Human Rights Policy

Commitment to Human Rights

Corning believes in the fundamental dignity of the Individual, which is one of our core Values. The very foundation of this Value is respect for the rights, freedoms and standards of treatment to which all people are entitled—human rights. .

At Corning, we uphold these rights, regardless of race, gender, nationality, ethnicity, age or other status.? Respect for human rights is practiced the same way we practice our other Values: everyday, as a part of every interaction with each other and those with whom we do business. It is a responsibility we take seriously.

Corning also supports the advancement of human rights through our global efforts to make the world more connected, to expand technology access, and to promote sustainable technological innovations.? We are committed to continuous improvement, valuing the Individual, and being a responsible member of the communities in which we live and work around the globe.

Embedding respect for human rights

The Corporate Responsibility and Sustainability Committee regularly discusses and reviews Corning’s sustainability activities and philosophy and maintains general oversight of environmental and social risks, with particular responsibility for employee welfare and labor relations, social justice, supply chain integrity, human rights, political activity, community responsibility, and environmental matters. Corning’s Senior Vice President of Human Resources has internal oversight over employee and contingent worker human rights matters and relies upon Corning’s global and regional human resources personnel for day-to-day implementation of our programs and policies regarding employee and contingent worker human rights matters worldwide. Corning’s Senior Vice President and Chief Supply Chain Officer oversees the application of our Supplier Code of Conduct and Human Rights Policy with third-party suppliers. The Senior Vice President and Chief Supply Chain Officer also maintains performance objectives, including communicating and implementing our Supplier Code of Conduct, which covers our most salient supply chain human rights risks. ?

We also integrate human rights into our internal management processes, such as our Enterprise Risk Management process, which is reviewed annually by our Audit Committee and is based on material issues regardless of where they are identified within the value chain. Corning also established a??to address?Environmental, Social and Governance (ESG) issues, including human rights issues, in its Enterprise Risk Management process.?For more information on this, please see our most recent and .

The Corning describes the company's business conduct principles, or core values, which set forth global legal and ethical expectations for all members of Corning's workforce and third parties who act on Corning’s behalf. The principles in this Code of Conduct are consistent with Corning’s longstanding business conduct principles, its Values, and our shared ethical standards for conducting business with uncompromising honesty and integrity. We communicate our Code of Conduct to all employees, who are required to complete training to enforce their understanding of the Code of Conduct. Corning employees, including all supervisors, managers, and other leaders, are responsible for knowing and following the ethical, legal, and policy requirements that apply to their jobs and for reporting any suspected violations of law or the Code of Conduct. Executives and managers are trained on supervisor responsibilities related to the Code of Conduct (refer to the Training and Communication section below) and are accountable for creating an inclusive workplace environment that encourages asking questions and raising concerns.

Upholding Corning’s Code of Conduct and Values is also the responsibility of every person acting on Corning’s behalf. Multiple processes are in place to ensure Corning’s principles are being upheld by these parties. For example, we recognize that the choices we make for our material and service providers must also reflect our Values. Accordingly, we require our suppliers to share our commitment to maintaining ethical, compliant, responsible, and sustainable operations and practices. In addition to full compliance with all applicable labor and employment laws, we expect our suppliers to commit to upholding the human rights of workers and treating them with dignity and respect as generally understood by the recognized international community. We communicate these expectations to our suppliers through the Corning Supplier Code of Conduct, which we require all suppliers to follow as a condition of doing business with us. For more details on our approach to supply chain responsibility, see the on our website.

From time-to-time, Corning engages in mergers and acquisitions, adding additional business interests to the company. For each business that may be acquired, human rights issues are considered relative to risk and compliance during the acquisition due diligence and integration processes. A detailed plan to integrate new acquisitions into Corning, and if necessary, bring them into compliance with Corning’s policies and standards, is generally developed within the first 100 days after the acquisition.

Approach to human rights due diligence

In our view, human rights due diligence requires a holistic approach. We assess our own business as well as those who are acting on our behalf—in supply roles and in mergers and acquisitions—to identify salient and applicable human rights issues. Our various internal management and oversight systems and processes—which include, among others, due diligence of high-risk locations; supplier audits and compliance oversight; ongoing health and safety audits within our facilities; regular surveys that employees can complete anonymously to provide feedback; and a secure Code of Conduct hotline that any party can access to raise concerns or express grievances anonymously, if desired—help us identify human rights risks and impacts. Assessments are typically triggered by mergers and acquisitions, new country operations or entries into new markets, new business relationships (such as a new supplier) or changes in the human rights conditions in particular locations.

Our approach to human rights due diligence aligns with our corporate Human Rights Policy and includes these points of review: a safe and healthy workplace; a workplace free from discrimination, harassment, bullying or victimization; freedom of association; and prohibition on and prevention of any use of child labor or forced labor. Our internal team of sustainability experts regularly use a tool to assess risks associated with our own operations and suppliers.?The tool provides enterprise-wide visibility to existing and emerging risks by generating risk scores for suppliers, customers, transportation locations, our own manufacturing locations, and entire supply paths.?The tool also provides risk scores for Tier 2 suppliers and critical industry suppliers.?Each score is comprised of five major factors:?Viability, Delivery, Market/Cost, Image & Compliance, and Quality & Performance. The tool also enables risk prioritization across the enterprise by utilizing these risk scores in combination with internal impact scores.

Based on our assessment process, we have determined salient human rights risks in our various spheres of influence (our own business and in others acting on Corning’s behalf), as well as actions to mitigate these risks, as indicated in the table below.

Sphere of Influence Salient Risk Action Plan to Prevent, Mitigate or Remediate Risk

Workers and local communities in our supply chain

Labor, ethics, health and safety, and environmental risks, as outlined in Corning’s

The sphere with the greatest potential for human rights impact is within our supply chain. Our Supplier Code of Conduct applies to all suppliers, including direct and indirect suppliers, as well as directly contracted and third-party contracted staff performing tasks for Corning. In our most recent fiscal year 2020, 484 nonconformances were identified and addressed.

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Given the significance of this sphere, we have set a 2025 to ensure that 100% of Corning’s high-risk suppliers and contract manufacturers are certified as socially responsible, which includes several human rights related criteria. See our??for more information.

Corning employees and workers in our supply chain

Forced labor and child labor

Across our operations, we pay our employees regularly, in full, and on time. We do not require our employees to pay work-related fees or costs and all employees receive a payslip with their wages and explanations of any legitimate deductions. We do not retain personal documents or restrict our employees’ freedom of movement outside of work hours and we do not require our employees to stay at and pay for accommodations.

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Consistent with applicable law, we also verify the eligibility of job applicants and workers to ensure compliance with their right and legal ability to work in their respective jurisdictions. ???Corning maintains a global HR system that captures key data for all global employees, including birthdate.? The global HR system is foundational and linked to numerous other applications including reporting, payroll and benefit systems around the world.

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Within our supply chain, we provide more information on how we prevent the use of any forced labor and child labor in our supply chain in our Supplier Code of Conduct and . We particularly recognize that the use of recruitment and labor agencies increases the risk of forced labor. Therefore, in addition to ensuring compliance with our Supplier Code of Conduct, we are making progress towards requiring recruitment and labor agencies to take our human rights training, which covers our expectations on the prevention of work-related fees (e.g., recruitment fees) paid by workers and retaining personal documents that may restrict workers’ freedom of movement. ?

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Corning employees

Health and safety

Our vision is to provide an injury-free workplace for every employee, contractor, and visitor. We have set a sustainability goal to continue maintaining our safety metrics in the top quartile of our industry benchmark values. See our??and our??for occupational health and safety.
Corning employees Working hours

We respect applicable international standards and comply with all laws and regulations related to working hours for employees, including ensuring that working hours include the minimum breaks and rest periods set by law. Many of Corning’s manufacturing plants run continuous (24/7) operations and will have either 8-hour or 12-hour shift patterns, or a combination of both, as well as overtime shifts. The standard work week in our manufacturing plants, excluding overtime and exceptional cases, does not exceed 48 hours. Actual shift patterns and duration are based upon production requirements, and hours worked by employees on a week-by-week basis will vary depending upon shifts and scheduling. In all instances, Corning complies with applicable contract terms and legal requirements related to work hours, shifts, overtime, and compensation.

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Corning employees

Non-discrimination

We have set a to ensure that all Corning employees understand Corning’s , which includes a strict prohibition of harassment of any kind, including any action in the workplace that intimidates, insults, offends, or ridicules an employee because of race, color, gender, age, religion, national origin, sexual orientation, gender identity or expression, disability, or veteran status.

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Corning is committed to the advancement and empowerment of women in the workforce, their personal lives, and the communities in which they live. At Corning, we acknowledge, respect, and promote the basic human rights of women to be free from discrimination, violence, poverty and other barriers that can deny equal access to the workplace and the enjoyment of their lives regardless of gender. In furtherance of our commitment to the elimination of discrimination against women, Corning strictly prohibits any harassment, intimidation, and violence against women. As part of this commitment, we follow the Women's Empowerment Principles (WEPs) and are a member of the WEP’s global community to foster business practices that empower women everywhere we operate1. We expect our business partners, including our suppliers, to commit to these (or similar) principles. See our for more information on how we respect the rights of women throughout all levels of employment.

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Corning employees

Freedom of association Corning does not have operations in any countries that prohibit membership in or affiliation with unions or other workers’ associations. Over 70% of Corning employees worldwide are represented by unions or other workers’ associations, and we endeavor to maintain positive and constructive relations with all such worker representative groups wherever we do business.

Corning employees

Fair compensation We are currently in the process of researching and gathering living wage standards and data by country and identifying any gaps in meeting such living wage standards in all countries where we have significant operations (representing over 97% of our in-scope employees).? By the nature of the jobs we provide, we know that Corning provides compensation that always meets, and very often significantly exceeds, minimum wage requirements in all the jurisdictions we operate in.? Our preliminary analysis, starting with the countries where Corning has the greatest number of employees, indicates that Corning also provides compensation that would meet or exceed a higher living wage standard for more than 99% of the 43,000 employees assessed to date. Similar to the annual assessment Corning conducts on pay equity, we intend to develop a repeatable process to assess and monitor our continued progress against evolving living wage standards.

1 While we seek to adhere to the Women’s Empowerment Principles, we are currently not a member of the Women’s?Empowerment Principles network.

Tracking and monitoring actions taken

Each functional area with ownership of a salient human rights risk has the responsibility to monitor the implementation of Corning’s Human Rights Policy and track actions taken to prevent, mediate or remediate the risk through their established management systems. For example, Corning established a sustainability goal that all Corning Incorporated employees will understand Corning’s Code of Conduct, including how to report allegations of ethical or legal misconduct. The Compliance team in the Law Department tracks progress toward this goal through the existing employee survey process. As another example, Global Safety Services tracks health and safety performance through their existing management system and will compare Corning’s performance with our industry benchmark values to ensure that we maintain our safety metrics in the top quartile, our Occupational Safety and Health sustainability goal. Lessons learned within the Global Safety Solutions function are regularly shared throughout Corning operations using multiple methods to include written communications and regularly scheduled meetings. Functional areas are also responsible for improving the ongoing effectiveness of their existing risk management systems based on the successes or challenges that they face in implementing action plans to mitigate the identified human rights risks and impacts.

Training and communication

All employees are required to complete training related to Corning’s Code of Conduct. This training ensures that employees are familiar with the areas covered by Corning’s Code, including ethical and legal obligations toward the protection of human rights. Corning’s training also ensures employees know how to report concerns, including through Corning’s anonymous third-party hotline, if desired. Corning maintains a strong commitment to preventing retaliation against those who report compliance concerns, as set forth in Corning’s . In addition, management personnel within Corning are also required to complete an annual certification attesting that they know and understand the requirements of Corning’s Code of Conduct. Human rights trainings are also provided to specific teams and individuals, such as our supply chain and procurement staff, who are responsible for communicating and implementing Corning's Supplier Code of Conduct with our suppliers. Additionally, we provide our priority suppliers with Supplier Code of Conduct and human rights training. See our .

We use and make available to our stakeholders our sustainability website and sustainability report—published annually and based on recognized reporting standards—to communicate our Code of Conduct, Supplier Code of Conduct, and Human Rights Policy and provide regular updates on how we are making progress on our commitments and how effective we have been in addressing our salient risks and impacts.

Engaging stakeholders

Corning's processes are at the core of our business success. Ensuring those processes reflect our corporate Values and are executed with integrity is how we maintain our position in the global marketplace and maintain the respect of our employees, customers, stakeholders, investors, and suppliers. These processes help to safeguard one of Corning’s most important assets—information—and they help ensure responsible stewardship for our stakeholders. They also help enable Corning’s reputation as an attractive investment opportunity.

Corning is committed to engaging with our stakeholders to understand key topics and gather their feedback on the continuing development of our human rights approach. This ?documents the stakeholder groups, the engagement channels, and the key topics addressed via our engagements.

Raising, addressing, and resolving concerns

We are committed to providing effective remedy where we determine that we have caused or contributed to adverse human rights impacts in our value chain and to using our leverage to encourage our suppliers and partners to provide remedy where we find impacts directly linked to our business operations, goods, or services. When concerns related to human rights, labor practices, environmental, or safety issues arise, our employees and others who are or may become aware of such issues are encouraged to raise questions and report known or suspected misconduct.

We provide a variety of mechanisms for reporting and resolving concerns:

  • Discuss any issues with or report any perceived wrongdoing to your supervisor
  • Talk with your human resources leader or any other manager.
  • Contact the Law Department at (607) 974-0000 and ask to speak to a lawyer about the Code of Conduct and your concerns.
  • Contact the Finance Division at (607) 974-8242 and ask to speak to the Corporate Controller or Treasurer about the Code of Conduct and your concerns.
  • Contact Corning’s Code of Conduct Line at (888) 296-8173 or at . ?These services can be used to make an anonymous report and are available on a 24/7 basis. An outside organization provides these services and your report cannot be traced back to you unless you choose to identify yourself.

Corning prohibits retaliation against anyone who in good faith asks a question, reports a concern, or participates in a company investigation. We also will not obstruct access to judicial or non-judicial mechanisms and will cooperate with such mechanisms should the situation arise. We do not ask affected individuals to waive their legal rights to bring a claim through a judicial process as a condition of participating in our grievance process.

Although timing will vary depending on the complexity of any report, Corning strives to complete all investigations within 90 days and to communicate the outcomes of these investigations to the complainant(s) and other affected stakeholders, if any, through appropriate channels. Depending on the nature of the allegations and issues involved, investigations may be completed by internal Corning resources or escalated to external resources, as determined by Corning’s Chief Compliance Officer.

In calendar year 2021, 62 cases raising human rights issues, in whole or in part, were filed, addressed, and/or resolved. Additional information on our procedures and results can be found in the Code of Conduct, Whistleblower Policy, and . We may receive feedback from our stakeholders, including Corning employees, to help us track and monitor the performance and effectiveness of our Code of Conduct hotline. For example, in the past, we have integrated lessons learned from the feedback received from our employees to improve the accessibility of our grievance mechanism by enhancing the hotline’s phone structure and numbering system to make it more functional and easier to use from any given country or location.

Our Policy

At Corning, we:

  • Respect and support human rights as set out in the ten principles of the UN Global Compact as well as the UN Guiding Principles on Business and Human Rights.
  • Expect our employees and contractors to comply with this policy, in the context and spirit of Corning’s Values and Code of Conduct, and we seek to work with third parties who support our approach and standards.
  • Comply with applicable laws that support human rights wherever we operate. Where our policy goes further than local laws (e.g., Corning’s safety standards), we will operate to our policy. If our policy conflicts with local law, we will follow local law while trying as far as possible to act in accordance with the spirit of our policy.
  • Are committed to respecting the rights of workers, in accordance with the International Labour Organization (ILO) fundamental conventions. This commitment applies to all workers, including temporary, migrant, student, contract, direct employees, or any other worker. We also respect the rights of vulnerable groups particularly relevant to the industry, including women, migrants, and children, in accordance with the ILO fundamental conventions.
  • Respect and support the right of employees to establish, join or not join trade unions or other associations, and we recognize any rights to collective bargaining for represented employees.
  • Do not tolerate or support the use of child labor, forced, or compulsory labor in our operations and in our supply chain.
  • Are committed to providing a fair, safe, and healthy working environment for our employees that is free from unlawful discrimination, harassment, bullying or victimization.
  • Are committed to being an inclusive employer, promoting and valuing diversity within our workforce, among our customers, suppliers and in the communities in which we operate.
  • Care about the way our suppliers do business, and we will work with them to continuously improve. Our Supplier Code of Conduct outlines our expectations in the areas of labor and human rights, as well as health and safety, environment, ethical dealings, and supply chain diversity.
  • Respect the rights of human rights defenders. We do not tolerate unlawful threats, intimidation, or attacks against human rights defenders, including those exercising their legal rights to freedom of expression, association, or peaceful assembly. We expect our suppliers to make a similar commitment.
  • Do not tolerate bribery and corruption in any form. Bribes, pay-offs, facilitation payments, secret, unjustified or inflated commissions, kick-backs and any like payments are strictly prohibited.

Employees who suspect any behavior which is inconsistent with this policy should follow the reporting procedures in Corning’s Code of Conduct. Corning strictly prohibits any form of retaliation for good faith reports, as described in our Code of Conduct and Whistleblower Policy.

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Wendell P. Weeks
Chairman and Chief Executive Officer

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