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, verification of established formal procedures ensuring review of age documentation, vetting of labor brokers and safeguarding of high-risk candidates are 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.
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 well-being 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 continuation of the business relationship once remediation is complete. Only when remediation is not possible will we work with the appropriate stakeholders to develop a responsible disengagement strategy whereby we intend to mitigate additional harm to the workers. See our 2022 California Transparency in Supply Chains Act disclosure for more information.
Target’s Standards of Vendor Engagement explicitly articulate 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 third-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 if we believe the merchandise was made with underage labor. 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, comparable 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 corporal punishment is identified, 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 as a reason 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 workdays. Both guidelines we adopted from the International Labour Organization. All facilities must use an effective timekeeping system to ensure timecards are accurate and completed by the employees themselves. During an unannounced audit, we review recent payroll records, cross-checking timecards to make sure they are accurate and in accordance with local law and Target standards. If we identify violations, we consider them Critical under the Responsible Sourcing Audit Program.
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-compliance 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 six months.
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 timecard 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.
We are committed to providing Target team members, workers in our supply chain, community members and other stakeholders with access to effective grievance mechanisms. We expect our business partners to share any ethical concerns or potential misconduct so that we can investigate and address concerns promptly. These mechanisms are an important aspect of our ongoing human rights due diligence, and our strategic focus on promoting workers’ voices and well-being. We believe the most effective way to ensure respect for human rights and good working conditions is to enable and empower individuals to speak up.
Training, governance & programs
Our Ethics and Responsible Sourcing & Sustainability teams conduct ethics training(s) with business partners worldwide. This training promotes the Target Integrity Hotline, a channel available to all team members and supplier workers for confidentially reporting issues related to the SOVE or any other ethical concerns or business misconduct; the call is free and handled by an independent third party, and local language interpreters are available 24 hours a day. We do not share or publish specific grievances or specific issues raised and do not tolerate any retaliation against any team member who reports in good faith.
In 2022, we partnered with Article One to create an in-depth training experience for our sourcing team members worldwide. The training, provided both as a self-paced e-module and in a train-the-trainer format, 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 intended to deepen understanding of human rights issues and to recognize the importance of having effective grievance mechanisms in place for all workers in our supply chain.
Target continues to explore opportunities to increase awareness and accessibility of reporting options and drive comfort in using the reporting options provided. During 2021, we distributed information on accessing and engaging with Target’s Integrity Hotline to all factory and supplier locations.
Third party helplines
We support suppliers in collecting data on grievance types, resolution and mechanism channels, and through third-party helplines associated with our audit program partners, enhancing effectiveness and worker engagement. Examples of third party helplines include:
Once a grievance is raised, Target leverages a strict triage process to ensure issues are addressed and/or investigated by the appropriate, qualified team. Grievances are managed from intake to resolution. Additionally, we recognize our responsibility to exercise influence through our business relationships and building leverage with others to address issues deeper in our supply chain where we may not have direct business relationships.
This specific analysis of human rights impacts is integrated into our existing routine for handling cases and incidents. To prevent re-occurrence, we have ongoing monitoring programs in place to assess progress, incentivize suppliers that share our ambition for responsible and sustainable business practices through more business, and encourage engagement in various programs at local and global levels.
Outcomes of remedy
In the event that a grievance is identified as founded, Target will engage with its business partners to remediate any and all adverse impacts. In some cases, we will partner with globally recognized nonprofit organizations such as Verité, Impactt and The Centre for Child Rights and Business, to support capability building and remediation of complex workplace human rights issues, to be sure that we are providing the most effective solution.
Health and safety review
Health and safety violations have been a major focus of Target's responsible sourcing audit program. 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 of the mining and trade of columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten (collectively, “3TG”) by armed groups in the Democratic Republic of the Congo and its adjoining countries (the "Covered Countries"). Target encourages its suppliers to source 3TG responsibly. Target seeks to neither finance nor benefit those armed groups directly or indirectly. Target will not knowingly purchase or sell any owned or exclusive brand products that contain 3TG that finances armed conflict in the Covered Countries.
Target also recognizes that there are many smelters and refiners that source from the Covered Countries whose activities do not finance or benefit armed groups and who are certified as “Conformant” by the Responsible Minerals Initiative (RMI). In order to avoid the undue harm to local populations that a generalized embargo upon this region could perform, Target encourages vendors to identify Conformant smelters and refiners within the Covered Countries and to source from them when commercially practicable.
Target requires its owned and exclusive brand product vendors to:
- Adopt a policy related to 3TG sourcing that is consistent with Target’s Conflict Minerals Policy and the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold.
- Complete a Conflict Minerals Reporting Template, which is the standard form developed by RMI for gathering information regarding 3TG usage and related sourcing procedures.
- Exercise due diligence in seeking upstream information to support vendor responses to the questions in the Conflict Minerals Reporting Template.
- Use smelters and refiners certified by RMI as "Conformant," but avoid a generalized embargo on smelters and refiners in the Covered Countries.
- Make available the due diligence used in determining the source of its 3TG upon Target’s request.
Target continues to be engaged with multi-stakeholder initiatives that encourage responsible 3TG sourcing and is a member of and participates in the RMI.
View Target’s Conflict Minerals Report
Cotton Origin Policy
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. 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.
Target does not accept:
- Products containing Turkmen cotton, regardless where produced; and
- Products containing cotton originating in the Xinjiang province of China, regardless where produced.
Target continually monitors and assesses 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. Products in violation of Target’s sourcing policies, including the use of cotton violating this policy, constitutes a breach and entitles Target to exercise any potential remedy available to Target under the Conditions of Contract, including but not limited to order cancellation.