Audit Program
We expect all business partners to provide a safe and healthy working environment for workers.
Overview
Our risk-based Audit Program assesses manufacturing location conditions, worker treatment and compensation, hiring processes, environmental practices and compliance with applicable laws and Target’s Standards of Vendor Engagement (SOVE). All disclosed manufacturing locations must conduct regular audits and have them approved by our industry-aligned audit protocol. Because we believe in making a collective impact, we value common or shared audit programs, addressing issues that are too big for any one company to tackle alone through collaboration with others.
Scope
Our Responsible Sourcing & Sustainability Audit Program focuses on identifying health and safety violations and covers all facilities that manufacture or convert raw materials into:
- Target Owned Brand
- Limited Time Offer (LTO)
- Target Brand - No Brand
- Target Brand Non-Retail
- Vendor Brand Exclusive
- Non-branded product that is Vendor Brand Exclusive
- Nationally branded product for which Target is the importer of record
Oversight and industry-converged approach
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. Further feedback we received from suppliers is that, by accepting several audit programs, suppliers’ facilities are more proactive in identifying root causes of issues and making improvements that benefit workers. To support deeper visibility, we also increased our disclosure requirements, including requirements about manufacturing location disclosure and applicability. Target maintains the right to conduct unannounced audits of any disclosed location.
Continuous improvement
Target believes in supporting vendors’ continuous improvement in responsible sourcing performance. As part of our continuous improvement program, Target communicates audit results to our vendors and manufacturing locations and requires a detailed corrective and preventative action plan (CAPA). Our responsible sourcing team has ongoing discussions with suppliers as they address the CAPA requirements, focusing on steps taken, required timelines, manufacturing location accountability for ongoing monitoring, and long-term stability planning. An important part of this process is helping the vendor and manufacturing location identify the root causes of violations, so they do nor recur.
Also, Target supports continuous improvement through various initiatives to build our vendors’ capacity to manage and improve their own responsible sourcing programs.
Training programs
In 2022, our team delivered 28 training sessions focused on our SOVE and audit process, with over 5,000 attendees, and exceeding 9,000 training hours. In 2023, we had more than 2,000 suppliers attend our training webinars on 2024 SOVE updates, continuing education sessions on key compliance topics and new supplier onboarding sessions, respectively.
In 2022, we rolled out our first human rights training to key business areas, including merchandising, owned brands, sourcing and corporate responsibility. The training covered an overview of business and human rights and Target’s approach, including our human rights statement and business operations and supply chain due diligence efforts.
Disclosure
All factories/locations manufacturing or converting raw materials or components into Target owned brand products and packaging, Target exclusive products, Target-distributed products and/or nationally branded products for which Target is the importer of record are required to disclose locations to Target and participate in Target’s Responsible Sourcing & Sustainability Audit Program.
The risk-based program assesses manufacturing location 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 location.
Audits, protocols and resources
The purpose of Target’s Responsible Sourcing & Sustainability Audit Program is to assess manufacturing location conditions, worker treatment and compensation, hiring processes, environmental practices and, more generally, compliance with applicable laws and Target’s SOVE.
All disclosed manufacturing locations must conduct an approved audit as part of Target’s industry aligned audit protocol. Factories must submit one of the following responsible sourcing audits as applicable to their industry on a regular basis: amfori Business Social Compliance Initiative (BSCI), Better Work, Equitable Food Initiative (EFI), Ethical Supply Chain Program (ESCP), Responsible Business Alliance (RBA), Fair Trade USA, Sedex Members Ethical Trade Audit (SMETA) 4 Pillar, and the Social Labor Convergence Program. Target maintains the right to conduct unannounced audits of any disclosed location.
In addition, all factories in scope of the Higg Facilities Environmental Module (FEM) must complete the self-assessment annually. All Tier 1 and Tier 2 factories producing Target owned-brand products, as well as national brand where Target is the importer of record, are in scope of the Higg FEM self-assessment. Excluded are factories regulated by the Food and Drug Administration (FDA) and the United States Department of Agriculture (USDA). Additional information on Target’s participation in Cascale and The Higg Index can be found on our Traceability & Transparency page.
All in-scope Tier 2 manufacturing locations must meet the requirements of the Institute of Public & Environmental Affairs (IPE) to build a green supply chain in China. Each manufacturing location must comply with IPE requirements and remediate any issues that may be identified.
If any issues are found during verification by a third-party, we tailor our response to the circumstances. Some Zero Tolerance and Critical Issue violations could deactivate the manufacturing location from our list, while for other issues, we will work with the supplier to help them achieve compliance within an agreed-upon period.
Audit ratings, violations and consequences for non-compliance
Target’s responsible sourcing team reviews every audit and determines the results based upon the findings presented. We categorize violations as Non-Critical, Critical and Zero Tolerance depending on their severity. We categorize audit results as Outstanding, Acceptable, Needs Improvement and Non-Compliant. An audit is ‘Outstanding’ if compliance is demonstrated with no or very few issues. An audit is ‘Acceptable’ if a few Non-Critical violations are identified. ‘Needs Improvement’ findings result when several of Non-Critical violations are identified.
A manufacturing location is non-compliant if:
- Zero Tolerance violations are discovered, including: underage labor, prison or forced labor, corporal punishment, discrimination, harassment, bribery, sandblasting, unauthorized subcontracting, egregious wastewater treatment and/or absence of appropriate licensing/permitting;
- Critical issues are identified;
- An excessive number of violations are discovered; or
- A Target team member or Target representative is denied access to a manufacturing location for a second time.
We prioritize remediation and continuous improvement but, in some cases, non-compliant audits may result in the cancellation of purchase orders and the termination of business relationships.
Target will not allow a vendor to use a previously non-compliant manufacturing location until the deactivation period has expired and the manufacturing location has demonstrated compliance with Target’s SOVE and applicable laws. The formal reinstatement process involves a review of an audit protocol recognized by Target to validate that the issues were satisfactorily remediated.
Prioritizing health and safety
Providing a safe and healthy working environment for workers is a key expectation for our vendors. The Responsible Sourcing & Sustainability Audit Program focuses on health and safety violations to minimize safety risks.
Target also participates in industry-led initiatives like Nirapon and Life and Building Safety (LABS) to enhance worker safety and create a culture of minimizing occupational hazards in our supply chain.
Target is a founding member of LABS, a global apparel and footwear industry initiative which seeks to find and address building safety risks related to structural, electrical, fire safety and evacuation preparedness. Currently, LABS operates in Vietnam, Cambodia, India and Indonesia.
Nirapon is an industry-led nonprofit that collaborates with global brands, retailers, manufacturers and NGOs to create and sustain a culture of workplace safety in Bangladesh factories. This organization also aims to support workers’ human rights, protect factories’ most valuable assets, instill confidence in global companies sourcing from Bangladesh and drive the growth of an ethical manufacturing industry.