On 29th September 2021, Ethical Consumer viewed Google's website for the company's supply chain management policy. Its 2020 Supply Responsibility Report was found, which linked to Google’s Supplier Code of Conduct and other information.
Supply chain policy (rudimentary)
A strong policy would include the following commitments: no use of forced labour, permission of freedom of association, payment of a living wage, the restriction of working hours to 48 hours plus 12 overtime (without exception), no use of a child labour (under 15 or 14 if ILO exempt), no discrimination by race, sex or for any other reason.
Google's supply chain policy included adequate clauses on child labour, forced labour, freedom of association and non-discrimination. However the clause on working hours was not considered adequate as it was qualified by "except in emergency or unusual situations." It also did not contain a clause guaranteeing workers' a living wage. Overall Google was considered to have a rudimentary supply chain policy.
Stakeholder engagement (poor)
Ethical Consumer deemed it necessary for companies to demonstrate stakeholder engagement, such as through membership of the Ethical Trade Initiative, Fair Labour Association or Social Accountability International. Companies were also expected to engage with Trade Unions, NGOs and/or not-for-profit organisations which could systematically verify the company's supply chain audits, and for workers to have access to an anonymous complaints system, free of charge and in their own language.
No references could be found to the effect that Google was working with multi-stakeholder organisations or trade unions or NGOs to help verify its labour standards within its supply chain, or had any complaints procedure that workers would be aware of and able to use.
Auditing and reporting (rudimentary)
Ethical Consumer deemed it necessary for companies to have an auditing and reporting system. Results of audits should be publicly reported and quantitatively analysed. The company should have a scheduled and transparent audit plan that applies to their whole supply chain, including some second tier suppliers. The company should also have a staged policy for non-compliance. The costs of the audit should be borne by the company.
Google stated that "We hold suppliers accountable to our Supplier Code of Conduct through a multi-step assessment process, which includes self-assessments, risk assessments, and independent third-party audits." Google provided a table which stated how much non-compliance had been found and the most common reasons for non-conformance. However there wasn't a schedule for audits or commitment to audit the whole supply chain. Overall Google was considered to have a rudimentary approach to auditing and reporting.
Difficult issues (rudimentary)
Ethical Consumer also deemed it necessary for companies to address other difficult issues in their supply chains. This would include ongoing training for agents, or rewards for suppliers, or preference for long term suppliers. It would also include acknowledgement of audit fraud and unannounced audits, and measures taken to address the issue of living wages, particularly among outworkers, and illegal freedom of association.
Google stated in its report "As of December 31, 2019, over 95% of the identified population of Google employees managing relationships with higher-risk suppliers had completed the online training." The online training was said to cover "anti-modern slavery education for workers in roles related to hardware supplier management". This was considered to be addressing a difficult issue.
Google did not appear to be addressing any other difficult issues such as illegal freedom of association found within supply chains. Overall Google was considered to have a rudimentary approach to difficult issues.
Overall Google received Ethical Consumer's middle rating for Supply Chain Management and lost half a mark in this category.