V.A.L.U.E. Facts

Global Vendor Social Compliance Program

TJX's Global Vendor Social Compliance Program is coordinated by its Assistant Vice President, Global Social Compliance, who has specific responsibility for managing and overseeing our ethical sourcing program. Our Assistant Vice President, Global Social Compliance, reports to the Senior Vice President, Enterprise Risk Director and Chief Compliance Officer, and works closely with representatives of the different purchasing functions across all of TJX's businesses and with the Vendor Social Compliance Committee, discussed below. This Global Social Compliance position interacts on a regular basis with UL Responsible Sourcing (formerly STR), Intertek Group PLC (Intertek) and other internal and external resources on issues of program development and on vendor and buying agent training, monitoring and remediation.

Our Vendor Social Compliance Committee is overseen by senior management. The Committee is comprised of management representatives from the relevant disciplines within TJX, including merchandising, sourcing, imports, compliance, enterprise risk management, legal and investor relations. The Committee meets on a regular basis and oversees compliance with TJX's Vendor Social Compliance initiative. Committee members work closely and cooperatively with the Assistant Vice President, Global Social Compliance, on responding to significant issues.

Private Label and Name Brand Products
Only a small percentage of the product sold by TJX in its stores is private label merchandise produced specifically for TJX. We do not own, operate, or control any facilities which manufacture the products we sell. Indeed, the vast majority of products sold in our stores is brand name merchandise. Many of these brand owners apply their own codes of conduct, ethical sourcing guidelines, and monitoring programs to the suppliers and licensees that produce their products. These programs for the most part incorporate the same universe of supplier expectations as does TJX's Vendor Social Compliance Program. Nevertheless, as part of the purchase order terms, our vendors of name brand product also agree to comply with TJX’s Vendor Code of Conduct and warrant that their goods have been manufactured and shipped in accordance with all applicable laws, regulations and industry standards.

TJX's Vendor Social Compliance initiative focuses most of its resources on striving to assure compliance at overseas facilities producing private label products for sale in our stores. We believe that our finite resources are best devoted to those suppliers who produce our private label product because this is where we are most likely and most able to have a meaningful impact.

Third-Party Resources and Support
In pursuing our Vendor Social Compliance initiative, we have relied upon some of the best resources available:

• We have reviewed and incorporated many of the international human rights standards enunciated by international bodies such as the United Nations and the International Labor Organization.

• We have received and incorporated valuable insights and suggestions from our investor community, specifically from socially-responsible investor groups.

• We have reviewed and benchmarked ourselves against the programs of companies comparable to ours.

• We have retained UL Responsible Sourcing and Intertek, organizations that have extensive experience and knowledge in the field of ethical sourcing, to assist us with program development, education and training, and compliance monitoring.

• We are members of the National Retail Federation, the Ethisphere Business Ethics Leadership Alliance and the Ethics and Compliance Officers Association.

• We are active participants in industry conferences and training programs on the latest developments in vendor compliance and ethical sourcing.

Program Summary
TJX sources its private label products from vendors in countries around the world. We have put significant effort into working with our primary buying agents, familiarizing and training them with respect to our Vendor Code of Conduct and our Vendor Social Compliance Program, and reviewing their audit protocols. We intend to continue and to improve upon these training efforts, both with our buying agents and with our private label vendors. We believe that our emphasis on training, coupled with our factory monitoring efforts and the terms of our purchasing documentation, underscore for our agents and these vendors our commitment and seriousness of purpose with respect to the ethical sourcing of our products.

Although our Vendor Code of Conduct encompasses all the products we purchase for sale in our stores, we target our principal attention and resources on those areas of the world where we believe the challenges associated with achieving our Code expectations are the greatest. We work closely with experts both in the U.S. and in the relevant markets to assess where these challenges are the greatest, and to develop our auditing, remediation, and training plans and schedules based upon what we believe will best enable our vendors to satisfy our expectations. Some of our program details applicable to our private label vendors are discussed below.

Monitoring and Compliance
Vendors producing private label product are expected to cooperate fully with TJX and its auditors, and to provide access to facilities and documents. We and our representatives work closely with our vendors and agents so that they understand our Vendor Code of Conduct and our Vendor Social Compliance Program. While remediation and continuous improvement are our goals, if we find that our standards are not being met, we reserve the right to take action - up to and including cancellation of purchase orders and termination of our business relationship.

• Vendor Social Compliance Audit Guidelines: TJX requires our international buying agents and vendors to confirm that our policies are followed and our expectations are met. Our buying agents and our vendors understand that TJX requires access to factories in which our private label goods are being manufactured in order for us to make such determinations.
• Independent Third-Party Audits: TJX has engaged UL Responsible Sourcing and Intertek, both of which have offices throughout the world, to conduct factory inspections on behalf of TJX and liaise with TJX to develop recommendations for necessary corrective action items identified as a result of these inspections.

UL Responsible Sourcing and Intertek audits generally entail one to two full working days at a factory. The auditing team includes fluent native speakers and readers of the manufacturing country's language who are familiar with the local culture. During the course of an audit, we require that UL Responsible Sourcing and Intertek inspectors have the opportunity to interview factory management, as well as to conduct private interviews with factory workers. The auditors also review factory policies and documentation, and conduct a factory walk-through to assess compliance with labor, health and safety regulations, industry standards and TJX's Vendor Code of Conduct.

Each audit concludes with a closing meeting, at which time the auditor's findings are communicated to factory management. If necessary, a preliminary corrective action plan is provided and appropriate follow-up is planned. Once we determine that a factory on a corrective action plan has taken all appropriate corrective action, the factory is thereafter audited on a regular basis to verify that compliance is maintained. For the benefit of those working in the factory and to effect social change, it is our goal to work with our vendors to help them understand and comply with our standards. When required, we inform our vendors of the steps they need to take to meet our standards. However, in extreme cases, we will terminate vendors for noncompliance.

Environmental Responsibility
In keeping with our commitment to protect the environment, audits conducted on behalf of TJX include a review of factory policies, practices and procedures concerning the handling of chemicals and other hazardous waste, and a review of whether the factory is in compliance with all applicable environmental laws and regulations. Our Vendor Code of Conduct strongly encourages our vendors to share our commitment to environmentally-responsible business practices including reusing, reducing and recycling waste.

Management Systems and Program Design

• We hold periodic meetings with UL Responsible Sourcing and Intertek to (a) assess program status; (b) set monitoring priorities; (c) discuss training initiatives; (d) get updates on industry best practices; and (e) refocus strategic direction for our program. We also rely on input from other experts and stakeholders at various stages of this process. These include groups of interested investors, who have helped us by sharing their thoughts, ideas and suggestions. These discussions help us refine and improve these processes on an ongoing basis.
• Our Assistant Vice President, Global Social Compliance, has regular, ongoing and systematic interaction with UL Responsible Sourcing and Intertek to develop, orchestrate and implement TJX's Vendor Social Compliance Program. This process also includes the involvement of TJX internal buying staff and others involved in the day-to-day management of sourcing issues for TJX.
• We communicate on an ongoing basis with our buying agents to explain our expectations and to understand how their processes and management systems conform to those expectations.
• We have similar dialogues and processes with vendors from whom we source directly.
• UL Responsible Sourcing has conducted reviews of the internal compliance programs of several of our principal buying agents so that we might fully assess our reliance on their monitoring efforts conducted on our behalf.