This Statement relates to our fiscal year that commenced on January 30, 2022 and ended January 28, 2023 (“fiscal year 2023”). This Statement generally discusses the efforts of The TJX Companies, Inc. and its consolidated subsidiaries to address modern slavery because we take a global approach to modern slavery compliance. The reporting entities come within our Global Social Compliance Program.
About Our Business. TJX is an off-price retailer of apparel and home fashions with over 4,800 stores across three continents in nine countries offering a rapidly changing assortment of merchandise. We source merchandise from a varying and expansive universe of approximately 21,000 vendors and more than 100 countries. As a multi-banner, multi-geography off-price retailer, we have a large, complex, and global business model that differs from many other traditional retailers that, unlike TJX, may own, operate, or control the facilities that manufacture products sold in their stores and/or may purchase products from a generally consistent vendor base. Our strategies to acquire merchandise are intentionally flexible to allow our buying organization to react to frequently changing opportunities and trends in the market and to adjust how and what is acquired as well as when it is acquired. Sometimes, when what we are seeing in the marketplace is not the right value for our customers, meaning the right combination of brand, fashion, price, and quality, we may help design or develop merchandise to be manufactured just for us.
Our Commitment. 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 our merchandise vendors, reflect these principles and prohibit involuntary or forced labor. We believe that—like most other retailers—a principal modern slavery risk is that forced labor could occur without our knowledge in violation of our policies in areas of the supply chain from which we may be several or more levels removed. We are aware of reports of modern slavery in apparel supply chains generally and, as described below, our Global Social Compliance Program underscores our efforts to address and mitigate these risks and, where appropriate, take corrective action. We believe that modern slavery risks in our own workforce are minimal due to the strength of our internal employment policies and procedures.
Our Global Social Compliance Program. Our Global Social Compliance Program includes, among other things, our factory audit program, our Vendor Code of Conduct, our training efforts, and our grievance mechanisms for vendors. As part of our program, including as part of assessing its effectiveness, we regularly review factory audits performed, remediation efforts taken, and vendor training attendance. Our Global Social Compliance Committee, which includes senior leadership, meets on a regular basis to oversee this program and review trends in social compliance. In addition to our Global Social Compliance Committee, our Chief Risk and Compliance Officer, who is a member of our Global Social Compliance Committee, provides an annual update to our Board of Directors on our Global Social Compliance Program and meets regularly with our Board and committees of the Board.
To help us evaluate and address the risks of modern slavery in our merchandise supply chain, we are members of external multi-stakeholder initiatives that share resources and best practices intended to improve efforts to combat forced labor, including the Joint AAFA/NRF/RILA/USFIA Forced Labor Working Group, the Responsible Business Alliance’s Responsible Labor Initiative, Retail Industry Leaders Association (“RILA”) Responsible Sourcing Committee, and the American Apparel and Footwear Association Social Responsibility Committee.
Vendor Code of Conduct. Our merchandise purchase order terms and conditions include a requirement for our merchandise vendors to agree to comply with our Vendor Code of Conduct, which prohibits involuntary or forced labor, including labor obtained through slavery or human trafficking. Our Vendor Code of Conduct further requires that the goods our merchandise vendors sell be manufactured in accordance with all applicable laws and regulations, which include those pertaining to involuntary labor, forced labor, or human trafficking. It also requires that merchandise vendors ensure that all subcontractors and any other third parties they use in the production or distribution of goods offered for sale in our stores comply with the principles described in the Vendor Code of Conduct.
Third-Party Audits. Our Global Social Compliance Program includes factory auditing. We focus our factory auditing where we have more influence in bringing the products to market. This means our program typically reaches factories that produce merchandise that we have helped design or develop to be manufactured just for us. We focus our auditing efforts on these factories because we believe this is where we are most likely to be able to have a meaningful impact. We contract with both leading independent auditors (including UL, Intertek, and Omega) and other third parties (such as our buying agent) to conduct these social compliance audits and we also accept audit reports from recognized audit sources, including BSCI, WRAP, and SEDEX. These social compliance audits evaluate and address risks, including risks of modern slavery. In fiscal year 2023, we reviewed more than 2,900 audits. Over the last two decades, we have conducted or accepted tens of thousands of audits.
We maintain a Global Social Compliance Manual, which is available in seven languages and contains an audit procedure outline and factory evaluation checklist to help factories better understand our Vendor Code of Conduct and prepare for audits conducted on our behalf by UL, Intertek, and Omega. The audits are conducted on an unannounced basis during specified time windows, where practical, and they are intended to verify the factory’s compliance with the standards contained in our Vendor Code of Conduct, including our prohibition of involuntary or forced labor. To this end, factory audits consider, among other things, 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. Factory audits include employee interviews in order to hear first-hand about worker treatment. We recently enhanced our audit program with additional forced labor questions based on recommendations from industry groups. When we accept factory audit reports from recognized third party audit sources, the audit report is evaluated against our own internal audit requirements to determine the factory’s audit score. The factory’s score on the initial audit determines timing for reassessment, according to a risk-based audit cycle we have developed. Our policy is to take appropriate steps should we learn that a vendor is failing to meet our standards. These steps may include remediation, cancellation of purchase orders, or termination of our business relationship.
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 are also expected to select those that act with integrity and in a manner consistent with the ethical principles stated in our Global Code of Conduct. TJX reviews reported concerns and takes appropriate action depending on the nature and severity of the violation.
Training. We provide regular training for Associates, including management, involved in the development and buying of merchandise, as well as cyclical training for our buying agents, certain vendors, and their factory representatives around the world. Typically, we hold an average of 8-12 training sessions a year, focusing on various locations around the world that are regionally close to factories included in our factory audit program. Among other things, this training provides guidance on recognizing and mitigating the risks of modern slavery. Due to the COVID-19 global pandemic, we held virtual training in fiscal years 2022 and 2023. Live training sessions were reinstated for fiscal year 2024. Through our affiliation with the Responsible Business Alliance, we now offer all TJX vendors access to a virtual training about the prevention of forced labor. All merchandise vendors and the factories they use in the production of TJX goods are encouraged to self-register for this training through our corporate intranet site for vendors.
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, including vendor personnel, may reach us via this ethics hotline or any of the phone numbers or addresses listed by locality on the "Contact Us" section of our corporate website. During fiscal year 2023, we added a “Reporting” section to our Vendor Code of Conduct, which includes a link to our ethics hotline and phone number, further enabling vendors to report any potential violations or concerns to us. While an overview of our efforts is provided here in response to the California Transparency in Supply Chains Act and the U.K. Modern Slavery Act, we invite you to explore a more comprehensive description of our Global Social Compliance Program within the Corporate Responsibility section of our website at https://www.tjx.com/responsibility/responsible-business.
This statement was approved on 31 July 2023 by the Boards of Directors of TJX UK, TJX Europe Buying (Deutschland) Ltd. and TJX Europe Buying Ltd., which are the TJX subsidiaries subject to the UK Modern Slavery Act, and signed by the undersigned Director of each of those entities as of 31 July 2023.
David L. Averill, Director
TJX UK, TJX Europe Buying (Deutschland) Ltd., and TJX Europe Buying Ltd.
Updated July 2023