social compliance audit process

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 and Sustainability audit program. 

Audit Purpose, Protocols and Resources 

The purpose of Target’s responsible sourcing audit program is to assess factory conditions, worker treatment and compensation, hiring processes, environmental practices and more generally, compliance with applicable laws and Target’s Standards of Vendor Engagement. All  disclosed manufacturing locations are required to conduct an audit that is approved 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: 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. Target maintains the right to conduct unannounced audits of any disclosed locations.

In addition, all factories in scope of the Higg Facilities Environmental Module (FEM) must complete the self-assessment on an annual basis. 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 the Sustainable Apparel Coalition and The Higg Index can be found here.

Violations, Audit Results and Consequences for Violations 

Target’s Responsible Sourcing Team reviews every audit and determines the final 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 Acceptable, Needs Improvement, and Non-Compliant.  An audit is ‘Acceptable’ if few Non-Critical violations are identified. ‘Needs Improvement’ findings result when a sufficient number of Non-Critical violations are identified. 

A factory is Non-Compliant if:

  • Zero Tolerance violations are discovered, including: underage labor, forced labor, corporal punishment, attempted 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 factory

Non-compliant audits may result in the cancellation of purchase orders up to the termination of the business relationship.

Target will only allow a vendor to use a previously Non-Compliant factory once the deactivation period has expired and provided they can then satisfactorily demonstrate compliance with Target’s Standards of Vendor Engagement and applicable laws. The formal reinstatement process involves a review of an audit protocol recognized by Target to validate the issues were satisfactorily remediated.

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 factories and requires a detailed corrective and preventative action plan (or CAPA). Our responsible sourcing team has ongoing discussions with suppliers as they address the CAPA requirements, focusing on steps taken, required timelines, factory accountability for ongoing monitoring, and long-term stability planning. An important part of this process is helping the vendor and factory identify the root causes of violations so they don’t recur. Additionally, Target supports continuous improvement through a variety of Initiatives to build our vendors’ capacity to manage and improve their own Responsible Sourcing programs.

 

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