Inadequate hiring practices are one of the most common challenges we see. When facilities do not have a formal hiring process, they are at higher risk of using unethical practices. We expect all facilities to have a human resources department and to enforce a policy that no candidate can be hired until approved by human resources. We do not allow exceptions, including those for temporary and contract workers. During our audit, we review personnel records and discuss the hiring process with management. We verify that they have a formal procedure in place that includes reviewing age documentation and eliminating high-risk candidates. We also make sure that they keep standard personnel files for all workers where information is readily available. If a facility does not meet these requirements, the auditor will review them with facility management and our headquarters team will communicate with the vendor. A follow-up audit is required to ensure that a formal process has been implemented.
Forced Labor and The California Transparency in Supply Chains Act
We identify risk of forced labor through our unannounced audit process and our audit history. We also closely monitor and collaborate with NGOs and other brands to identify and mitigate this risk. This topic is specifically covered in the training we provide internally and externally to all vendors in our program. If we find forced labor at any facility, we immediately deactivate the facility and do not accept any merchandise in production. We have taken a strong, public stance prohibiting the use of cotton produced in Uzbekistan, where it is public knowledge that forced labor is used in cotton production. We have a heightened awareness in the Middle East, where there are labor challenges related to migrant workers.
The California Transparency in Supply Chains Act of 2012 went into effect Jan. 1, 2012. Under this 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 that they can make informed decisions and purchase goods from companies that responsibly manage their supply chain. Target’s SOVE explicitly addresses these violations by stating zero tolerance for forced or compulsory labor.
Our other efforts include:
Requiring vendors to register all facilities that they use to produce our merchandise.
Requiring all Target-brand vendors to complete a human rights and compliance assessment as part of registration. If a vendor wants to use a supplier that has known audit issues, we require a completed corrective action plan to remediate issues before allowing production to take place.
Requiring vendors to complete certification, which includes instruction on our Zero-Tolerance policy.
Conducting random, unannounced audits at facilities producing Target-brand merchandise.
Providing mandatory training for all Target team members with supply-chain management responsibilities – social compliance, overseas and select TSS team members – with an emphasis on strong social-compliance management practices.
Target’s SOVE explicitly articulates our zero-tolerance policy for underage labor. We identify risk of underage labor through our unannounced audit process and our audit history. As part of an audit, we perform in-depth records and personnel file reviews and conduct employee interviews. This topic is covered in the training we provide internally and externally to all vendors in our program. Online training also is available on this topic. If we find underage labor at any facility, we immediately deactivate the facility and do not accept any merchandise in production. However, we also are partnering with Better Work to systematically address underage labor and remediate cases of underage labor when found. Underage labor does not seem to have a correlation to specific categories of production.
We expect all workers, including imported and migrant workers, to be provided wages, benefits and working conditions that are fair and in accordance with local law. We do not condone holding workers’ passports to keep them from leaving, charging any type of fee or deposit for employment, or any other unfair practice. We review these policies in detail during our audit process and expect our vendors to share these views and comply.
Target will not knowingly work with vendors or factories who use physical or mental punishment against their workers. Our auditors conduct multiple checks to ensure these practices are not occurring in the facilities, including interviews with employees about working conditions and disciplinary actions. If we identify corporal punishment, we consider it a zero-tolerance violation.
We respect cultural differences and believe decisions concerning hiring, advancement, disciplinary action or dismissal should be based on a worker’s abilities rather than his or her race, gender, personal characteristics or beliefs, and we encourage our vendors to eliminate discrimination in their workplaces. We also prohibit the use of pregnancy testing as a condition of employment or to terminate employment.
Working Hours and Time Off
Target expects a 60-hour maximum work week, including overtime, in all facilities—a guideline we adopted from the ILO. If local law differs, a facility must follow the stricter requirement. We also expect workers to receive a minimum of one full rest day after six consecutive work days. All facilities must use a mechanical or electronic time-keeping system to ensure time cards are accurate and completed by the employees themselves. During an unannounced audit, we review the two most recent pay-period records, cross-checking time cards and payroll documents to make sure they are accurate and in accordance with local law and Target standards. If we identify violations, we consider them critical and either will return for a re-audit or deactivate the facility for non-compliance, depending on where the audit is in the audit cycle.
Excessive working hours is still a widespread practice in many parts of the world. Workers often comply in order to make higher wages but are not paid legal wages for the regular hours that they work. Many factors lead to excessive working hours, including company purchasing decisions that impact production deadlines. To reduce the risk of occurrences, Target provides training to our team members who make sourcing decisions. We also offer extensive training for our vendors on working-hour reduction and management, and we expect them to communicate production challenges so that we can partner on a solution. We consider working-hour violations critical. If a facility is not able to meet local law and our requirements, we will deactivate the facility for a minimum of one year.
Payment of Wages
Target has a firm stance on the payment of wages and we will not knowingly work with factories or vendors who do not follow local law and our standards. During an audit, we do a thorough review of time card and payroll records to ensure workers were paid legal wages for all the hours they worked, including regular, overtime, holiday and vacation wages. During an audit, in addition to discussing wage policy with management, we make sure employees understand their wages, benefits and deductions. We also make sure they have access to their own records to verify their hours and wages, and that they know with whom to discuss discrepancies. We consider wage violations critical. If they do not meet our requirements and local law, we will deactivate the facility for a minimum of one year.
Facility and Dormitory Review
Health and safety violations have been an ongoing challenge and a major focus of our audit process. We conduct an in-depth review of a facility’s health and safety practices across all buildings, reviewing everything from fire safety equipment and preparedness to worker safety, such as clean facilities, the availability of personal protective equipment, chemical safety and employee training. An auditor will identify any violations during his or her tour and explain procedures for making and sustaining corrections. The auditor also will review health and safety training records and ensure that a facility has a schedule to provide regular training.
Target emphasizes the importance of having measures in place to ensure that factory workers know what to do in an emergency, as well as policies and procedures to prevent emergencies. We provide our vendors with a variety of training materials, many in multiple languages, to educate them on the importance of being proactive and making safety a priority.
In view of health concerns related to the use of sandblasting in garment processing, we conducted a study on its use and available alternatives. After thorough evaluation, we have banned the use of sandblasting on all future Target-brand apparel.
No Dirty Gold
We support the efforts of Oxfam and Earthworks with the “No Dirty Gold” campaign and reinforce this commitment through vendor education efforts as part of our social compliance program.
Conflict Minerals Policy
Target supports the humanitarian goals of the Dodd Frank Act and recognizes the adverse impact from mining and trade of Tin, Tungsten, Tantalum and Gold (3TG) by armed groups in the Democratic Republic of Congo (DRC) or an adjoining country. Furthermore, we seek neither, directly nor indirectly, to finance or benefit those armed groups. 3TG that are used to finance armed conflict in the DRC or an adjoining country are known as Conflict Minerals. Target will not knowingly purchase or sell any product if we have reason to believe that it contains any Conflict Mineral necessary to the production or functionality of the product.
In keeping with those goals, Target seeks to:
Educate our supply chain on the issues related to mining and trade in 3TG from the DRC or an adjoining country;
Require that all vendors who contract to manufacture products for Target containing 3TG complete a conflict minerals reporting template, which is the standard form developed by the Conflict-Free Sourcing Initiative for gathering information regarding 3TG usage and related sourcing procedures (the “Conflict Free Minerals Reporting Template”); and
Continue to work with our supply chain to improve transparency with the goal of neither, directly nor indirectly, financing or benefitting armed groups in the DRC or an adjoining country by purchasing or selling products containing Conflict Minerals.
Target expects that each of the vendors with which it contracts to manufacture will:
Adopt a policy relating to 3TG sourcing that is consistent with Target’s Conflict Minerals Policy and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition;
Implement a due diligence program in support of its 3TG sourcing policy;
Complete the Conflict Minerals Reporting Template;
Exercise due diligence in seeking upstream information to support the vendor’s responses to the questions in the Conflict Minerals Reporting Template;
Use smelters certified as being free of Conflict Minerals whenever sourcing 3TG mined in the DRC or an adjoining country; and
Make available its due diligence in determining the source of its 3TG upon Target’s request.
Target supports broader efforts to improve conditions in the DRC and its adjoining countries. We are a founding Executive Committee Member of the Retail Industry Leaders Association Conflict Minerals Program, a multi-year program that helps retailers navigate the issue, the compliance requirements, and solutions through a combination of educational materials, benchmarking, implementation tools, and key partnerships. As part of the Retail Industry Leaders Association Conflict Minerals Program, we developed common approaches for determining the source and chain of custody of 3TG, and worked with Business for Social Responsibility to develop training for our vendors.
Click here for a copy of Target’s Conflict Minerals Report
No Uzbek Cotton
Based on global concerns that forced child labor is being used in the cotton fields of Uzbekistan, and our ongoing commitment to no child labor, Target will not accept products that contain Uzbek cotton. To the best of our knowledge, Target does not currently source any products from Uzbekistan, nor do we use Uzbek cotton in textiles used to manufacture products from other countries. In addition, Target does not knowingly buy or sell products that contain cotton sourced from any country that condones the use of forced child labor. We require that our vendors not use cotton sourced from any country with a known record of forced child labor in its cotton fields, including Uzbekistan. We have shared this position with the U.S. government, NGOs and other industry leaders who have approached us with related concerns.