Wales. Goodyear’s ultimate parent company is The Goodyear Tire & Rubber Company which, together with its global subsidiaries, is known as Goodyear.
Goodyear’s Global Human Rights Policy applies to the company’s operations and affiliates worldwide, including Goodyear UK, and is part of its commitment to ethical and socially responsible business practices. As stated in the Policy, Goodyear is committed to the following principles:
• Maintaining an inclusive workplace free of unlawful harassment and discrimination;
• Voluntary employment and the prohibition of all forms of compulsory labor and human trafficking;
• Prohibiting the exploitation of children, including child labour;
• Recognizing and respecting the right of associates to join organizations (such as unions) of their choosing, or to refrain from joining organizations;
• Complying with all applicable labor laws and regulations, including those related to wages and hours worked; and
• Providing a safe and secure workplace.
All Goodyear UK employees must adhere to the Goodyear Business Conduct Manual, which incorporates Goodyear’s policies relating to global human rights and provides for disciplinary action in the event of violations. Goodyear strives to do business with reputable suppliers committed to Goodyear’s ethical standards and business practices, including in relation to modern slavery and human trafficking. Goodyear’s Supplier Code of Conduct contains provisions regarding human rights and other workplace issues, as well as the right for Goodyear to perform human trafficking and slavery audits. Goodyear requires certain raw material suppliers to certify to Goodyear’s Supplier Code of Conduct or provide their own code of conduct that Goodyear must review and accept. Goodyear may decline to make future purchases from a supplier that does not certify to the Goodyear Supplier Code of Conduct or does not provide an acceptable version of its own code of conduct. In addition to the principles set forth in the Supplier Code of Conduct, Goodyear expects its suppliers to act in a manner compatible with the standards set out in Goodyear's Natural Rubber Procurement Policy and Soybean Oil Procurement Policy.
DUE DILIGENCE PROCESSES
Supply Chain Due Diligence
Goodyear performs an assessment of the materials and countries of origin in its raw material supply chain to determine which materials come from countries or industries that have a higher risk of having been produced by forced labour, child labour or both, in violation of international standards. Through its Supplier Certification process (below), Goodyear is working to mitigate the risks for these sourced materials.
Goodyear performs periodic supplier audits on an ongoing basis for validation of material quality and supplier conformance to certain regulatory requirements. All suppliers that certify to the Goodyear Supplier Code of Conduct may be subject to human trafficking and slavery audits.
RISK MITIGATION MEASURES
Goodyear’s risk mitigation measures are periodically reviewed to ensure that they are focused on risks identified through its risk assessment and due diligence processes. In the past reporting year, for example, Goodyear has taken steps to enhance its global policy framework in relation to human rights risks as well as its human rights due diligence processes for its direct operations and supply chains.
TRAINING AND AWARENESS
Employees of Goodyear UK who are directly responsible for suppliers are provided with awareness training on forced labour, child labour, and human trafficking risks. In addition, in the past reporting year Goodyear provided dedicated forced labour awareness training to Human Resources, Internal Audit, Procurement, and Law personnel globally, including at Goodyear UK.
All Goodyear and Goodyear UK associates are required to report any actual, suspected, or potential misconduct to management or through the Company’s Integrity Hotline. Available 24 hours a day, 7 days a week from anywhere in the world via toll-free telephone or by a dedicated website, our Integrity Hotline allows associates and third parties to report a concern or ask a question, including anonymously (where allowed by law).
Goodyear measures the effectiveness of its compliance program and progress over time through a number of key performance indicators (KPIs). More details can be found in Goodyear’s Annual Corporate Responsibility Report.
Approved by the Goodyear UK Board of Directors on 13th May 2022.