Some of our merchandise is manufactured for us and some we design, particularly 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 believe our factory monitoring efforts are best devoted to products we design and have manufactured for us, because this is where we are most likely to be able to have a meaningful impact. When we source these products, we require the buying agents and vendors that are involved to identify any active factories that they use, or intend to use, to produce such merchandise and request that we have an audit prior to starting to produce our goods. Further, we strive to have members of our buying offices visit all factories in which we expect to produce goods designed by us.
Together with our representatives, UL LLC (“UL”), Intertek Group PLC (“Intertek”), and Omega Compliance Limited (“Omega”), we work closely with our agents and vendors so that they understand our Global Social Compliance Program, our Vendor Code of Conduct, and our factory auditing process. Our merchants also play an important role in educating vendors on our Program requirements and encouraging them to make improvements at their facilities, when necessary. Additionally, our buying offices have one or more Associates assigned to support our local social compliance efforts and assist in driving positive change at the factories.