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 and
Business Partner Code of Conduct, which our suppliers are subject to as a condition of doing business with Target.
On November 14, 2016, we
announced our enhanced efforts to monitor for forced labor within Target’s supply chain and our commitment to take swift action when indicators are discovered. Target, through the engagement of reputable, third-party auditors, verifies compliance with Target’s
Standards for Vendor Engagement for all 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 whom are required to disclose their production factories with Target.
The risk-based program assesses factory conditions, worker treatment and compensation, hiring processes, environmental practices and compliance with applicable laws and Target’s SOVE. All disclosed factory locations in scope of Target’s Audit Program must regularly schedule and complete an approved scheme audit as part of Target’s industry-aligned audit protocol. Target maintains the right to conduct unannounced audits of any disclosed locations.
Factories must submit one of the following responsible sourcing audits as applicable to their industry on a regular basis: Social Labor Convergence Program (SLCP), Better Work, Business Social Compliance Initiative (BSCI), Sedex Members Ethical Trade Audit (SMETA), Ethical Supply Chain Program, or Responsible Business Alliance. Apparel, handbags, footwear and nominated tier 2 factories are required to participate in Better Work or SLCP.
Based on a changing industry landscape, Target is evolving its oversight approach to go beyond compliance, including implementing an industry-converged approach to assessment, and introducing more direct worker reporting channels and other real-time insights to understand emerging business and human rights risk. In 2022, our audit penetration rate was 79% and in 2023 it increased to 80%.
Stakeholder Engagement
Our
Standards of Vendor Engagement condemn and prohibit the use of forced, trafficked, or incarcerated labor by our suppliers, which is an expectation that extends to how and from whom they procure their raw materials and product components. Target does not knowingly buy or sell products that are made, in whole or in part, using forced or underage labor. Moreover, our vendors and their suppliers are prohibited from using forced or underage labor to produce their goods for Target in accordance with the requirements of Target's
Standards of Vendor Engagement.
We pay particular attention to, and perform additional due diligence around, indicators of forced labor in relation to commodities representing higher risk, such as cotton and seafood.
For example, in 2010 Target adopted the Responsible Sourcing Network’s No Uzbek Cotton pledge to help eliminate forced labor and human trafficking within the global textile supply chain. Considering the human rights monitoring in 2021 that indicated an end to systemic forced labor in Uzbekistan, The Cotton Campaign ended their call for a global boycott of Uzbek cotton, a decision supported by the ILO. In alignment with this recommendation, Target decided to lift our Uzbek cotton ban in May 2022. In 2018, we updated Target’s policy to include a ban on Turkmen cotton and in 2020 we prohibited products containing cotton originating in the Xinjiang province of China, regardless of where produced.
Additionally, as part of our commitment to sourcing fresh and frozen seafood, canned tuna sustainably, and Owned Brands pet food seafood ingredients, we continue to enhance labor standards in seafood supply chains. In 2021, we updated our seafood commitment to include new worker protections and have collaborated with Verité to conduct in-depth foreign contract worker assessments at all Tier 1 seafood-processing factories that employ foreign contract workers.
In addition to our efforts focused on Target’s supply chain, we also regularly collaborate with NGOs, brands, governments, international organizations, and other expert stakeholders to help advance working conditions and eliminate forced labor from the global supply chain more broadly. Target is a proud member of the
IHRB Leadership Group for Responsible Recruitment - an initiative of the Institute for Human Rights and Business—where we utilize our collective influence, voice, and size to push for improved recruitment systems globally. We are committed to the Employer Pays Principle and have helped to return significant sums to workers around the world through reimbursement of recruitment expenses. We are also working toward ensuring that workers pay no fees to secure jobs from the start.
Target is also an active member of several industry and trade association forced labor working groups, such as the Commercial Customs Operations Advisory Committee (COAC) on Forced Labor and the Forced Labor Working Group of the joint trade associations AAFA, RILA, USFIA, FDRA and NRF. Additionally, 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. Beginning in 2022, we partnered with
Work Better Innovations to implement a forced labor prevention initiative for small- and medium-sized businesses in Taiwan. The project included the creation of a bilingual policy guide based on the ILO’s 11 Indicators of Forced Labor and a series of three training exercises in Taiwan that were open to companies across various industries. We also routinely seek input from experts such as Verité and Impactt as well as other organizations within the CSO and NGO communities, to help ensure Target’s evolving policies and oversight practices are effective in helping identify and eliminate unfair, unethical, or illegal working conditions and/or labor practices, including the use of forced labor. Moreover, when stakeholders share information with us related to potential forced labor circumstances, we listen.
For example, in early 2018, the NGO Transparentem shared with Target that they had identified indicators of forced labor at a factory used by one of our vendors in Malaysia. Although we were no longer doing business with the factory for unrelated reasons, we took swift action. Those actions entailed working with the factory's other customers and a credible third-party expert in forced labor to validate the claims and then partnering with our vendor, the factory, and its other customers to develop and implement a corrective action plan to address the issues. That work included, among other things, returning passports to the foreign contract workers employed there, requiring reimbursement to workers for the recruitment fees they paid to secure their jobs in violation of the Employer Pays Principle, and overhauling the factories management and hiring practices to ensure the issues would not recur.
Now that remediation is complete and the indicators eliminated, we believe the overall effort will serve as a model for collective, multi-stakeholder remediation, both for Target and other importers, when indicators of forced labor are discovered in the supply chain.
Verification of Product Supply Chains
All manufacturing locations producing Target Owned Brand, Target Exclusive, and nationally branded goods for which Target is the importer of record must be fully disclosed in Target’s systems before production may begin. As part of our efforts to verify our suppliers’ compliance with Target’s
Standards for Vendor Engagement and applicable laws, each of those production factories must complete a compliance questionnaire as part of the registration process, freely and cooperatively submit to responsible sourcing audits conducted by Target approved third-party auditor partners and submit those audit reports to Target. Target utilizes a risk-based approach in supply chain verification efforts, including how we prioritize factory audits. We use a variety of risk intelligence sources and focus on the country's operating conditions and any product-specific risks. 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.
In addition to our standard audit process, we also manage supplemental oversight programs in areas of elevated risk. An example of this is our Responsible Recruitment program. We assess workforce demographic risks, and where appropriate, deploy experienced auditors with deep knowledge to conduct a supplemental assessment specific to foreign contract workers and supplier recruitment practices. This supplemental assessment includes reviewing hiring practices, interviewing labor agencies, analyzing migrant worker conditions, auditing living accommodations and generally understanding the migrant worker employment experience at a given factory, and we take action on the findings.
We understand that risk also exists further back in the supply chain which is why we have designed and deployed a Traceability program, starting with cotton-based products. Target’s initial traceability focus is on cotton due to its prevalence in our assortment, the regulatory requirements associated with cotton and our public commitment to source cotton more sustainably for our products by the end of 2025. To meet our goal, we aim to achieve full visibility into where the cotton for our owned brand and national brand import vendors’ products is grown. We aspire to continuous improvement within the interconnected supply chain through collaboration with farmers and brands, as well as other retailers and organizations who share our commitment. We also intend to track and validate our progress and share in our annual ESG report.
Supplier Audits
Target designated third-party audit partners conduct factory audits at registered Tier 1 factories and nominated Tier 2 factories to verify our suppliers’ compliance with Target’s
Standards for Vendor Engagement. For more information about Target’s supplier assessments, review Target's
Comprehensive Audit Program.
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 United States as well as their country of origin. Target’s
Standards for Vendor Engagement expressly prohibit our suppliers from utilizing any forced or compulsory labor and accordingly, we expect our suppliers to remediate indicators when identified. This policy and expectation extend not only to our suppliers’ own operations and production factories, but to their upstream material and component suppliers as well.
For additional information, review our
Labor & Human Rights policies. Target will not do business with a vendor that fails to warrant compliance with all applicable laws.
Accountability
In the spirit of continuous improvement, Target’s approach to forced labor is consistently evolving as we adopt proven methods, and partner with reputable experts and specialized service providers, to help discover and eradicate it from our supply chain. If forced labor indicators are found in a supplier’s production factory, we will work quickly to assess the situation and evaluate a variety of factors including the supplier’s and factory’s ability to remediate, the feasibility of providing meaningful remedy to impacted workers and the likelihood of sustained improvement.
When remediation is achievable, the supplier is required to work with the factory, in consultation with Target and industry experts, to develop and implement an appropriate corrective action program in keeping with our ‘do no harm’ aspiration. If the situation is not conducive to remediation, then we will work to disengage responsibly from a factory. For additional information related to supplier performance, probation/termination processes and training, review
Target's Responsible Supply Chains.
Target also makes an
Integrity Hotline available to Target team members, our suppliers, and the workers in our suppliers’ production factories. 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 issues raised by workers within our suppliers’ production factories.
When worker allegations are received, they are investigated by our global investigations team in partnership, when needed, with independent investigation firms. At the conclusion of the investigation, Target takes appropriate actions considering the findings consistent with Target’s
Standards for Vendor Engagement. Such actions may range from corrective action plans and remediation to the discontinuation of the business relationship.
Target Team Member and Supplier Training
Our training programs focus strengthening social and environmental compliance management practices and mitigating and managing risk. Target has a large library of social and environmental compliance training available for supplier and factory education. We also provide in-person and online training options on a variety of topics, including forced labor, human trafficking, and responsible recruitment. We request an evidence-based self-assessment for Owned Brands vendors, launched in 2021, to evaluate their management system maturity and social and environmental capabilities and performance. The results of the assessment are paired with E-Learnings and coaching to support business partner capability building. In 2023 Target’s Oversight & Performance Elevation team supported tailored remediation activities and delivered 14 distinct training programs for suppliers and internal teams, with 21000+ training hours logged and 12000+ total participants.
Target’s Responsible Sourcing & Sustainability team offers ongoing live training opportunities on various social and environmental topics to internal team members. Beginning in 2021, Target began launching new annual E-Learning trainings for Merchandising and Sourcing. As of 2024, these trainings cover
Business Partner Code of Conduct and our
Standards of Vendor Engagement, Foundations of Human Rights, Manufacturing Location Disclosure, and Responsible Exit and Decline. In 2022, a live, in-depth Grievance Mechanisms training was delivered to internal team members working closely with external suppliers.