California Transparency in Supply Chains Act Disclosure
(Updated as of November 19, 2015)
On January 1, 2012, California enacted the California Transparency in Supply Chains Act which mandates manufacturers and retailers to disclose their efforts to prevent forced labor in their direct supply chains for goods offered for sale. By requiring greater transparency about goods made available to its consumers, the law encourages California customers to make informed purchasing decisions.
Kohl’s is committed to sourcing products from companies that share our values around human rights, ethics and environmental responsibility. We require all of our vendors to comply with our Terms of Engagement (“our Policy”) as a condition of doing business with Kohl’s. Our Policy strictly prohibits the use of prison labor, bonded labor, indentured labor or forced labor in the manufacture or finishing of products we order, including without limitation, prison and slave labor or human trafficking for the purposes thereof. Our Policy is designed to protect the interests of workers engaged in the manufacturing of merchandise procured for Kohl’s, and we select vendor partners who we believe share our commitment to the fair and ethical treatment of employees. Our Policy is posted at https://corporate.kohls.com/content/dam/kohlscorp/non-press-release-pdfs/2016/Terms%20of%20Engagement%20for%20Business%20Partners%20-%20September2016.pdf. The following provides additional information concerning the steps Kohl’s takes to enforce our Policy.
Kohl’s works with our vendor partners and agents to raise awareness of the issue of human trafficking. Those vendors that produce private label and exclusive merchandise for us are required to identify all manufacturing facilities, domestic and foreign, that they plan to use to produce such merchandise and to provide us with written certification that each facility will operate in compliance with our Policy and all applicable laws, including but not limited to, laws regarding slavery and human trafficking in the countries in which they do business.
Kohl’s requires our vendors to maintain documentation necessary to demonstrate compliance in those factories producing merchandise for Kohl’s. Additionally, all subcontractors that a vendor desires to use in the manufacturing process require Kohl’s approval. Kohl’s enforces a zero tolerance policy regarding the use of prison labor, forced labor, slavery and human trafficking. Action will be taken against any vendor for non-compliance, resulting in potential termination of our business relationship. In order to verify compliance by our vendors, Kohl’s conducts audits of our vendors as described below.
Kohl’s actively monitors factories in which our private label and exclusive merchandise is produced. We contract the services of independent, professional, third party social compliance monitoring firms to perform both announced and unannounced factory audits. Our monitors have auditing professionals located in the territories in which the manufacturing facilities reside who are able to speak the language of the workers and management, and who have extensive experience with monitoring social compliance on behalf of international customers. Completion of our full audit program requires a two-day factory visit, while follow-up audits are completed in one day. Each factory is inspected for compliance on a periodic basis at a frequency based upon a risk assessment and prior audit findings. If issues are noted, the factory undergoes follow-up monitoring visits and training. Kohl’s reserves its right to review all vendor partner facilities, including the use of unannounced on-site inspections of manufacturing facilities.
In addition to our Policy, any vendor desiring to do business with Kohl’s must adhere to our Purchase Order Terms and Conditions (“our Terms”), the contract under which we purchase goods. Our Terms expressly require a vendor to represent and warrant that its goods (as well as all materials incorporated therein) are manufactured in accordance with our Policy and all applicable laws, including without limitation, those regarding slavery and human trafficking of the country(ies) in which the vendor does business. Kohl’s pursues affirmative measures to monitor compliance with our Policy and our Terms, and to hold our vendors accountable as also described herein.
Kohl’s employs dedicated policy compliance personnel who are responsible for the day-to-day duties and administration of the compliance program, and who are independent of the Product Development and Merchandising departments responsible for development, sourcing and merchandising. Accordingly, day-to-day assessments and decisions regarding the social compliance status of potential factories that may be used to produce private and exclusive merchandise for Kohl’s, are made by employees not involved in the product purchase negotiations.
Furthermore, potential violations of our Policy or other ethical or legal concerns can be reported through our existing internal hotline and external reporting mechanisms found under “Corporate Governance” at, http://www.kohlscorporation.com.
Kohl’s provides training to relevant Kohl’s employees regarding identification and mitigation of the risks addressed by our Policy. For those employees who have direct responsibility for supply chain management, we provide additional training on human trafficking and slavery, particularly with respect to mitigating those risks within the supply chain. Kohl’s also conducts quarterly internal training sessions for Product Development employees regarding our Policy requirements.