California Transparency in Supply Chains Act
The California Transparency in Supply Chains Act of 2010 (SB 657) requires retailers to disclose their efforts to eradicate slavery and human trafficking within their supply chains.
The Talbots, Inc. (including its affiliated entities and brands, “Talbots”) is committed to preventing forced labor and human trafficking in our global supply chain. At Talbots, we are taking the measures described below to try to ensure that suppliers making our products provide acceptable working conditions for their employees, and that the manufacturing of our products is free from forced labor and human trafficking.
Setting Standards: Talbots has adopted a Supplier Code of Conduct, together with Supplemental Guidelines, that outline our expectations for all of our suppliers, including contractors, vendors and agents. Our Supplier Code of Conduct prohibits any forced or involuntary labor, whether prison, indentured, bonded, or other compulsory labor, and requires suppliers to ensure there is no forced labor or human trafficking in their supply chains. We partner with our buying agents to enforce this Code.
Verification: Our efforts to verify our supplier's compliance begins with our supplier onboarding process. Our social responsibility team reviews and verifies new production facilities being considered for manufacturing. This verification process requires a factory to demonstrate compliance to all local laws, standards, regulations, and our Supplier Code of Conduct through third-party auditing. Once approved, contract factories are then subject to ongoing factory monitoring.
Auditing: Our agents and independent third parties conduct audits to assess compliance. The frequency of audits will depend on the supplier’s historical performance. During the audit, noncompliance issues are noted and addressed in a Corrective Action Plan (CAP), and suppliers are expected to remedy violations in a timely fashion. Our sourcing partners are regularly advised of factories' compliance performance, and we reserve the right to discontinue business with suppliers who fail to make reasonable efforts to improve.
Certification: Our Supplier Code of Conduct and Supplemental Guidelines provide clear guidance to our expectations concerning working conditions, including the prohibition of all forms of forced labor and human trafficking. We require all direct suppliers to certify their compliance with Talbots Supplier Code of Conduct at the beginning of the business relationship and regularly after that. In addition, we require suppliers to maintain adequate records to demonstrate compliance, such as proof of age for all workers, timesheets, and payroll records.
Internal Accountability: Our employees and contractors are expected to conduct themselves according to the Talbots Code of Business Conduct and Ethics guidelines. Our agreements with buying agents also require compliance with Talbots guidelines and to all local country laws and regulations. We also have systematic internal controls assigned to our compliance teams to ensure we successfully prohibit production at unauthorized production factories.
Training: We recognize the importance of educating our employees involved in supply chain-related management about forced labor and human trafficking risks. Key employees and executives undergo training in the identification and prevention of forced labor.