Responsible Supply Chain

AT&T is committed to conducting business with the highest ethical standards and integrity, with an emphasis on corporate responsibility and sustainability. Our suppliers are held accountable to the same high ethical, environmental, social and governance standards.

Key Performance Indicators (KPI)

Suppliers are a key part of our business and therefore must be part of our approach to sustainability and diversity. We have suppliers around the world (in non-embargoed countries) representing all types of trades, engaged across all our operating units. Our AT&T Communications unit works with more than 20,000 suppliers globally. This reach allows AT&T the opportunity to streamline operations, reduce long-term costs and limit overall environmental impact.

AT&T proactively works with our suppliers to advance sustainable business practices throughout our supply chain, focusing on energy use, climate impact, human rights, water use, waste and natural resource use. We are committed to promoting healthy, safe and inclusive working conditions throughout our supply chain, and we continue to increase the engagement of minority-, woman-, veteran-, LGBTQ+- and disability-owned business enterprises. We also encourage subcontracting opportunities for these businesses by requiring supplier diversity participation from our prime suppliers.

As part of our work to advance sustainability in our supply chain, we set a science-based target to ensure that 50% of our spend – covering purchased goods and services, capital goods, and downstream leased assets – is with suppliers who set their own science-based Scope 1 and Scope 2 greenhouse gas emissions (GHG) targets by 2024. We work with suppliers individually to help set their targets. Through the end of 2021, 47% of suppliers by spend have set a science-based GHG target.

To support small, minority-owned and woman-owned businesses affected by the COVID-19 pandemic, AT&T Supplier Diversity worked with regional diverse business organizations to provide grants covering fees for diverse supplier certification – a necessary step that businesses must take to work with corporations and other businesses seeking diversity in their supplier relationships. In 2021, we also hosted a training for our top-spend suppliers that emphasized the importance of using reporting and sustainability disclosures to reduce the environmental impact of their operations.

Our Global Connections and Supply Chain (GCSC) organization manages the supply chain of our AT&T Communications and AT&T International operating companies, representing the largest and most complex portion of AT&T’s supply chain. Because of the scale of this work, this issue brief reflects the efforts of GCSC unless otherwise noted. Supplier diversity ⁴ and supplier sustainability metrics represent the effort of our entire U.S. operations. GCSC has centralized the management of high-risk suppliers representing certain high-risk factors and optimized reverse logistics strategy and operations.

Top managerial responsibility for supply chain management lies with the Executive Vice President – GCSC, who is a member of the Corporate Social Responsibility Governance Council. The council is led by our Chief Sustainability Officer, with oversight from the Governance and Policy Committee of the AT&T Board of Directors.

In 2020, we implemented our Preferred Supplier program to recognize suppliers that demonstrate a commitment to diversity and sustainability and prioritize those companies in our sourcing decisions. Suppliers are reviewed on multiple criteria, such as reported diversity and inclusion data and participation in third-party sustainability assessments.

Supplier Engagement in Sustainability

AT&T holds our suppliers to high ethical, environmental, social and governance standards, and we regularly engage them in sustainability through a range of policies and programs.

Supply Chain Due Diligence

The AT&T supplier due diligence process focuses on vetting suppliers prior to contract execution and thereafter monitoring to ensure that AT&T is not conducting business with entities that pose risks to its operations, brand or reputation. We use a variety of approaches – including online and subscription resources – to assist in assessing and monitoring our suppliers for indications of financial, security and other risks. During our initial engagement process, suppliers complete an onboarding questionnaire. We deploy applicable risk mitigation, such as contract language and other controls, based on their responses and the presence of any high-risk indicators. We also perform business- and risk-specific compliance monitoring, as appropriate.

We also have a screening process for restricted parties that identifies potential sustainability risks in the supply chain. This program screens customers, suppliers and other trading partners against hundreds of restricted-party lists from governments worldwide. Additionally, our procurement systems and contracting processes include the use of a high-risk activities questionnaire that identifies which contract clauses are required to mitigate high-risk engagements.

The AT&T Risk Management organization is responsible for preserving our assets and shareowner value by minimizing the financial effects of accidental losses, including activities related to the AT&T supply chain. Risk Management is responsible for establishing insurance requirements for contractors/vendors and reviewing insurance clauses within contracts.

Contracting

GCSC’s agreements contractually compel suppliers to conduct business with respect for corporate citizenship, sustainability supplier diversity, and human rights and to conduct their business operations in a manner consistent with AT&T’s corporate social responsibility (CSR) practices. AT&T expects suppliers to adhere to high social standards, reduce the environmental impact of their products and services, support energy efficiencies, and respond to AT&T’s sustainability-related information requests.

Principles of Conduct for Suppliers

We outline our expectations for suppliers on a variety of issues in our AT&T Principles of Conduct for Suppliers (Supplier Principles), which align to international standards, such as the International Labour Organization, for topics such as freedom of association, collective bargaining, forced labor, child labor and discrimination. The Supplier Principles encompass all environmental, social and governance (ESG) considerations, including the following:

• Sustainable business practices
• Environment, health and safety
• Supplier diversity
• Ethics
• Freedom of association
• Conflict minerals
• Labor Practices
• Human rights
• Circular economy
• Conflicts of interest
• Company property and resources
• Confidential information and privacy

AT&T suppliers should hold their subcontractors to the Supplier Principles, and we require all suppliers and subcontractors to comply with all applicable laws and regulations, both domestic and foreign. If a supplier has questions about the Supplier Principles, senior sourcing managers engage the AT&T Supply Chain Sustainability Office to consult with the supplier.

AT&T also expects suppliers to demonstrate robust environmental, health and safety (EHS) policies and practices. Suppliers should provide a safe and healthy workplace that meets international and national standards, laws, rules and regulations, and they should share appropriate health and safety information and training with their employees. We expect suppliers to minimize the impact of emergency events by proactively developing business continuity plans and response procedures.

Suppliers must verify that they follow the Supplier Principles through a supplier self-attestation process every 18 to 24 months. To ensure compliance with the Supplier Principles, we also survey a subset of suppliers based on their risk level, which is determined by reviewing their response to a high-risk activities questionnaire completed by our sourcing managers in cooperation with the respective AT&T department(s). The suppliers’ risk levels also determine the frequency with which we conduct the surveys.

Please refer to the AT&T Principles of Conduct for Suppliers for the latest information on these expectations.

Strategic Supplier Sustainability Assessments

We engage our strategic suppliers, representing 80% of our spend, in sustainability assessments on 1- to 3-year cycles. Through these assessments, in conjunction with supplier evaluations, we continue to meet our 2025 goal to integrate sustainability performance metrics into sourcing decisions for 80% of our spend.³

We evaluate our suppliers against scores in TIA Sustainability Assessor reports developed with the Telecommunications Industry Association (TIA). The TIA Sustainability Assessor and associated reports enable telecommunications industry suppliers to continuously improve sustainable best practices with:

• A 10-factor model that provides structure for users
• Several business segment options that refine appropriate questions
• Individual reports with a prioritized set of recommendations to optimize sustainability programs
• Support for sustainability planning aligned with the organizaton's strategy
• Shifted emphasis from compliance to excellence
• Benchmark data against others in industry

Suppliers completing the TIA Sustainability Assessor are requested to respond to questions regarding their policies and management practices:

Suppliers receive a report with an overall performance band – gold, silver, bronze or below bronze – along with a numerical score that gives insight into their performance level as well as their proximity to the next-level performance band. AT&T has visibility into suppliers’ scoring progress. Even if a supplier stays in the same performance band, we work with them to review actionable items and discuss improvement plans. Since 2017, more than 340 of our suppliers have completed the assessor tool. In 2021, TIA/QuEST Forum recognized AT&T with its “340 Club” award for exceptional membership participation and our employees’ engagement in multiple workgroups, sub-teams and regions.

Corporate Social Responsibility (CSR) Audits & Assessments

AT&T is a member of the Joint Audit Cooperation (JAC), an organization that facilitates collaboration among peer telecom companies and information and communication technology suppliers to verify and audit supply chains on areas such as labor practices, human rights, health and safety, ethics, and the environment.

We regularly engage our suppliers’ employees through our membership in JAC. If we learn a supplier may be at risk of noncompliance with social responsibility standards, JAC conducts on-site CSR audits by recognized, independent auditors at suppliers’ manufacturing and assembly facilities using a common audit framework. In addition, AT&T uses Mobile Worker Surveys (MWS) to supplement on-site factory audits. MWS is a mobile platform survey, enabling two-way communication directly between auditors and factory workers without management intervention. This survey drives to increase insight and visibility into potential human rights issues that would otherwise go unreported.

Through our JAC membership, CSR audits are conducted by recognized, independent auditors at suppliers’ manufacturing facilities using a common audit framework. On-site audit methodology is defined by JAC members based on SA 8000 and ISO 14001 standards. JAC members share supplier audit results, which promotes continuous improvement while reducing supplier audit fatigue. Due to the ongoing COVID-19 pandemic, in 2021 AT&T and other JAC members were again unable to audit as many facilities as in previous years. In 2021, JAC audited 71 factory locations, including 8 AT&T suppliers, 4 AT&T-led third-party audits and Mobile Worker Surveys of AT&T suppliers’ factory locations, and conducted human rights reviews for more than 107,000 individuals.

The JAC audit framework includes the following:

• Facility evaluation of production areas, office areas, storage facilities, distribution centers and any supplier-provided employee dormitories.
• Management interviews of production, EHS, quality, human resources and payroll manager(s).
• Confidential worker interviews of permanent, temporary and subcontracted labor across various departments and shifts.
• Review of relevant company documents necessary to understand whether the supplier is conforming to common CSR principles and standards. This may include personnel records, proof-of-age documentation, timesheets, payroll records, environmental permits, emergency response plans, and health and safety training documentation and certifications.

The 10 main areas of focus, all of which are addressed during the audits, are:

If we become aware of suppliers at risk of noncompliance with CSR standards, we engage the supplier(s) through JAC with on-site CSR audits and corrective action plans. In 2021, JAC identified 402 corrective actions and closed 71% of all open and newly identified corrective actions – including 35% rated as major, 61% rated as minor and 5% flagged for priority.

AT&T also manages supplier risk via the TIA Sustainability Assessor, which asks suppliers to respond to questions on policies and management practices which:

• Prohibit child labor
• Prohibit forced labor
• Protect freedom of association
• Prohibit discrimination
• Prohibit physical coercion and inhumane disciplinary practices
• Ensure health and safety
• Limit the number of working hours
• Address wages and compensation
• Prohibit corruption and bribery

In addition to these audits and surveys, suppliers and their employees can contact AT&T regarding issues, such as social responsibility standards or concerns of noncompliance, at inquiry@attsuppliers.com.

Conflict Minerals

We actively seek to address the human rights issue of conflict minerals from the Democratic Republic of the Congo and surrounding areas through increased transparency in our supply chain. Our Supplier Principles confirm our expectations that the products we sell will not contain conflict minerals that either directly or indirectly finance or benefit armed groups, and we require our suppliers to comply with applicable laws, including any applicable conflict mineral rules. We reserve the right to audit for any known instances of noncompliance. If corrective action is warranted due to noncompliance with our conflict minerals expectations, we work with our suppliers to correct or remedy any identified noncompliance and will suspend or terminate contracts with suppliers that fail to demonstrate a commitment to our Supplier Principles. AT&T has put in place the following ongoing activities to identify potential reporting obligations regarding conflict minerals:

• A comprehensive Conflict Minerals Program that serves as the documented framework in which AT&T performs the steps required to determine the applicability of and compliance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the Securities and Exchange Commission’s (SEC) rules implementing that act (SEC Conflict Minerals Rules)
• A working team that addresses day-to-day activities associated with complying with the SEC Conflict Minerals Rules
• A governance committee that reviews and provides general guidance on conflict minerals compliance activities

We have taken the necessary steps to determine the extent to which we may have reporting obligations under the SEC Conflict Minerals Rules. The Executive Vice President – GCSC of AT&T Communications has ultimate managerial responsibility for conflict minerals. The GCSC team ensures applicable contracts reference our Supplier Principles and our expectation that suppliers do not use conflict minerals in the products they provide to AT&T.

We also support industry efforts to address conflict minerals, such as through our membership in the Global Enabling Sustainability Initiative (GeSI) and our participation in the JAC program. Through continued collaboration with suppliers, we are committed to the responsible sourcing and use of these minerals.

Supplier Diversity

AT&T has been a long-standing leader in supplier diversity by identifying and promoting diverse businesses for contract opportunities as both prime suppliers and subcontractors. We are proud to be one of the first corporations in the U.S. to have a supplier diversity program – launched in 1968 as a response to the civil unrest and economic disparities many diverse businesses were encountering. As we adopt new and emerging technologies critical to our business initiatives, we’ve made targeted efforts to ensure that diverse businesses are part of that transformation. Our supplier diversity program is also instrumental in helping prime suppliers increase the use of minority-, woman-, veteran-, LGBTQ+- and disability-owned businesses in their supply chain for subcontracting opportunities.

AT&T Supplier Diversity connects certified diverse minority-, woman-, veteran-, LGBTQ+- and disability-owned business enterprises with opportunities to provide products and services to AT&T around the world. We believe diverse suppliers bring value to our company through their unique skills and innovative ideas. Their efforts help us deliver products and services to meet our customers’ diverse needs.

Our annual goal is to exceed $10 billion in total procurement expenditures with minority-, women-, veteran-, LGBTQ+- and disability-owned business enterprises. Suppliers must obtain third-party certification by an approved organization or agency to participate in the supplier diversity program. In 2021, 100% of AT&T diverse suppliers were externally certified by third-party agencies.

We have spent nearly $4 billion with Black-owned suppliers in 2021, adding new Black suppliers while increasing spend with others. Black suppliers support AT&T across different lines of business including legal and professional services, warehousing, logistics, advertising and marketing services, fuel, construction and engineering, property management, and fiber installation. Many helped us get through COVID-19 by keeping our supply chain resilient, ensuring a reliable fuel supply for our fleets and even distributing pandemic-related supplies to our global workforce to keep our employees safe. Going forward, we will maintain our focus on an inclusive supply chain that recognizes the value Black-owned and other diverse suppliers bring to AT&T.

Our supplier diversity program managers are dedicated to working with our sourcing teams and departments to identify areas of opportunity and include diverse businesses in competitive bids. We are committed to identifying, considering and mentoring diverse suppliers throughout the sourcing process while also creating business development initiatives, including business education opportunities. Our program, which is structured around both internal and external initiatives, is guided by 4 areas of focus:

1. Strategic supplier outreach: We interview prospective suppliers at regional and national supplier diversity events and share important information and criteria about doing business with AT&T. We work with several diversity business organizations for targeted supplier identification such as the National Minority Supplier Diversity Council and Women’s Business Enterprise National Council. AT&T is also a founding member of the Billion Dollar Roundtable, a small group of corporations that regularly achieve at least $1 billion annual spend with diverse businesses. In 2021, AT&T Communications vetted and provided feedback to over 900 diverse suppliers and sponsored or participated in roughly 100 virtual supplier diversity outreach events.
2. Diverse supplier advocacy: We work closely with our sourcing organization, department partners and prime suppliers to identify and influence opportunities for consideration and inclusion of diverse suppliers.
3. Engaging our prime suppliers: We work with our prime suppliers to maximize use of diverse suppliers as subcontractors. Key to this effort are our requirements that prime suppliers provide an annual plan outlining their proposed use of diverse suppliers and report their diversity subcontracting spend monthly.
4. Business development and education: We provide opportunities for diverse suppliers to participate in executive education and training programs through the sponsorship of formal mentoring and business development programs. We also host and participate in workshops, seminars and 1-on-1 counseling sessions.

Supplier Diversity Programming

Our supplier diversity team conducts comprehensive outreach to connect diverse businesses across the U.S. with supply chain opportunities at AT&T. We partner with business organizations, chambers of commerce and other groups that provide business development, certification and advocacy support.

To expand our measurement of AT&T Supplier Diversity impact beyond spend, we collect diversity and inclusion metrics from our suppliers to determine their workforce ethnic and gender diversity. These metrics are now a factor in our Preferred Supplier designation and are incorporated into sourcing decisions. Our goal is to drive accountability by rewarding suppliers who demonstrate strong diversity and inclusion values, which enables us to make a positive impact on the economic growth of diverse communities.

We encourage our prime suppliers to engage minority-, woman-, veteran-, LGBTQ+- and disability-owned businesses throughout our value chain in both overall spend and the number of contracts awarded to diverse subcontractors. The Prime Supplier Program aims to help prime suppliers create meaningful diverse supplier subcontract goals and provide quarterly reports. Our team conducts monthly reviews and, when necessary, develops action plans to ensure goal attainment.

AT&T also provides educational support, offering scholarships to diverse business executives/senior leaders, and financial support. Our supplier financing programs allow small, diverse businesses to leverage the credit power ranking/rating of AT&T. Our suppliers benefit by freeing up additional cash flow at a low interest rate that many are not eligible to receive at their financial institutions. In 2021, participants in our supplier financing program included 35 certified women-owned business enterprises, 41 certified minority business enterprises and 7 certified disabled-veteran enterprises. Additionally, AT&T Supplier Diversity sponsors the Business Growth Acceleration Program (BGAP), a signature diverse supplier mentoring program that helps diverse-owned businesses thrive in today’s market. To learn more about our supplier diversity programs, visit the AT&T Supplier Diversity website.

Industry Collaboration

We collaborate with peers in the industry and across our supply chain to develop more efficient products and practices. Examples of our engagement include:

• Telecommunications Industry Association (TIA)-QuEST Forum: We helped to lead the sustainability working group advancing the evolution and use of the TIA Sustainability Assessor and the sharing of best practices. We contributed to monthly working group conference calls that included presentations by member companies sharing best practices. For more information, visit the QuEST Forum Sustainability Initiative and TIA Sustainability websites.
• Joint Audit Cooperation (JAC): AT&T is a member of JAC, an organization that facilitates collaboration among peer telecom companies.
• Sustainable Purchasing Leadership Council (SPLC): AT&T is an active member of SPLC, which evaluates sustainable purchasing standards and tools in the market and publishes sustainable purchasing guidance for conducting RFx evaluations. These guidance documents are increasingly used to inform our RFx initiatives.
• CDP: Working with CDP’s supply chain program, 202 of our suppliers reported their greenhouse gas (GHG) emissions in 2021. We gather and analyze data on these suppliers’ emissions reduction goals and progress. See more information on how we manage our Scope 3 emissions at the CDP Supply Chain website and in our Greenhouse Gas Emissions issue brief.
• Global Enabling Sustainability Initiative (GeSI): As a GeSI board member and leader of the Climate Change Committee, AT&T works with industry peers and suppliers to improve performance across the value chain and drive achievement of the United Nations’ Sustainable Development Goals.

Supply Chain Recognition

In 2021, our supplier diversity program received the following awards:

• DiversityInc, Top Corporations Supplier Diversity (Ranked #4)
• Women’s Business Enterprise National Council, America’s Top Corporation for Women Businesses
• Board of Public Utilities Supplier Diversity Development Council, COVID-19 Responder Award 2021
• Georgia Minority Supplier Development Council, Corporation of the Year
• Florida State Minority Supplier Development Council, Corporation of the Year
• Dallas Fort Worth Minority Development Council, Corporation of the Year
• Georgia Women’s Business Council, Top Corporation for Women Owned Businesses
• Dallas Fort Worth Minority Development Council, Buy Those That Buy Us Award