GLOBAL SOCIAL COMPLIANCE PROGRAM

We strongly value our vendor relationships as we believe they have been a key factor in our long-term success. On a worldwide basis, in fiscal 2022, TJX had more than 1,200 Associates in its buying organization who source merchandise in a variety of ways from a universe of approximately 21,000 vendors and more than 100 countries around the world. 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. We focus our auditing efforts on the factories that manufacture this merchandise because we believe this is where we are most likely to be able to have a meaningful impact.

Our philosophy towards social compliance mirrors our culture, and just as we are committed to honesty, integrity, and treating others with dignity and respect, we expect those that we do business with to do the same. We have reviewed and incorporated many of the international human rights standards enunciated by international bodies, such as the United Nations and the International Labour Organization. Our commitment to these principles is reflected in our Vendor Code of Conduct, which serves as the foundation for our program and our responsible sourcing initiatives.

• Program Oversight

  Our Senior Vice President (SVP), Chief Risk and Compliance Officer has responsibility for social compliance across our global operations, including our Global Social Compliance Program. The SVP periodically reports to our Board of Directors on various aspects of our program, which may include training efforts, audit results, and other compliance-related topics. Our Global Social Compliance Program is part of our ongoing enterprise risk assessment.

  Program management is overseen by the Assistant Vice President (AVP), Global Social Compliance, who works closely with representatives of our merchandise and purchasing functions across all of TJX’s businesses and with the Global Social Compliance Committee. This committee is comprised of senior leadership representing the U.S., Canada, and Europe and from relevant disciplines within TJX, including Merchandising, Sourcing, Imports, Compliance, Audit, Legal, and Global Communications. The committee oversees compliance of TJX’s ethical sourcing initiatives, and serves in an advisory capacity, helping to guide the strategy and execution of the program. Our international buying offices and merchants also play key roles in achieving our goals.

  Our approach to our Global Social Compliance Program includes:

  Stakeholder Engagement:

  • We believe that engaging with various audiences and a variety of industry associations and considering their guidance helps us as we strive to continually improve our program.

  
  

  Auditing:

  • In fiscal 2022, we accepted more than 2,400 audits, which were either conducted directly by TJX’s third-party auditors or were accepted from recognized sources.¹

  
  

  Training:

  • We offer training sessions on a regular basis to educate buying agents, vendors, and factory management within our audit program on our expectations with regard to social compliance and to reiterate our seriousness of purpose. TJX Associates involved in the development and buying of merchandise are expected to undergo formal social compliance training biennially.

  
  

  Vendor Code of Conduct:

  • As part of our purchase terms, merchandise vendors are required to adhere to our Vendor Code of Conduct and ensure that any factories or subcontractors they use also comply with our Code’s principles. Factories included in our audit program are required to undergo regularly scheduled audits.
• External Stakeholder Engagement

  As we continue to develop and evolve our Global Social Compliance Program, we engage with various audiences and consider their guidance. We have reviewed and incorporated many of the international human rights standards enunciated by international bodies, such as the United Nations and the International Labour Organization, and have received, and at times incorporated, insights and suggestions from investors. For our audits conducted by third-party auditors, we have retained and engage with several organizations that have extensive experience and expertise in the field of ethical sourcing – UL LLC, Intertek Group PLC, and Omega Compliance Ltd. Additionally, these groups assist us with program development, education and training, and compliance monitoring.

  We are members of the National Retail Federation, the Retail Industry Leaders Association (RILA), Ethisphere’s Business Ethics Leadership Alliance, Boston College Center for Corporate Citizenship, the Ethics & Compliance Officer Association, and the American Apparel Footwear Association. We also collaborate with various industry groups such as the Joint Forced Labor Working Group, RILA’s Responsible Sourcing Committee, Responsible Sourcing Network’s Yarn Ethically & Sustainably Sourced, AAFA’s Social Responsibility Committee, and Responsible Business Alliance (RBA) Responsible Labor Initiative. We participate in industry conferences and stay current on the latest developments in social compliance and ethical sourcing. Finally, we benchmark ourselves against the programs of companies whose business models more closely relate to our own, as well as retailers whose business models differ significantly.

• Continuous Improvement

  The driving tenet of our Global Social Compliance Program is continuous improvement, as we believe this is in the interest of the workers in the facilities that we audit. We expect each of our merchandise vendors and agents to adhere to the expectations set forth in our Vendor Code of Conduct, and we also encourage them to make improvements throughout their operations. To advance these objectives, we do more than test compliance; we also provide education and training to our agents, vendors, and factory management within our audit program, so that they understand our expectations and can develop meaningful processes to meet and exceed these expectations.