Inadequate hiring practices are one of the most common challenges encountered in the industry. When facilities do not have a formal hiring process and controls in place, they are at higher risk of using unethical practices. Target expects all facilities to have a functioning human resources department that enforces the policy that no candidate can be hired until approved by human resources. We do not allow exceptions, including those for temporary, migrant and contract workers. During the responsible sourcing audit, personnel records are reviewed and the hiring process is discussed with management. Through this process, verifciation of established formal procedures ensuring review of age documentation, vetting of labor brokers and safeguarding of high-risk candidates, is undertaken. Maintenance of standard personnel files for all workers where information is readily available is also confirmed. Finally, Target reviews that all facilities are upholding the Employer Pays Principle, reiterating the expectation that the costs of recruitment are paid by the employer-- not the worker. A follow-up audit is conducted to ensure that a formal hiring process has been implemented.
Forced Labor and The California Transparency in Supply Chains Act
We identify risk of forced labor through our responsible sourcing audit process, audit history and a variety of risk intelligence sources. We also closely monitor and collaborate with NGOs and other brands to identify and mitigate these risks. If we find credible indicators of forced labor at any facility, we prioritize the wellbeing of the workers, which means that where possible, we strive to frame and implement a corrective action plan that will facilitate the remediation of the indicators and a continuiation of the business relationship once remediation is complete. Only when remediation is not possible, we will work with the appropriate stakeholders to develop a responsible disengagement strategy and intended to mitigate additional harm to the workers. See our California Transparency in Supply Chains Act for more information.
Target’s SOVE explicitly articulates our zero-tolerance policy for underage labor. As part of an audit, we perform in-depth records and personnel file reviews and conduct employee interviews. If we find underage labor at any factory, we immediately review all aspects of the situation, and where possible, we work with a credible 3rd party expert to develop and implement a comprehensive remediation plan in line with internationally defined best practices. If the remediation is unsuccessful or not possible, we deactivate the factory for non-compliance. In all cases, we do not accept any merchandise in production. Additionally, we also partner with Better Work and Goodweave in countries where they operate to systematically address underage labor and remediate cases of underage labor when found in the apparel and rug industries, respectively.
We expect all workers, including foreign and domestic migrant workers, to be provided wages, benefits and working conditions that are fair, comperable to local workers and in accordance with local law. We do not condone holding workers’ passports or other personal documents, charging any type of fee or deposit for employment, allowing labor agents or brokers to charge fees or engaging in deceptive recruitment practices. We review these policies in detail during our audit process and expect our vendors to share these views and comply.
Target expects that all employees are treated with dignity and respect. Target will not knowingly work with vendors or factories who use physical abuse or intimidation against their workers. Our assessors 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 and individual differences and discrimination is not tolerated. Vendors and factories are expected to maintain a discrimination-free workplace and to employ workers based upon on their abilities, rather than their race, color, sex, pregnancy status, gender identity, marital status, political opinions, religion, age, disability, sexual orientation, social origin, national origin or any other characteristics unrelated to an individual’s ability to perform the work required by the job. 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. 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. Both guidelines we adopted from the ILO. 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 recent payroll records, cross-checking time cards to make sure they are accurate and in accordance with local law and Target standards. If we identify violations, we consider them critical.
Excessive working hours is a widespread practice in many parts of the world. Workers often comply in order to earn higher wages but are not always paid the appropriate legal overtime. Many factors lead to excessive working hours, including company purchasing decisions that impact production deadlines. Target asks vendors to communicate production challenges so that we can partner with sourcing team members to develop solutions and prevent recurrences. We consider transparency of paramount importance and in exceptional cases, when facilities demonstrate transparency, we may suspend deactivation for violations of excessive overtime if it can be established to our satisfaction that the overtime was voluntary, paid at a premium and where a corrective action plan has been agreed to that will eliminate instances of non-complinace in the future. If a facility is not able to meet local law or attempts to circumvent Target's requirements through falsification, forgery or withholding information the factory will be deactivated for a minimum of one year.
Payment of Wages
Target has a firm stance on the payment of wages and will not tolerate when factories or vendors do not follow local law and our standards related to the payment of wages. 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 and that those wages were paid timely. During an audit, in addition to discussing the 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.
Target expects suppliers to implement effective grievance mechanisms to resolve internal disputes and employee complaints. Legitimate and effective grievances procedures have legitimacy and are accessible, predictable, equitable, transparent, rights-compatible, confidential, based on engagement and dialogue, and are used as a source of continuous learning.
Health and Safety Review
Health and safety violations have been a major focus of Target's responsible sourcing audit process. We conduct an in-depth review of a facility’s health and safety practices across all buildings, reviewing fire safety equipment and preparedness to worker safety, such as clean facilities, the availability of personal protective equipment, chemical safety and employee training. An assessor will identify any violations during the tour of the factory and explain procedures for making and sustaining corrections. The assessor also will review health and safety training records and ensure that a facility has a schedule to provide regular training to workers.
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.
Target was a founding member of the Alliance for Bangladesh Worker Safety. The Alliance, which helped improve fire safety, electrical safety and the structural integrity of buildings, audited all factories used by Target in Bangladesh. Additionally, the Alliance also provided worker training on fire safety and has launched a help line for workers to express safety concerns in Bangladesh.
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 Target-brand apparel.
Conflict Minerals Policy
Target supports the humanitarian goals of the U.S. Conflict Minerals Rule and recognizes the adverse impact from mining and trade of tin, tungsten, tantalum and gold (3TG) by armed groups in the Democratic Republic of the Congo (DRC) and its adjoining countries. Target seeks neither, directly nor indirectly, to finance or benefit armed groups. Accordingly, we will not knowingly purchase or sell any owned or exclusive brand product that contains 3TG that finances armed conflict in the DRC or an adjoining country.
Target recognizes that there are many smelters and refiners that source from the DRC and its adjoining countries whose activities do not finance or benefit armed groups and who are certified as “conformant” by the Responsible Minerals Initiative (“RMI”) or the equivalent by another recognized independent certification organization. In order to avoid the undue harm to local populations that a generalized embargo upon this region could perform, Target encourages its suppliers to identify compliant smelters and refiners within the DRC and its adjoining countries and to source from them when commercially practicable.
In keeping with those goals, Target seeks to:
- Educate our supply chain on the responsible sourcing of 3TG from the DRC and its adjoining countries;
- Obtain from vendors who contract to manufacture products for Target containing 3TG a completed Conflict Minerals Reporting Template, which is the standard form developed by the RMI regarding 3TG usage and related sourcing procedures (the “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 3TG that supports or benefits these groups.
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: Third Edition;
- Complete the Reporting Template;
- Exercise due diligence in seeking upstream information to support the vendor’s responses to the questions in the Reporting Template;
- Use smelters and refiners certified as conformant by the RMI or the equivalent by another recognized independent certification organization, but avoid a generalized embargo of smelters or refiners in the DRC region; and
- Make available its due diligence in determining the source of its 3TG upon Target’s request.
Target was engaged in early efforts to further responsible sourcing of 3TG. Target was a founding Executive Committee Member of the Retail Industry Leaders Association Conflict Minerals Workgroup, a multi-year program that helped retailers navigate the issues, compliance requirements, and solutions through a combination of educational materials, benchmarking, implementation tools, and key partnerships. Target worked with Business for Social Responsibility to develop training for vendors. Target continues to be engaged with multi-stakeholder initiatives that encourage responsible 3TG sourcing and is a member of and participates in the RMI.
Click here for a copy of Target’s Conflict Minerals Report
No Uzbek or Turkmen Cotton
Target does not knowingly buy or sell products that were made, in whole or in part, using forced or underage labor. Moreover, our vendors are prohibited from using forced or underage labor to produce their goods in accordance with the requirements of Target’s Standards of Vendor Engagement. Because forced and underage labor is actively being used in the cotton fields of Uzbekistan and Turkmenistan, Target will not accept products containing Uzbek or Turkmen cotton, regardless where produced. Additionally, because of the global concerns that Uzbek cotton is frequently utilized to manufacture textile products in Bangladesh, Target will not accept any products that contain 1) Uzbek cotton or 2) Cotton or cotton-blended fabric that was knit or woven in Bangladesh or 3) Cotton or cotton-blended sweater yarn produced in Bangladesh. Target continually monitors and assesses the risks associated with, among other things, certain products, various raw materials and regions of production. As a result, our sourcing policies are subject to change at any time and in Target’s sole discretion.