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FY23 10-K

Percentage of products sold that contain IEC 62474 declarable substances (%): 100 

Description of approach to managing the use of substances that appear as declarable substance groups or declarable substances in IEC 62474: 

Dell Technologies Chemical Use Policy describes Dell's approach to managing regulated substances in its products. To implement the policy, Dell's Material Restricted for Use specification lists all substances that our suppliers need to disclose if used in Dell products. Two tables are of particular relevance:

Table 1, which contains substances that are restricted, and 

Table 2, which are the declarable substances. 

This specification is updated at least once a year to include substances based on worldwide regulatory developments. During the review, IEC 62474 is used as a reference in the update process. Dell suppliers must provide declarations (Supplier Declaration of Conformity) on the use of the substances listed in the Materials Restricted for Use specification for any parts supplied to Dell. This declaration confirms that restricted substances are not used in the product, or if used, that the use is exempted (RoHs exemptions). If a substance is designated as reportable to Dell, the supplier would record the use of the substance in the declaration, if the reporting threshold is exceeded. 

Dell Technologies Chemical Use Policy  

Materials Restricted for Use Specification  

EU REACH SVHC Disclosure and Candidate List

Percentage of eligible product models that were registered to EPEAT in FY23:

Consumer Computers: 58%

Commercial Computers: 93%

Displays Commercial & Consumer: 76%

Power Edge Servers: 48%

EPEAT Registry

Percentage of eligible product models that were registered to ENERGY STAR qualified in FY23

Consumer Computers: 97% 

Commercial Computers: 98% 

Displays Commercial and Consumer: 60% Power Edge Servers: 79% 

ENERGY STAR Product Finder

Weight of end-of-life material recovered, in metric tons (t): 95600

Percentage of end-of-life materials recovered and subsequently recycled (%): 88%

Disclose the standard(s) with which the entities you have transferred e-waste to are compliant:

In addition to compliance with many mandatory local, national and international regulatory requirements the following voluntary standards may also be held by our electronics disposition partners:

- R2 Certification by Sustainable Electronics Recycling International (SERI)

- e-Stewards by Basel Action Network (BAN)

- EN50625 by WEEELABEX

Describe your strategic approach to managing risks associated with the use of critical materials in products:

It is Dell’s goal not to purchase product materials containing minerals whose sale directly or indirectly finance armed conflict or contribute to human rights abuses. In those regions where conflict and poor labor practices in mining operations are more prevalent, we are committed to supporting those entities who practice responsible sourcing.

Dell’s mineral due diligence process is designed to align with the five-step due diligence framework set forth in the Organisation for Economic Co-operation and Development’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 3rd Edition (2016)”. We investigate our supply chain and engage with suppliers to ensure responsible mineral sourcing by implementing the following steps of the OECD framework:

Step 1: Establish strong company management system

Step 2: Identify and assess risks in the supply chain

Step 3: Design and implement a strategy to respond to identified risks

Step 4: Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain

Step 5: Report on supply chain due diligence.

This is a complex area where multi-stakeholder collaboration – including shared capacity building initiatives, sub-tier supplier engagement, and data exchange – is essential to effectively mitigate risks associated with mining operations and advance progress. Alignment on ethical sourcing expectations and application of combined leverage is prioritized and pivotal as downstream companies do not directly purchase any materials from smelters, refiners or mines, and many supply chain actors are not legally required to report on mineral due diligence.

Identify critical materials that present a significant risk to your operations, the type of risk(s) they represent, and the strategies used to mitigate risk(s):

As a manufacturer of technology products, Dell purchases components and materials that may contain “Conflict Minerals”, also known as 3TG. As defined in Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the term ‘‘Conflict Mineral’’ refers to columbite-tantalite (coltan), cassiterite, gold, wolframite and their derivatives – including tantalum, tin and tungsten – or any other mineral or its derivatives determined by the U.S. State Department to be financing conflict in the Democratic Republic of the Congo ("DRC") or an adjoining country.

Dell follows the OECD Due Diligence Guidance for Responsible Supply Chains from Conflict-Affected and High-Risk Areas to investigate our supply chain and ensure sales of 3TG contained in our products don’t directly or indirectly finance armed conflict or contribute to human rights violations. We expect our suppliers to have policies and due diligence practices in place to reasonably assure that 3TG contained in products and components supplied to Dell are not sourced from conflict mines.

Dell participates in multi-stakeholder initiatives such as the Responsible Minerals Initiative (“RMI”). The RMI provides tools such as the Conflict Minerals Reporting Template (“CMRT”) and oversees the Responsible Minerals Assurance Process (“RMAP”), which verifies that sourcing practices are aligned to the OECD framework. We use these tools, RMI guidance, and the OECD framework to conduct due diligence on our 3TG supply chain and advance responsible minerals sourcing practices. For more details on the due diligence process, please see our Conflict Minerals Disclosure report, Responsible Sourcing Policy, and Supply Chain Sustainability Report.

We have broadened our responsible material management system to include cobalt, which is used in the production of lithium-ion batteries, as the Congolese cobalt supply chain has been linked to child labor and poor safety conditions for artisanal mining, and to negative community impacts for large scale cobalt production. We are implementing the OECD Due Diligence Guidelines using the tools and programs of the RMI; we expect suppliers to follow this same framework and to participate in cobalt due diligence processes and capability building efforts around responsible minerals sourcing. Dell is also actively participating in several RMI’s workgroups, such as the Due Diligence Practices group and Mineral Reporting Templates group, to expand due diligence processes and tools to a broader set of minerals in collaboration with industry peers and other supply chain actors.

Dell Responsible Sourcing Policy

Conflict Minerals Report

Water use associated with Dell Technologies' operations are reported in our CDP Water Security response, section W1, at the link provided. Our 2023 response will be available in late 2023. Until then, our 2022 response is available.

CDP

How We Win: Dell Technologies Code of Conduct

Dell Location-Specific Privacy Policies