Setting purpose

The company’s stated purpose, as the expression of the  means by which a business proposes solutions to economic,  environmental and social issues. Corporate purpose should create value for all stakeholders, including shareholders.

At Dell Technologies our purpose is to create technologies that drive human progress.

Our commitment to advance sustainability, drive diversity, equity and inclusion, transform lives through digital inclusion initiatives and uphold trust is core to who we are and how we deliver technology that drives business and society forward.

Our environmental, social and governance strategy is how we turn this commitment into action, holding ourselves accountable to drive greater impact for business, people and the planet.

Dell Technologies Code of Conduct

Corporate Governance Principles

Governance body composition

Composition of the highest governance body and its committees by: competencies relating to economic, environmental and social topics; executive or non-executive; independence; tenure on the governance body; number of each individual’s other significant positions and commitments, and the nature of the commitments; gender; membership of under-represented social groups; stakeholder representation.

Board of Directors

Committee Composition

FY23 Proxy Statement, Page 15-22

GRI 2-9 (2021 Standards) and

GRI 405-1a (2016 Standards)

Material issues impacting stakeholders

A list of the topics that are material to key stakeholders and the company, how the topics were identified and how the stakeholders were engaged.

We've identified the following as ESG materiality issues (in alphabetical order). "ESG materiality" references in this section should not be construed as a characterization regarding the materiality of such information to our business or financial results or for purposes of U.S. securities or other applicable law. Any references of "materiality" in this section refers to such term in the context of ESG reporting and strategy. The following are considered ESG materiality issues:

• Business Ethics
• Community Investment 
• Corporate Governance 
• Data Privacy & Security 
• Diversity, Equity & Inclusion 
• Economic Performance Innovation 
• Energy & Climate 
• Human Rights 
• Labor Engagement & Development 
• Occupational Health & Safety 
• Product Quality & Safety 
• Product Stewardship 
• Regulatory Compliance 
• Substances of Concern 
• Supply Chain Resilience 
• Sustainable Consumption 
• Water & Effluents

For more information about our approach to materiality and stakeholder engagement, see the Stakeholder Engagement and ESG materiality section on page 17 of our FY23 ESG Report

GRI 2-12 (2021 Standards),

GRI 2-29 (2021 Standards),

and GRI 3-2 (2021 Standards)

Anti-corruption

1. Total percentage of governance body members, employees and business partners who have received training on the organization’s anti-corruption policies and procedures, broken down by region.

a) Total number and nature of incidents of corruption confirmed during the current year, but related to previous years; and 

b) Total number and nature of incidents of corruption confirmed during the current year, related to this year.

2. Discussion of initiatives and stakeholder engagement to improve the broader operating environment and culture, in order to combat corruption.

1. 100% of our employees have received training on anti-corruption. Dell has a robust Anti-Corruption program which includes regular and impactful training and awareness, a thorough and comprehensive investigation process, digital controls and use of predictive digital analytics (including with respect to third parties).

 2. a and b. Aside from those we are obligated to report by law, reporting these numbers would violate attorney/client privilege and would amount to a voluntary self-disclosure, a decision currently reserved for Dell's General Counsel. In addition, this has the possibility of disadvantaging those companies that do thorough investigations and predictive analytics, and therefore know more. 

Refer to page 8 of our Dell Technologies Code of Conduct

GRI 205-2 (2016 Standards) and 

GRI 205-3 (2016 Standards)

Protected ethics advice and reporting mechanisms

A description of internal and external mechanisms for:

1. Seeking advice about ethical and lawful behaviour and  organizational integrity; and

2. Reporting concerns about unethical or unlawful behaviour and lack of organizational integrity.

Internal and External Mechanisms: 

The Ethics Helpline is a service where employees, partners, stakeholders and customers can ask questions either via phone call or online web form in multiple languages. It is confidential, operated by NAVEX and is available around the world 24x7. 

The Ethics@Dell.com mailbox is also available to employees, partners, stakeholders and customers to ask questions. This mailbox is actively managed by the Dell Global Ethics and Compliance team. 

Additional Internal Mechanism: 

Employees are also encouraged to reach out to their manager and/or HR when seeking advice about ethical and lawful behavior. 

Refer also to pages 6, and 54-58 of our Code of Conduct

Integrating risk and opportunity into business process

Company risk factor and opportunity disclosures that clearly  identify the principal material risks and opportunities facing the  company specifically (as opposed to generic sector risks), the  company appetite in respect of these risks, how these risks and  opportunities have moved over time and the response to those  changes. These opportunities and risks should integrate material  economic, environmental and social issues, including climate  change and data stewardship.

Pages 19-31, FY23 Form 10-K 

Refer also to section C2, CDP Climate Change Questionnaire.Our 2023 questionnaire will be available in late 2023. Until then, our 2022 response is available here

CDP

Greenhouse gas (GHG) emissions

For all relevant greenhouse gases (e.g. carbon dioxide, methane, nitrous oxide, F-gases etc.), report in metric tonnes of carbon dioxide equivalent (tCO2e) GHG Protocol Scope 1 and Scope 2 emissions.

Estimate and report material upstream and downstream (GHG Protocol Scope 3) emissions where appropriate.

TCFD implementation

Fully implement the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). If necessary, disclose a timeline of at most three years for full implementation. Disclose whether you have set, or have committed to set, GHG emissions targets that are in line with the goals of the Paris Agreement – to limit global warming to well below 2°C above pre-industrial levels and pursue efforts to limit warming to 1.5°C – and to achieve net-zero emissions before 2050.

We are in the process of adopting the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) in our climate change-related reporting. For details on our ESG governance, see the ESG Governance section in our FY23 ESG Report

We have carried out a scenario analysis in alignment with TCFD’s guidance, which  is detailed in our CDP Climate Change Questionnaire, section C3.1b. 

Recommendations of the TCFD;  CDSB R01, R02, R03, R04 and R06; Science Based Targets initiative

Water consumption and withdrawal in water‑stressed areas

Report for operations where material: megalitres of water withdrawn, megalitres of water consumed and the percentage of each in regions with high or extremely high baseline water stress, according to WRI Aqueduct water risk atlas tool.

Estimate and report the same information for the full value chain (upstream and downstream) where appropriate.

See Section W1.2d in our CDP Water Security Questionnaire 

Our 2023 response will be available in late 2023. Until then, our 2022 response is available.

CDP

SASB CG-HP-140a.1, and WRI aqueduct water risk atlas tool

Diversity and inclusion (%)

Percentage of employees per employee category, by age group, gender and other indicators of diversity (e.g. ethnicity).

Pay equality (%)

Ratio of the basic salary and remuneration for each employee category by significant locations of operation for priority areas of equality: women to men, minor to major ethnic groups, and other relevant equality areas.

Dell treats this data as confidential company information. However, at the links provided, we describe our approach to avoiding discrimination and promoting equality.

Code of Conduct (page 18)

FY23 ESG Report

Wage level (%)

1. Ratios of standard entry level wage by gender compared to local minimum wage.

2. Ratio of the annual total compensation of the CEO to the median of the annual total compensation of all its employees, except the CEO.

1. Dell treats this data as confidential company information.

2. Please see our FY23 Proxy Statement, page 58, for our ratio of the annual total compensation of the CEO to the median of the annual total compensation of all its employees. 

GRI 202-1 (2016 Standards),

Adapted from Dodd-Frank Act, US SEC Regulations

Risk for incidents of child, forced or compulsory labour

An explanation of the operations and suppliers considered to have significant risk for incidents of child labour, forced or compulsory labour. Such risks could emerge in relation to: 

a) type of operation (such as manufacturing plant) and type of supplier; and

b) countries or geographic areas with operations and suppliers considered at risk.

Refer to disclosures GRI 408-1 (b), GRI 409 in our GRI Index

GRI 408-1b (2016 Standards) and

GRI 409-1a (2016 Standards)

Health and safety (%)

1. The number and rate of fatalities as a result of work-related injury; high-consequence work-related injuries (excluding fatalities); recordable work-related injuries; main types of work-related injury; and the number of hours worked. 

2. An explanation of how the organization facilitates workers’ access to non-occupational medical and healthcare services, and the scope of access provided for employees and workers.

Number of fatalities: 0 

Rate of fatalities: 0

Number of high-consequence work-related injuries:0

Rate of high-consequence work-related injuries: 0

Number of recordable work-related injuries: confidential business information

Rate of recordable work-related injuries: 0.04 (Cases based on 100 full-time employees (FTEs)

Most work-related injuries are strains and sprains associated with material handling, and fractures, contusions and lacerations from slips, trips and falls.

Number of hours worked: confidential business information

Rates calculated based on 200,000 hours worked

GRI Index

Training provided

Average hours of training per person that the organization’s employees have undertaken during the reporting period, by gender and employee category (total number of hours of training provided to employees divided by the number of employees).

Refer to disclosure GRI 404-1 in our GRI Index

GRI 404-1 (2016 Standards) and SASB HC 101-15

Absolute number and rate of employment

Total number and rate of new employee hires during the reporting period, by age group, gender, other indicators of diversity and region.

Total number and rate of employee turnover during the reporting period, by age group, gender, other indicators of diversity and region.

Economic contribution

1. Direct economic value generated and distributed (EVG&D), on an accruals basis, covering the basic components for the organization’s global operations, ideally split out by:

• Revenues
• Operating costs
• Employee wages and benefits
• Payments to providers of capital
• Payments to government
• Community investment

2. Financial assistance received from the government: total monetary value of financial assistance received by the organization from any government during the reporting period

1. Page 49, FY23 Form 10-K 

2. Page 151, FY23 Form 10-K

GRI 201-1 (2016 Standards) and

GRI 201-4 (2016 Standards)

Financial investment contribution

Total capital expenditures (CapEx) minus depreciation, supported by narrative to describe the company’s investment strategy. 

Share buybacks plus dividend payments, supported by narrative to describe the company’s strategy for returns of capital to shareholders.

1. Pages 60 and 79, FY23 Form 10-K 

2. As part our overall capital allocation strategy, we intend to drive growth while maintaining our investment grade rating and focusing on returning capital to our shareholders through both share repurchase programs and dividend payments. Refer to page 64 of our FY23 Form 10-K

Total R&D expenses ($)

Total costs related to research and development.

Total tax paid

The total global tax borne by the company, including corporate income taxes, property taxes, non-creditable VAT and other sales taxes, employer-paid payroll taxes, and other taxes that constitute costs to the company, by category of taxes.

Adapted from GRI 

201-1 (2016 Standards)