Our team contracts with responsible vendors throughout the world to ensure our products are manufactured in accordance with acceptable environmental, legal and ethical standards. We will not partner with suppliers and factories that are unwilling or unable to work with us to achieve our compliance standards.
Responsible Sourcing
Our Design & Global Sourcing team contracts with responsible vendors throughout the world to ensure our products are manufactured in accordance with acceptable environmental, legal and ethical standards. We will not partner with suppliers and factories that are unwilling or unable to work with us to achieve our compliance standards.
Vendor and Supplier Diversity
- We’ve gathered data from our current vendors and suppliers to assess how they uphold diversity, equity and inclusion.
- We’re tracking contracts as they approach renewals to ensure there is representation of diverse firms in our Request for Proposal (RFP) process.
- We have partnerships with two industry groups focused on vendor diversity – Women’s Business Enterprise National Council (WBENC) and National Minority Supplier Development Council (NMSDC) – to garner their subject matter expertise on the program’s expansion.
Sustainability of Supply Chain
- We regularly evaluate our processes and our performance to minimize the impact of our operations on the environment.
- In 2019, we launched a new test program using our trucks to haul recyclable materials from our stores to our distribution centers for bundling and recycling.
- We use airflow streaming technologies such as nose cones in our last mile fleet and wheel skirts on our over-the-road trailers.
Factory Working Conditions
- We conduct an initial on-site corporate social responsibility (CSR) and Security audit of all of our direct suppliers’ manufacturing facilities and our largest mills. The audit evaluates the compliance with health and safety, human rights, wages and benefits, compliance with laws and ethical practices, and environmental, security and other standards set forth in our Supplier Code of Conduct.
- We promote and monitor the use of continuous improvement practices by our direct suppliers, factories and mills. To achieve this, we train, audit and work directly with our suppliers and always strive to be transparent in our supply chain.
- We will not partner with suppliers or factories that are unwilling or unable to work with us to achieve our compliance standards. We have a robust process to foster compliance with our Supplier Code of Conduct and to support long-term relationships with suppliers that share our values.
- We have a comprehensive Supplier Code of Conduct that prohibits forced labor and child labor and requires freedom of association. The foundation of our Supplier Code of Conduct is based on accepted human rights principles and the international conventions of the International Labour Organization (ILO) and the United Nations (UN).
- We recognize that our responsibility as a Company includes different legal and cultural environments in which suppliers operate globally. We have developed our Supplier Code of Conduct to ensure the communication of our compliance requirements to our direct suppliers, their workers and subcontractors. To reinforce our commitment to the standards, we require our direct suppliers complete an initial and regular CSR and Security audit through third-party auditors such as Underwriters Laboratories (UL) and/or become WRAP (Worldwide Responsible Accredited Production) certified. We do this to ensure a consistent standard for working conditions throughout the world, which are often above and beyond local regulations.
- We believe in continuous improvement and remediation over termination. If a supplier does not fully meet our requirements under our Supplier Code of Conduct, we will work with them to develop a corrective action plan (CAP). The CAP provides the steps to remediate the findings found in an audit, and there are subsequent follow-up audits to assess their progress.
PRIVACY & CYBERSECURITY
PRIVACY
We are committed to protecting the privacy of our customers. Our programs and policies incorporate information privacy best practices and infuse privacy by design concepts into our corporate culture, to ensure compliance with global, federal and state security and privacy laws and industry standards. We lead with a focus on modern, consumer-centric, yet business-driven, privacy practices and ethical corporate governance to maintain the trust our customers place in us with their data. For more information about how we maintain and protect customer information, please see our Privacy Policy. Our Chief Legal Officer holds regular briefings with the Audit Committee of our Board of Directors regarding the ever-shifting data privacy regulatory landscape, risks and mitigating actions.
CYBERSECURITY
Cybersecurity incidents and data breaches, particularly in the retail industry, have been well publicized. Like other retailers, we are subject to cybersecurity risks. We use a range of technologies and security controls to minimize the threat and impact of unauthorized access to our networks and systems. Our data protection efforts include vendor security due diligence and management, monitoring, auditing, vulnerability assessments, employee awareness, regular drills and phishing tests, designed to protect our customers’ data from intrusions and unauthorized access and minimize the harms associated with such events. We continuously invest in our security capabilities, including maintaining and enhancing our existing technologies to continue to stay ahead of new security threats. In addition, we regularly train and educate our employees to maintain the necessary standards of privacy and confidentiality. Our Board of Directors devotes time and attention to oversight of cybersecurity and information security risks, including regular updates from our Chief Technology Officer and Chief Information Security Officer to the Board’s Audit Committee regarding cybersecurity matters.