Responsible Sourcing

Our Off-Price Business Model

Evolving Issues

• BANGLADESH

  The tragedies that have taken place in factories in Bangladesh are reminders that we must remain vigilant and continue to monitor whether our policies and practices are adequate and appropriate. Although only a small amount of product manufactured for us is made in Bangladesh, worker health and safety have always been a significant part of TJX's Global Social Compliance Program.

  Our audit programs are based on evolving industry recommendations regarding auditing the fire safety practices of factories. We stress the importance of fire safety in our external supplier and internal buyer training programs and have posted a message about our workplace safety expectations on our vendor intranet site. Our Vendor Code of Conduct includes a statement that extends our requirements for providing safe and healthy conditions beyond the factory to include any living facilities provided to workers. Going forward, we plan to continue to follow the various initiatives of the retail industry to glean any insights that might enhance our own Global Social Compliance Program.

• Conflict Minerals

  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 Global 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 that our affected vendors will not 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.

• Fur Practices

  TJX’s businesses around the world are fur-free. From time to time, our businesses may offer products containing shearling, haircalf, or hide. Additionally, in Europe and Australia, we do not knowingly source goods containing angora. While across all of our regions – the U.S., Canada, Europe, and Australia, we avoid knowingly purchasing or selling products that contain real fur, 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, we work quickly to remove the item.

  We are also 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 incorporated information about our fur practices into our social compliance training in 2018. Importantly, at all times, TJX is committed to conducting business in compliance with all applicable laws, rules, and regulations, including but not limited to, animal protection laws.

• Modern Slavery and Human Trafficking

  (California Transparency in Supply Chains Act of 2010 and U.K. Modern Slavery Act of 2015)

  About Our Business. TJX is an off-price retailer of apparel and home fashions with over 4,500 stores across three continents in nine countries offering a rapidly changing assortment of merchandise. We source merchandise from a universe of more than 21,000 vendors and over 100 countries. 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.

  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 are aware that instances of modern slavery have been reported in merchandise supply chains. As described below, our Global Social Compliance program, which includes, among other things, our factory audit program, our Vendor Code of Conduct, our training efforts, and our grievance mechanisms for vendors, underscores our efforts to address and mitigate these risks with our merchandise vendors, and where appropriate, to take corrective action. We also regularly review factory audits performed, remediation efforts taken, and vendor training attendance, as part of these efforts.

  Our TJX Global 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. This Committee also reviews summary results of audits and global trends in social compliance. In addition to our Global Social Compliance Committee, in 2018, we established a Global Corporate Responsibility Executive Steering Committee comprised of senior personnel across several departments, which has responsibility for overseeing our global corporate responsibility efforts across functions and geographies, facilitating information exchange, recommending additional program efforts to potentially undertake as a Company, and reporting to the Company’s senior management and Board of Directors as appropriate.

  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 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 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 to us have been 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. In May of 2020, we amended our Vendor Code of Conduct to expressly provide that our merchandise vendors must not require workers to surrender any identity papers as a condition of employment, and our merchandise vendors must reimburse their workers for any recruitment or hiring fees paid. Additionally, we now require that merchandise vendors provide a written contract to their workers, with wage terms and terms of employment, prior to acceptance of employment.

  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 expected to 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 leading independent auditors (including UL, Intertek, and Omega) and other third parties (such as our buying agent) to conduct social compliance audits at factories that supply products that we have designed for sale in our stores and online. In addition, we accept audit reports from recognized accredited audit sources, including BSCI, WRAP, and SEDEX, from these merchandise vendors. These social compliance audits evaluate and address risks of forced labor, including slavery and human trafficking. Over the last two decades, thousands of audits have been conducted.

  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, where possible, 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, factory audits 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. Factory audits 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 representatives 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 attends these training sessions, 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, including vendor personnel, 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 that commenced on February 3, 2019 and ended February 1, 2020. The publication of this statement has been delayed due to disruptions to our business caused by COVID-19. This statement encompasses The TJX Companies, Inc. and its consolidated subsidiaries because we take a global approach to modern slavery compliance. However, 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 was approved on October 15, 2020 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 U.K. Modern Slavery Act, and signed by the undersigned Director of each of those entities as of October 15, 2020.

  
  
  

  David L. Averill, Director
  TJX UK, TJX Europe Buying (Deutschland) Ltd., and TJX Europe Buying Ltd.

• UZBEKISTAN: FORCED ADULT AND CHILD LABOR

  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 forced adult or 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, and our vendors are reminded of this policy during our vendor training sessions.

  In the past, we have been a signatory on letters urging the Government of Uzbekistan to ensure there is an immediate cessation to forced child labor in the cotton fields, and we have participated in multi-stakeholder meetings to address this issue. TJX continues to participate, along with over 300 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.

CONTINUOUS IMPROVEMENT