CA Transparency in Supply Chains Act

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On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect in the State of California. Under the law, large manufacturers and retailers are required to disclose their efforts to eradicate slavery and human trafficking within their supply chains. The law’s underlying purpose is to educate consumers, so they can make informed decisions and purchase goods from companies that responsibly manage their supply chains.

At Target, we hold ourselves and our vendors accountable to high ethical standards wherever we do business. Target works diligently to ensure Target’s products are produced ethically by our suppliers and in accordance with Target's Standards of Vendor Engagement (“Target’s Standards”) and Target's Vendor Conduct Guide, which our suppliers are subject to as a condition of doing business with Target.  We recently made a commitment to our guests to enhance our efforts to ensure Target products are made ethically and responsibly.  On November 14, 2016, we announced Target’s Responsible Sourcing Aspirations for 2020, which includes enhanced efforts to monitor for forced labor within the supply chain and a commitment to take swift action to eliminate it if discovered.  Today, Target undertakes social compliance verification efforts for our suppliers producing Target owned-brand goods, Target exclusive goods and for all national brand products for which Target is the importer of record, all of which are required to register their production facilities with Target.  In 2016, we conducted nearly 1,600 unannounced social compliance audits of the registered production facilities.  In 2017, with the implementation of our enhanced efforts, we increased that number by over 10%.     

In addition to our efforts focused on Target’s supply chain, we also regularly collaborate with NGOs, brands and other expert stakeholders to help identify and eliminate forced labor from the global supply chain more broadly. For example, Target adopted the Responsible Sourcing Network’s No Uzbek Cotton pledge in 2010, and since 2016 we have actively engaged with the Seafood Task Force in an effort to eliminate forced labor and human trafficking within the global textile and seafood supply chains respectively. Target is also an active member of the Consumer Goods Forum Social Sustainability Committee devoted to working on a Forced Labor resolution, and we are a founding member of the Responsible Business Alliance’s Responsible Labor Initiative. Additionally, we are actively engaging our supply chain partners to collaboratively implement preventative programs such as Elevate’s Laborlink and the Ethical Trading Initiative’s Nalam Spinning Mill Program. And finally, we routinely seek input from experts such as Verite and other organizations within the CSO and NGO communities, to help ensure Target’s evolving policies and oversight practices are effective in helping eliminate unfair, unethical or illegal working conditions and/or labor practices, including the use of forced labor.    

Verification of Product Supply Chains
All production facilities manufacturing Target owned-brand goods, Target exclusive goods and nationally-branded goods for which Target is the importer of record must be registered before Target will accept goods produced there.  As part of our efforts to verify our suppliers’ compliance with Target’s Standards and applicable laws, each of those production facilities must complete a human rights and compliance questionnaire as part of the registration process and authorize unannounced compliance audits. Target utilizes a risk-based approach in our supply chain verification efforts, including how we prioritize our unannounced facility audits.  Our main focus is the general conditions of the country where the goods are produced.  We also leverage an internal, cross-functional team of company leaders and compliance personnel to evaluate proposed shifts or expansions in overseas production to ensure regional and/or commodity-related risks are accurately identified and appropriately weighed.         

Supplier Audits
Target or our qualified, third-party auditors conduct unannounced facility audits at registered facilities to verify our suppliers’ compliance with Target’s Standards, and we prioritize the higher risk facilities. For more information about Target’s supplier assessments, please review Target's Comprehensive Social Compliance Audit Process.  We also regularly conduct product safety and quality assurance audits as well as C-TPAT supply chain security audits (as part of the Customs and Trade Partnership Against Terrorism program, of which Target is a founding member) at our suppliers’ facilities.  Quality/safety and security auditors are trained to spot potential social compliance concerns (including indicators of forced labor) and to escalate them for further investigation by our global investigations’ and responsible sourcing teams.      

Certification of Compliance with Laws
As an additional condition of doing business with Target, all our suppliers warrant that the products they supply to Target are manufactured in accordance with all applicable laws, regulations and standards – both of the United States as well as their country of origin. Target’s Standards expressly prohibit our suppliers from utilizing any forced or compulsory labor. They also mandate that workers receive wages and benefits in compliance with all applicable laws. For additional information, please review our Labor & Human Rights policies. Target will not do business with a vendor that fails to warrant compliance with all applicable laws.  Moreover, Target will cease doing business with any production facility that fails to live up to those promises.  In 2016 and 2017, we also reiterated, in writing, Target’s zero-tolerance policy regarding forced labor to all suppliers producing Target owned brand, Target exclusive and national brand product for which Target is the importer of record, which is a message we intend to emphasize annually.  We also reiterated that this policy and expectation extends not only to our suppliers’ own operations and production facilities, but to their material and component suppliers as well.

Target has a zero-tolerance policy regarding any suppliers’ use of forced labor.  If forced labor is found in a supplier’s production facility, the facility is deactivated from Target’s approved factory list and any merchandise in production there will not be accepted.  For additional information related to supplier performance, probation/termination processes and training, please review Target's Social Compliance Operations. Target also makes an Integrity Hotline available to Target team members, our suppliers and the workers in our suppliers’ production facilities. The purpose of the Integrity Hotline is to provide a vehicle for anonymously reporting concerns dealing with potentially unfair, unlawful or unethical business practices and to maintain a system through which Target can investigate claims and address complaints.  The system has been an effective mechanism for identifying and remediating issues raised by workers within our suppliers’ production facilities.  When received, worker allegations are investigated by our overseas’ and global investigations’ teams.  At the conclusion of an investigation, Target takes appropriate actions in light of the findings, consistent with Target’s Standards.  Such actions may range from Corrective Action Plans and remediation to the discontinuation of the business relationship.         
Target Team Member and Supplier Training
Target administers mandatory training for team members responsible for sourcing and merchandising decisions on an array of topics, including Target’s Standards and Target’s Social Compliance program. We also require all team members to comply with our Business Conduct Guide, which includes an annual review of Target’s Standards. Target has an extensive library of social compliance training available for our suppliers, as well as a factory education guide that includes a social compliance section. Our training materials emphasize strong social compliance management practices and focus on preventing and managing related issues, including human trafficking and forced labor.   

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