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 in 2012 and 2013 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 in order 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 200 other brands and retailers, as a signatory on a pledge, sponsored by the Responsible Sourcing Network, to not knowingly source Uzbek 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.
TJX's vendor relationships are based on a mutual commitment to uphold the high ethical standards embodied in our Vendor Code of Conduct and social compliance program. As a condition of conducting business with TJX and as a means of self-certification, all merchandise vendors 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.
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, and to evaluate and address risks of forced labor, including slavery and human trafficking. We created the TJX Global Social Compliance Manual, which is available in six languages and contains an audit procedure outline and factory evaluation checklist, to help the affected factories better understand our Code 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 Code, including our prohibition of involuntary or forced labor. Vendors are expected to cooperate fully with the audits and to provide the auditors with full access to their facilities, employees and documentation. 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. TJX has procedures to take appropriate steps should we learn that a vendor is failing to meet our standards, including remediation, cancellation of purchase orders and termination of our business relationship.
With respect to internal accountability, our TJX Global Code of Conduct prohibits behavior that creates an intimidating or hostile work environment, and it requires 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 are obligated to select vendors who act with integrity and in a manner consistent with the ethical principles stated in our Code. TJX reviews reported concerns and takes appropriate action depending on the nature and severity of the violation.
TJX provides biennial training for Associates and 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, slavery and human trafficking.
We believe that these efforts underscore to our vendors, buying agents and Associates our commitment and seriousness of purpose with respect to the ethical sourcing of our products. For many more details, particularly concerning our audit and training processes, we invite you to explore more fully this section of our website, which is dedicated to our Social Compliance Program.
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 – 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. 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.
To raise questions or concerns about these issues, please contact us at firstname.lastname@example.org
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 in the corporate responsibility section of our website.