Responsible Sourcing

1,200+

Buying Associates

~21,000

vendors

100+

Countries

TJX believes in the importance of ethical sourcing in our supply chain and is committed to strive for continuous improvement. We strongly value the relationships that we have developed with our vendors, which are built on a foundation of honesty, trust, and ethical business practices. We believe these relationships have been a key factor in our long-term success.

On a worldwide basis, in fiscal 2022, more than 1,200 Associates in our buying organization sourced product from a universe of approximately 21,000 vendors and more than 100 countries around the world. As part of TJX’s purchase order terms and conditions, our merchandise vendors are required to comply with our Vendor Code of Conduct. The Vendor Code of Conduct requires that goods we sell have been manufactured and shipped in accordance with all applicable laws, regulations, and, including, among other things, a commitment to respect the rights of the workers who manufacture products for sale in our stores and online. These requirements stand even if a vendor applies their own code of conduct, monitoring, or ethical sourcing guidelines. Our vendors are also required to ensure that any factories or subcontractors they use comply with our Code’s principles.

Our Off-Price Business Model

TJX is the leading off-price apparel and home fashions retailer in the U.S. and worldwide. Our mission is to deliver great value to our customers every day. We do this by offering ever-changing selections of high quality, fashionable, brand name, and designer merchandise at prices generally 20% to 60% below full-price retailers’ (including department, specialty, and major online retailers) regular prices on comparable merchandise, every day.

The majority of product we sell in our stores and online is brand-name merchandise. To obtain this merchandise, we work closely with our vendors and take advantage of a wide variety of opportunities, which can include department store cancellations, a manufacturer making up too much product, or a closeout deal when a vendor wants to clear merchandise at the end of a season. There are other ways we bring tremendous value to our customers. For example, 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 GLOBAL SOCIAL COMPLIANCE EFFORTS

We focus our factory monitoring and supplier training program 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.

While we do not own, operate, or control any facilities that manufacture products we sell, we collaborate closely with our buying agents and international buying offices because they have strong relationships with local production facilities and are well positioned to reinforce our expectations. Learn more about our commitment to Global Social Compliance.

1,200+

Buying Associates

~21,000

vendors

100+

Countries

1,200+

Buying Associates

~21,000

vendors

100+

Countries

RWENZORI TRADE PROJECT

We are particularly proud of the Rwenzori Trade Project, a sustainable trade program that we helped to develop in Uganda. In 2008, TJX Europe partnered with Save the Children with the aim of supporting education in the cotton-growing communities in the Rwenzori region of Western Uganda. We began our work with 12 communities, funding classrooms and teachers’ housing as well as donating money to supply educational materials, clean water, and toilets.

As our program evolved, we learned that to have a long-term impact, these communities needed ways to generate greater and more reliable income for their families. We began working with local partners to help create a sustainable trade program. Our goal was to help families living in this area increase their incomes so they could better care for themselves and send their children to school.

In 2011, the sustainable trade project was established to support the production of cotton, coffee, cocoa, and handmade crafts. Working with local commercial and development partners, farmers were taught how to develop better and higher quality crop yields. Producers were brought together to form cooperatives, giving them greater power in the marketplace, and a range of training courses were offered to teach skills ranging from bookkeeping to product development.

TJX Europe supported the establishment of a locally staffed trade center where producers can gather to pack and ship their products as well as collaborate and receive commercial, agronomic, and marketing support for their products.

The impact of Covid has brought new challenges to the Rwenzori communities. TJX has provided additional funding during this time to support out-of-school children and families affected by the pandemic.

Moving forward, we are proud to continue our support by offering Rwenzori co-operatives’ products, for sale in our stores across the U.S., Canada, and Europe.

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. 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, including 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 expands 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 we become aware that 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 Statement 

  (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 January 31, 2021 and ended January 29, 2022 (“fiscal year 2022”). 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 nearly 4,700 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 an off-price retailer, we have a complex global business model that is quite different from 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 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, our actions have included membership in external multi-stakeholder initiatives that share resources and best practices 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. 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.

  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 of modern slavery. In fiscal year 2022, we reviewed more than 2400 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 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, 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 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.

  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 agent, certain vendors, and their factory representatives around the world. Typically, we hold an average of 10-12 training sessions a year, focusing on various locations around the world that are regionally close to factories included in our factory monitoring 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 initiated virtual training in fiscal year 2021, which continued in fiscal year 2022.

  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. 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 20 July 2022 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 20 July 2022.

  
  
  

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

CONTINUOUS IMPROVEMENT