Verification

We do not currently engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery.

Audit

We do not currently conduct audits to evaluate compliance with the company’s standards for trafficking and slavery in our supply chains.

Certification

We do not currently require our direct suppliers to certify that they comply with anti-slavery and human trafficking laws in the country or countries in which they do business.

By 2019, we will require that suppliers for our private brand items self-certify that they comply with our anti-slavery and human trafficking standards by including the below Supplier Affirmation of Human Rights Conduct as part of our private brand supplier contracts. Misrepresentation by a supplier of any of these affirmations may be deemed a breach contract, permitting us to terminate our contract with that supplier.

Supplier Affirmation of Human Rights Conduct

Unless more strictly regulated by Applicable Law, SUPPLIER promises that, in its performance of this Agreement:

1. SUPPLIER does not employ anyone under the age of 15 (or younger than the age for completing compulsory education), or anyone under the minimum age established by applicable law in the country of manufacturer, if higher than the age of 15.
2. SUPPLIER does not use involuntary labor including prison labor, indentured labor, or forced labor of any kind. SUPPLIER’S employees are not required to lodge papers or deposits upon beginning their employment.
3. SUPPLIER does not engage in corporal punishment, mental, physical, sexual, or verbal abuse, and does not use cruel or abusive disciplinary practices in the workplace.
4. SUPPLIER complies with the laws on working hours and employment rights in the countries in which it operates.
5. SUPPLIER pays each employee at least the minimum wage, or a fair representation of the prevailing industry wage (whichever is higher), and provides every employee with all legally mandated benefits.
6. SUPPLIER does not discriminate against employees on the basis of gender, gender identity or expression, race, religion, age, disability, sexual orientation, nationality, marital or maternity status, work or personal affiliations, political opinion or social or ethnic origin.
7. SUPPLIER provides a safe and healthy workplace, presenting no immediate hazards to its employees. SUPPLIER provides access to emergency healthcare to its employees in the event of accidents or incidents at SUPPLIER’S workplace.
8. If SUPPLIER provides dormitories or other housing for its employees, those facilities are safe for human habitation and comply with all local health and safety laws and standards.

Internal Accountability

We do not currently have internal procedures for determining whether employees or contractors are complying with company standards regarding slavery and human trafficking.

Training

We do not currently provide training on mitigating risks of human trafficking and slavery to employees who have direct responsibility for supply chain management.