At the conclusion of an audit, a copy of the CAP is left with management to assist them in resolving any violations or deficiencies detected during the audit. To encourage collaboration between our buying agents and vendors, a copy of the CAP is also forwarded to both parties’ attention shortly following a third-party audit. TJX receives a copy as well.
For lower-risk deficiencies, our buying agents or direct vendors are expected to provide evidence to us demonstrating that remedial action has been carried out. However, where moderate to more serious violations of the Vendor Code of Conduct or the local laws are detected, we require that our third-party representatives re-audit the factory. Problems are tracked and factories are notified of the expectation of remedial action.
There are several issues that we consider “zero tolerance” issues. That is, we would immediately terminate the relationship if a factory is found to be in violation of this aspect of our program, including for example, issues like bribery/corruption; child, prison, slave, or forced labor; human trafficking; maintaining a facility with all doors and/or exits locked; use of chemicals banned in that region; and failure to pay any wages.
When a problem requires remediation, we expect that continuous improvement is verified during the re-audit. Our general goal is that each re-audit demonstrates measurable improvement from the prior audit. If a factory receives several consecutive noncompliant grades, this pattern may suggest that required remedial action is not being undertaken.
Though we strive to work with vendors to address and resolve shortcomings in their operations, under extreme circumstances, we must conclude that we can no longer do business with certain factories, or that they will be precluded from producing goods for us until they demonstrate that they have addressed the situation and have put management systems in place to prevent a recurrence.
Our preferred approach, however, is to work with vendors whenever possible to address and resolve issues identified during audits of their facilities because the reality is that improving working conditions in factories in underdeveloped countries is an ongoing effort. TJX, like other retailers, is facing this challenge. Our goal, when possible and reasonable, is continuous improvement of conditions at factories. This is preferable to ceasing business with these factories and gives us the ability to influence positive change. We believe that this “continuous improvement” model is in the best interest of the workers in the facilities from which we source goods.
Integral to the success of our compliance program is ongoing involvement and partnerships between TJX, UL, Intertek, Omega, our buying agents, and vendors to address shortcomings identified in audits and to work toward improvement.