Transparency in Supply Chains Act 2010

Beginning in 2012, many companies manufacturing or selling products in the state of California are required to disclose their efforts to eradicate slavery and human trafficking within their direct supply chain. This disclosure is mandated by the California Transparency in Supply Chains Act of 2010 (Senate Bill 657). The law is designed to increase information available regarding manufacturers and retailers efforts (if any) to address slavery and human trafficking, thereby allowing consumers to make better, more informed choices regarding the products they buy and the companies they choose to support. Slavery can take many forms of forced labor, including child labor. Goodyear through this disclosure is communicating its efforts to address the risk of human trafficking and slavery in its direct material supply chain. Goodyear's efforts include:

Risk-based Assessment

Goodyear performs an assessment of the materials and countries of origin in its raw material supply chain. The baseline for the assessment is the U.S. Department of Labor’s (DoL’s) 2010 report listing “goods from countries” that the Bureau of International Labor Affairs (ILAB) has reason to believe are produced by forced labor, child labor, or both, in violation of international standards. The risk assessment results indicate Goodyear uses a small number of materials listed in the DoL report. Through the Goodyear Supplier Certification (described below), Goodyear is working to mitigate the risks for those sourced materials listed in the DoL report.

Supplier Audits

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 at any time. Goodyear does expect that its suppliers be strictly compliant with local laws.

Supplier Certification

Goodyear has a Goodyear Supplier Code of Conduct (Code) which contains specific language regarding human rights and other workplace issues, as well as the right for Goodyear to perform human trafficking and slavery audits at any time. Beginning January 1, 2012, Goodyear will require its raw material suppliers with materials found on the DoL report to certify to Goodyear’s Code, 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 their own code.

Internal Accountability Standards

Goodyear’s employees, contractors, and suppliers are expected to adhere to the Goodyear Human Rights Policy that includes specific provisions related to forced labor, child labor, and human trafficking. All Goodyear employees must also adhere to the guidelines in the Goodyear Business Conduct Manual, which include disciplinary procedures for any violations.

Procurement Professionals Training

Employees of Goodyear directly responsible for suppliers are provided awareness training on human trafficking, such as forced labor and child labor, and are expected to report any known or suspected violations.