(California Transparency in Supply Chains Act of 2010 and U.K. Modern Slavery Act of 2015)
This Statement relates to our fiscal year that commenced on February 2, 2020 and ended January 30, 2021. 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 4,500 stores across three continents in nine countries offering a rapidly changing assortment of merchandise. We source merchandise from a universe of approximately 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.
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 of reports of modern slavery in apparel supply chains 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, we also have a Global Corporate Responsibility Executive Steering Committee to help guide our global corporate responsibility strategies and align them with TJX business priorities, oversee corporate responsibility efforts across functions and geographies, facilitate information exchange, and support enhanced corporate responsibility reporting. This Committee is comprised of senior executives representing functions across the Company, including two executive officers reporting directly to the CEO. These executive officers are positioned to update management and the Board on the ongoing work of the Committee.
To help us evaluate and address the risks of modern slavery in our merchandise supply chain, this past fiscal year, we increased our membership in external multi-stakeholder initiatives that share resources and best practices to improve efforts to combat forced labor. In September 2020, we joined the Joint AAFA/NRF/RILA/USFIA Forced Labor Working Group, and in December 2020, we joined the American Apparel and Footwear Association Social Responsibility Committee. TJX is also an Ambassador Sponsor of the Responsible Sourcing Network’s YESS initiative, which aims to train, support, and enable spinners and mills in the middle tiers of the supply chain to end forced labor at the raw cotton level.
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 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 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.
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 produce products for which we have more influence in bringing to market. Typically, this means factories that are involved with products that we have helped design or develop to be manufactured just for us. 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 modern slavery. 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 the audit process. The audits are conducted on an unannounced basis during specified time windows, where possible, 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 for audits conducted on our behalf by UL, Intertek, and Omega, with additional forced labor questions based on recommendations from industry groups. The factory’s score on the initial audit determines timing for re-assessment, 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.
We provide regular 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 modern slavery. Due to the COVID-19 global pandemic, we initiated virtual training in 2020.
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.
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 22 July 2021 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 22 July 2021.
David L. Averill, Director
TJX UK, TJX Europe Buying (Deutschland) Ltd., and TJX Europe Buying Ltd.