Since 1999, we, our buying agents, and our third-party auditors have conducted thousands of audits of factories producing goods for TJX. Based on the knowledge learned from these audits and the program in general, we continue to revise and enhance our program.
The tragedies that took place in Bangladesh several years ago clearly focused retailers’ and manufacturers’ attention on remaining vigilant and monitoring whether their policies and practices are adequate and appropriate. Although very little of the product manufactured for us is made in Bangladesh, worker health and safety have always been a significant part of TJX's Social Compliance Program, and we have further strengthened our focus in these important areas.
We have expanded our audit programs based on evolving industry recommendations regarding auditing the fire safety practices of factories. We have elevated the importance of fire safety in our external supplier and internal buyer training programs and posted a message about our workplace safety expectations on our vendor intranet site as well. Going forward, we plan to continue to follow the various Bangladesh-focused initiatives of the retail industry to glean any insights that might enhance our own global Social Compliance Program.
Consistent with our commitment to high standards and social responsibility, since 2009, we have been attentive to the reports of alleged forced labor in Uzbekistan. We have notified our global vendor base that TJX prohibits the use of child labor in any phase of manufacturing of its goods for sale, and it is our expectation and our requirement that our vendors will not knowingly use any cotton sourced from Uzbekistan. A letter on our policy regarding Uzbekistan cotton is posted on our intranet for vendors. Our vendors are also reminded of our policy regarding Uzbekistan cotton during our vendor training sessions.
On three separate occasions, TJX was a signatory among many other companies, civil society organizations, and investors on letters urging the Government of Uzbekistan to ensure there is an immediate cessation to forced child labor in the cotton fields. In the past, we have participated in multi-stakeholder meetings to address this issue in Washington, D.C., New York, and Brussels. TJX continues to participate, along with over 270 other brands and retailers, as a signatory on a pledge, sponsored by the Responsible Sourcing Network, to not knowingly source Uzbekistan cotton until the Government of Uzbekistan eliminates the practice of forced child and adult labor. We also continue to participate in periodic multi-stakeholder calls to stay current on this matter.
(California Transparency in Supply Chains Act of 2010 and U.K. Modern Slavery Act of 2015)
At TJX, we are committed to treating people with dignity, fairness, and respect. Both our TJX Global Code of Conduct, which applies to all of our employees (Associates) worldwide, and our Vendor Code of Conduct, which applies to all of our merchandise suppliers, reflect these principles and prohibit involuntary or forced labor. As described below, our factory audit program and training efforts further underscore this commitment. Our TJX Social Compliance Committee, which includes senior leadership from the U.S., Canada, and Europe, meets on a regular basis to oversee TJX's ethical sourcing initiative. While an overview of our efforts is provided here in response to the California Transparency in Supply Chains Act of 2010 and the U.K. Modern Slavery Act of 2015, we invite you to explore a more comprehensive description of our Social Compliance Program within this section of our Corporate Responsibility microsite.
Vendor Code of Conduct. As a condition of conducting business with TJX and as a means of self-certification, our merchandise vendors are required to agree to comply with our Vendor Code of Conduct, which prohibits the use of any form of involuntary or forced labor, including labor obtained through slavery or human trafficking. Our Vendor Code of Conduct further requires that the goods our vendors sell to us have been manufactured in accordance with all applicable laws and regulations.
TJX Global Code of Conduct. Our TJX Global Code of Conduct prohibits behavior that creates an intimidating or hostile work environment, and it requires TJX Associates to obey all applicable laws and regulations of the countries in which we operate, including wage and hour rules. In choosing third parties to work with, our Associates must select those that act with integrity and in a manner consistent with the ethical principles stated in our Code. TJX reviews any reported concerns and takes appropriate action depending on the nature and severity of the violation.
Third-Party Audits. We contract with both independent auditors (including UL, Intertek, and Omega) and other third parties (such as our buying agents) to conduct social compliance audits at factories for suppliers of products that we have designed for sale in our stores and online, and to evaluate and address risks of forced labor, including slavery and human trafficking. Thousands of audits have been conducted since 1999.
We created a Global Social Compliance Manual, which is available in seven languages and contains an audit procedure outline and factory evaluation checklist to help the affected factories better understand our Vendor Code of Conduct and prepare for the audit process. The audits are conducted on an unannounced basis during specified time windows, and they are intended to verify the factories' compliance with the standards contained in our Vendor Code of Conduct, including our prohibition of involuntary or forced labor. To this end, auditors consider whether workers are responsible for any fees associated with their recruitment, and evaluate policies related to passport retention. Vendors are expected to cooperate fully with the audits and to provide the auditors with full access to their facilities, employees, and documentation. Our auditors include employee interviews in order to hear first hand about worker treatment. The factory’s score on the initial audit determines how soon it will be re-assessed, according to a risk-based audit cycle we have developed. We will take appropriate steps should we learn that a vendor is failing to meet our standards, including remediation, cancellation of purchase orders, or termination of our business relationship.
Training. We provide biennial training for Associates, including management, involved in the development and buying of merchandise, as well as cyclical in-person training for our buying agents, certain vendors and their factory managers around the world. Among other things, this training provides guidance on recognizing and mitigating the risks of forced labor, modern slavery, and human trafficking. A senior member of our U.S. based Global Social Compliance team travels globally to attend these training sessions in person, making sure our commitment to these important issues is clear.
Grievance Mechanisms. TJX Associates are encouraged to raise any concerns without fear of retaliation and have multiple channels to do so, including an ethics hotline staffed by independent third-party operators. External stakeholders may reach us via any of the phone numbers or addresses listed by locality on the "Contact Us" section of our corporate website.
This Statement relates to our fiscal year ended February 3, 2018. It is made on behalf of The TJX Companies, Inc. and its consolidated subsidiaries (collectively, "TJX") because we take a global approach to the topic discussed herein. Not all of our consolidated subsidiaries are subject to the California Transparency in Supply Chains Act or the U.K. Modern Slavery Act. This Statement has been approved by the Boards of the TJX subsidiaries subject to the U.K. Modern Slavery Act, as required by that Act, and signed by the undersigned Director of those entities.
David L. Averill, Director
At TJX, we are committed to complying with the rules and regulations impacting our business, including those under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, intended to address violence and human rights abuses in the Democratic Republic of the Congo (the DRC) and adjoining countries. These rules require public companies to determine if they manufacture or contract to manufacture any products where “conflict minerals” - specifically tin, tantalum, tungsten, and gold (or “3TG”) - are necessary to the functionality or production of the product, and if so, whether those minerals originated in the DRC or adjoining countries. Companies are required to do additional diligence about the source and chain of custody of those minerals that may have originated in the covered region to determine if they came from sources that benefited armed forces in the region.
As demonstrated by the TJX Vendor Code of Conduct and our Social Compliance Program, we believe in responsible sourcing. TJX is many layers removed from the mining, smelting, or refining of any minerals contained in the products we sell, so we must rely on our vendors to collect current, complete, and reliable information to comply with these rules. We expect our affected vendors not to knowingly supply us with products that include conflict minerals that directly or indirectly benefit armed groups in the DRC or adjoining countries, although we do not discourage responsible sourcing from that region. We further expect our vendors and buying agents to comply with our requests to provide us with information and perform due diligence regarding their sourcing of the minerals at issue. We will consider appropriate remediation steps if we find that a vendor has violated this policy.
At TJX, our retail chains strive to offer a merchandise mix that provides choices for the very broad customer demographic that we serve across the globe. In each of our regions, we aim to offer customers the kinds of products that they may be interested in purchasing, and this approach is reflected in our fur practices.
TJX is committed to continuous improvement in the ethical sourcing of products intended for sale in our businesses, and as part of our ongoing considerations regarding animal welfare, we have recently incorporated information about our fur practices into our social compliance training.
The vast majority of TJX businesses are fur-free. In the U.S., at T.J. Maxx, Marshalls, HomeGoods, Sierra Trading Post, and Homesense, we avoid knowingly purchasing or selling products that contain real fur. In Europe, T.K. Maxx and Homesense have a longstanding “no fur” policy and since 2012, no longer source goods containing angora. At T.K. Maxx in Australia, we also avoid knowingly purchasing or selling products that contain real fur or goods containing angora. From time to time, these businesses may offer products containing shearling, haircalf, or hide. The process of procuring merchandise for our off-price model is complex, and if an item containing fur is mistakenly sent to our stores or e-commerce sites in these geographies, we work quickly to remove the item. At Winners, HomeSense, and Marshalls in Canada, our fur practices differ due to customer preferences, and we may, on occasion, offer products that contain fur.
Importantly, at all times, TJX is committed to conducting business in compliance with all applicable laws, rules, and regulations.
Social compliance is a tremendously challenging undertaking, and we know that we do not have all of the answers. Indeed, no company does. We believe we are responding to the challenge by making our commitment clear to our vendors, buying agents, and Associates; by our auditing and training efforts; by responding to issues as appropriate for our business; and by reporting on our efforts on our website.
To raise questions or concerns about these issues, please contact us at email@example.com.