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Wesco Conflict Minerals Policy

WESCO International, Inc. and its subsidiaries and affiliates, including but not limited to WESCO Distribution, Inc. and Anixter Inc. (collectively, “Wesco”), are committed to being responsible corporate citizens. As part of that commitment, Wesco seeks to source products, components and materials from companies that share our values. Wesco understands the intent of the rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Minerals Rule” or the “Rule”), adopted by the U.S. Securities and Exchange Commission (“SEC”), regarding disclosure of conflict minerals sourced from the Democratic Republic of Congo (“DRC”) and surrounding areas in order to promote ethical sourcing.

The minerals at issue are cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten, and gold (3TG), that originate from the DRC and adjoining countries. Revenue from the mining and transport of these minerals is believed to be financing or benefiting groups that are responsible for human rights violations. Wesco supports industry-wide efforts to identify and reduce the use of conflict minerals originating from the affected countries to the extent believed to be financing or benefiting groups committing human rights violations.

The Rule applies to a public company if conflict minerals are “necessary to the functionality or production” of a product manufactured or contracted to be manufactured by the company. As such, the Conflict Minerals Rule affects Wesco differently in its role as a distributor of products than in its limited role as a manufacturer. Wesco has developed and implemented processes appropriate to each of those roles in the supply chain.

The Conflict Minerals Rule requires certain companies to report annually to the SEC a description of measures taken to exercise due diligence on the source and chain of custody of conflict minerals in the manufacture of its products. Only a small portion of Wesco’s business involves “manufacturing” or “contracting to manufacture,” as those terms are used in the Rule. In order to meet potential SEC reporting requirements for the limited number of products we manufacture or contract with others to manufacturer, Wesco periodically surveys suppliers that provide parts or components for those products to determine if they are using conflict minerals, the origin of any such conflict minerals, and the products in which they are used.

In its role of a distributor of products manufactured by others, Wesco supports its suppliers in their efforts to track conflict minerals in their supply chains and to educate customers about this issue. Suppliers to Wesco are expected to establish their own conflict minerals policies and to cooperate with Wesco in its efforts to identify any conflict minerals in its supply chain.

Compliance with the Conflict Minerals Rule is important to Wesco, and we conduct due diligence within the standards set forth by the Conflict Minerals Rule. We continue to work with Assent, a compliance consulting company, to assist in the periodic collection of the requisite data from our suppliers and to provide our customers with additional information whenever possible.

2021

    Conflict Minerals Policy

Statement of Policy: Environmental sustainability is a strategic priority for WESCO and a company-wide responsibility.  As a global supply chain solutions provider, WESCO is committed to sustainability initiatives and to actively managing the impact of our operations on the environment and the communities we serve.   Beyond managing our own environmental impact, WESCO is also uniquely positioned as a trusted supply chain partner to help our customers and suppliers achieve their own sustainability goals. 

Policy Scope: This policy addresses WESCO’s long-standing commitment to environmental sustainability.  All WESCO locations and employees, both domestic and international, are subject to this policy.

Responsibility Statement: This policy will be managed by WESCO’s Environmental Sustainability Director and VP of Supply Chain and Operations, both of whom will work with business leaders to ensure that environmental sustainability considerations are part of WESCO’s business decision-making process. While this policy will be centrally managed, all WESCO associates have a responsibility to ensure that the environmental impact of their decisions is a consideration in their daily work activities. 

Sustainability Objectives:  WESCO is committed to the following sustainability objectives: 

• To actively manage and reduce energy usage at all branches, Distribution Centers and corporate locations;
• To reduce energy demands across the company through the adoption and implementation of new energy saving and renewable energy technologies where practical and financially feasible;
• To reduce greenhouse gas emissions through improved building energy efficiency, reduced fuel consumption, and investments in renewable energy sources where feasible;
• To evaluate our delivery trucks, fleet vehicles and employee travel on a yearly basis, and where feasible, to replace older vehicles with more fuel efficient vehicles; 
• To work with our employees and waste disposal partners to evaluate and raise awareness of all recycling opportunities in our locations and to  track and measure recycling rates; 
• To build a best-in-class sustainability program by actively engaging our employees and leadership in our environmental sustainability program through communication, training and participation opportunities; 
• To work as a trusted advisor with customers and suppliers to drive sustainability and energy saving measures across the value chain through our product and service offerings;
• To monitor the environmental performance of our supply chain partners since the greatest environmental impact often happens before products are received for distribution to our customers; and 
• To form partnerships with government and non-government organizations that we believe can help us in our sustainability mission and objectives. 

Metrics and Reporting: The following Key Performance Indicators will be used to help evaluate our sustainability performance and to help guide our annual and long-term performance goals: 1 

• Energy:  Overall Total KwH usage, building intensity (Total KWH usage/total Square Footage), and percentage of energy coming from alternate sources
• Transportation: Number of overall trucks and vehicles,  blended miles per gallon of vehicles and trucks, intensity of car fleet relative to overall revenue (number of vehicles/total revenue),  and total employee travel (miles)
• Waste: Tonnage of recycled waste and overall diversion rates

The Company will report the progress of our Environmental Sustainability actions annually as part our Carbon Disclosure Project submissions and bi-annually as part of an overarching Corporate Social Responsibility Report.

    Environmental Sustainability Policy

Statement of Intent:  WESCO supports the need for corporate social responsibility and environmental sustainability across our supply chain. These Sustainable Procurement Guidelines (“Guidelines”) are being implemented to help reduce the impact of our supply chain on the environment and more broadly to help ensure that our suppliers are conducting themselves responsibly. While no supplier will automatically be disqualified based on its current sustainability practices, WESCO intends to work with all suppliers to improve their environmental performance moving forward since we believe there is more value in bettering our supply chain than in simply changing it. That said, WESCO reserves the right to discontinue relationships with any suppliers that are unwilling to partner with us to better our supply chain.

Guidelines Administration: These Guidelines will be administered by our Director of Environmental Sustainability who will work with various internal and external stakeholders in the monitoring, enforcement, and continuous improvement of the Guidelines.

Reporting:  Progress toward implementation of these Guidelines and any associated Key Performance Indicators will be reported as part of our Corporate Social Responsibility report.

Scope: These Guidelines apply to WESCO’s purchases of products and services both for our own direct use in our own operations and for resale to our customers.  All WESCO suppliers, regardless of size, geographic location and product type, are subject to these Guidelines.

Supplier Requirements:  WESCO expects all suppliers to observe the following minimum standards and reserves the right to audit all suppliers’ progress in complying with these standards.  As these Guidelines evolve, WESCO will investigate means to measure suppliers’ sustainability performance and potentially conduct on-site audits, particularly for any suppliers that are deemed to be high risk.

Regulatory and Workplace:

• Conduct business in accordance with WESCO’s Supplier Code of Conduct located here (enter link).
• Abide by all local, national, and international laws.
• Comply with all applicable child labor laws.
• Actively promote a safe and healthy work environment, taking a zero-tolerance approach to harassment and discrimination, while also maintaining fair pay and work hours standards for their employees.

Environmental and Social:

• Actively manage the impact of their operations on the environment and investigate and implement reasonable and financially feasible ideas and projects designed to minimize undesirable environmental impacts.
• Partner with WESCO to explore opportunities to create more environmentally friendly products, services, and packaging.
• Become active members in supporters of the communities that they are located in.
• Develop a supplier diversity program among their supply base and ensure that small, medium, and diverse suppliers have an equal opportunity to participate in sourcing events.

Specific Product Category Requirements on Indirect Materials WESCO Procures for our Operations: Where cost and performance considerations are equal, WESCO will show a preference toward more environmentally friendly products and services.  Specifically, WESCO will observe the following category specific goals:

Electronics: Printers, copiers, faxes, monitors, personal computers, data center technology, and all other electronics should be energy-efficient and have reduced environmental impact in their production.

• All electronics should be ENERGY STAR-certified if certification exists in their product class. ENERGY STAR electronics will reduce our energy consumption, cut energy costs, and help WESCO do its part to reduce greenhouse gas emissions. WESCO is an ENERGY STAR partner, and we support the program’s mission to drive energy efficiency forward. www.energystar.gov
• When possible, all electronics should be EPEAT-compliant, reducing the environmental impact of these products as well as their use of toxic materials. http://www.epeat.net.

Office paper: All office paper should come from more sustainable sources.

• All general copy, fax, and printer paper should be 30% recycled content or higher. Where cost-competitive and job-appropriate, paper should be 100% post-consumer recycled content.
• Where cost-competitive, paper should come from sustainable sources and be certified by the Forest Stewardship Council (FSC).

Packaging: Where cost-competitive, all boxes should use cardboard from recycled sources. All packaging fill should be as sustainable as possible given product safety and cost constraints.

• Packaging fill should minimize the use of styrofoam, plastics, and virgin paper. Fill should come from recycled content, be recyclable, or come from sustainable bio-based sources.
• Warehouses and WESCO Branches should reuse packaging fill from intra-company and customer shipments whenever possible to reduce the purchase of additional packaging materials.

All cleaning supplies must be non-toxic:

• WESCO will work with our cleaning companies to ensure they are using products that are non-toxic and environmentally friendly

    Sustainable Procurement Guidelines

Policy Name: Human Rights Policy

Originator: Human Resources

Approvals: CHRO

Issued Date: September 26 , 2016

POLICY STATEMENT/PURPOSE:

At WESCO, the way we conduct business is as important as the products and services we provide.  In our Company, we are committed to ensuring that all employees are treated with dignity and respect. We comply with all applicable laws, regulations, and other employment standards, wherever we operate or work. WESCO strives to provide all employees a safe, clean, and healthy workplace. WESCO does not tolerate harassment or discrimination and WESCO works to ensure equal opportunity for all employees.

SCOPE:

This policy applies to all employees of WESCO Distribution, Inc. and its subsidiaries. NOTE: If the terms of this Policy, or the measures for discipline hereunder, conflict with the terms and conditions of a collective bargaining agreement, the terms and conditions of the collective bargaining agreement supersede the terms of this Policy

PROCEDURES:

Diversity and Non-Discrimination: WESCO values the diversity of all its employees and does not tolerate discrimination of any kind. WESCO is committed to maintaining a workplace that is free from discrimination. Recruiting, hiring, compensation and advancement are based on qualifications, skills and experience. Every calendar year, WESCO distributes to all locations the “Reaffirmation of the EEO/AAP/Disabled/Veteran Policies” which states that discrimination will not be tolerated.

Harassment Prohibition: All WESCO employees are expected to treat their coworkers and employees of customers with dignity and respect. WESCO will not tolerate harassment of any kind. All complaints or reports of harassment will be investigated confidentially. Each year, WESCO issues to all employees the “Reaffirmation of the Unlawful Harassment Policy” which states that every employee should be treated fairly, with consideration and respect.

Child or Forced Labor: WESCO will not employee anyone younger than the minimum age established by local jurisdiction. WESCO will not allow imprisoned, indentured, bonded, enslaved or any other types of forced labor in its operations. WESCO does not tolerate, engage in or support the use of corporal punishment, threats of violence or other forms of mental or physical coercion.

Working Hours, Wages and Benefits: WESCO compensates employees at a competitive rate compared to the industry and local labor market. WESCO operates in full compliance with applicable wage, work hours, overtime and benefit laws.

Workplace Conditions: WESCO provides working conditions that are safe and healthy to all employees. All employees are entitled to reasonable rest breaks, access to toilets, rest facilities and potable water at their place of work. All employees are provided with appropriate job skills training. WESCO declares that employees receive 24 hours rest within a time frame of 7 consecutive days throughout the entire scope of operations.

Safety in the workplace: WESCO provides a safe and secure environment for all employees. WESCO minimizes employee exposure to potential hazards by identifying risks and developing policies and procedures to minimize the chance of potential hazards happening.

Freedom of Association/Collective Bargaining: WESCO follows all applicable laws regarding employees’ ability to form or join labor unions. WESCO is committed to bargaining in good faith in such instances.

Training: All WESCO employees are required to familiarize themselves with this policy. Managers that are likely to receive reports of policy violation should know to direct employees to their Human Resources Representative.

Disabled Employee Workforce: WESCO employs qualified individuals without regard to physical/mental disabilities that do not affect the employee’s ability to perform the essential functions of the job.  WESCO provides reasonable workplace accommodations for qualified individuals with known disabilities unless doing so would result in an undue hardship to the business.

POLICY GUIDELINES:  All WESCO employees are to follow this policy and the procedures outlined above.  Non-compliance  Any WESCO employee who fails to follow this policy will be subject to disciplinary action, up to and including termination of employment.  

RESPONSIBILITIES:

Employees are responsible for familiarizing themselves with this policy and reporting any violations of this policy to their manager.

Managers are responsible for verifying that their employees are familiar with this policy and follow the procedures outlined above.

The Human Resources Department is responsible for establishing and communicating this policy and policy updates; assuring compliance with all applicable federal and state laws; and providing support to managers or employees as requested to assure compliance with the terms of this policy. 

RESOURCES:  For more information: contact us.

    Human Rights Policy