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 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 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 register their production facilities with Target.  

The risk-based program assesses facility conditions, worker treatment and compensation, hiring processes, environmental practices and compliance with applicable laws and Target’s SOVE. All disclosed manufacturing locations must conduct an audit that is approved as part of Target’s industry-aligned audit protocol on a regular basis. 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), ICTI Ethical Toy Program, or Responsible Business Alliance. Apparel, accessories, footwear and nominated tier 2 facilities are required to participate in Better Work or SLCP. 

During the coronavirus pandemic, travel and factory restrictions, as well as office closures related to COVID-19, decreased the ability for on-site audits to be conducted in many regions globally. Reflective of these ongoing impacts and the changing industry landscape, Target is further 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 2020, our audit penetration rate was 42.3% and last year these numbers increased by more than 28% YoY, resulting in a penetration rate of 70.43% for 2021.

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. In light of 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 where produced. Additionally, Target may choose to prohibit the use of cotton from certain geographies in Target products due to consumer preferences, sustainability considerations, supply chain instability or other economic reasons.

Additionally, as part of our commitment to sourcing fresh and frozen seafood and canned tuna sustainably, 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 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 (visit the website). In recognition of our adoption and commitment to the Employer Pays Principle in 2017, Target was admitted into the IHRB’s Leadership Group for Responsible Recruitment (visit the website). The Leadership Group is a collaboration between leading companies and expert organizations committed to improving global recruitment practices of foreign contract workers.

Additionally, we are actively engaging our supply chain partners to collaboratively implement preventative programs with the International Justice Mission. 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 facility used by one of our vendors in Malaysia. Although we were no longer doing business with the facility for unrelated reasons, we took swift action. Those actions entailed working with the facility’s other customers and a credible third-party expert in forced labor to validate the claims and then partnering with our vendor, the facility 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 facility’s 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 (for more detail, review the Ethical Recruitment Case Study (opens as a PDF) on the Impactt website here (opens as a PDF)).

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, 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 facility audits. We use a variety risk intelligence sources, and focus on the operating conditions of the country as well as 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 facility 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 2022. 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 or our qualified, third-party audit partners conduct facility audits at registered facilities to verify our suppliers’ compliance with Target’s Standards. For more information about Target’s supplier assessments, review Target's Comprehensive Social Compliance Audit Process. We also regularly conduct product safety and quality assurance audits as well as CTPAT 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 internal and independent third-party investigators.

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 and accordingly, we expect our suppliers to remediate indicators when identified. 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. 

Every year since 2016, we have reiterated to our suppliers, in writing, Target’s policy and expectations regarding forced labor. We have also reiterated that this policy and expectation extends not only to our suppliers’ own operations and production facilities, but to their upstream material and component suppliers as well.


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 facility, we will work quickly to assess the situation and evaluate a variety of factors including the supplier’s and facility’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 facility, 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 facility. For additional information related to supplier performance, probation/termination processes and training, 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 issues raised by workers within our suppliers’ production facilities. 

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 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. 
In 2021 we launched an evidence-based assessment with more than 550 business partners to evaluate their management system maturity and create a deeper understanding of their capabilities for managing social and environmental performance. The results of the assessment are paired with eLearning and coaching options from Target to support business partners in creating organizational development plans that will strengthen and mature management systems, enabling consistent compliance with our expectations to our expectations. For example, last year Target’s Oversight & Remediation team supported tailored remediation activities and delivered 17 distinct training programs for suppliers and internal teams, with 6,558 training hours logged and 3,155 total participants.

Also in 2021, Target launched new training for all Merchandising employees covering Target’s Code of Conduct for business partners and our Standards of Vendor Engagement. This same audience also received new training in 2022 on Human Rights in support of Target’s commitment to Human Rights. Also in 2022, we delivered a 3-part, in-depth training on Human Rights and Grievance Mechanisms designed for those employees who work most closely with external suppliers, vendors and other business partners in their roles.

Additionally, starting in 2021, we expanded the audience for our foundational training to be enterprise-wide. We also require all team members to comply with our Code of Conduct, 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 facility education guide that includes a social compliance section. Target also provides in-person, in-facility and classroom training options for a variety of compliance topics, including forced labor and human trafficking. 

For example, Target collaborated with Verité to conduct trainings in select markets specifically on the topics of responsible recruitment and ethical management of foreign contract workers. Our training materials emphasize strong social compliance management practices and focus on preventing and managing related issues, including human trafficking and forced labor.

For additional information and further detail regarding Target Forward, our enterprise sustainability strategy, visit our corporate website.

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