Labor Standards
The Company is committed to improving labor standards domestically and abroad. We seek and favor suppliers whose standards are compatible with our own, and we will not do business with companies or individuals that do not meet our standards.

History of The Company's Policies Related to Labor Standards
The Company was one of the first members of the U.S. apparel industry to develop and implement corporate policies requiring the observance by vendors and their subcontractors and suppliers of core labor standards as a condition of doing business. At the time of its introduction in 1994, our first formal policy, entitled WHAT WE STAND FOR: Vendors and Suppliers, reflected the best practices of the industry. Consistent with subsequent developments in the industry and heightened public interest and expectations, we developed in 1997 a new policy statement on this subject that contains specific obligations that must be undertaken by all of our vendors and their subcontractors and suppliers. That policy statement is now incorporated in this document.

The Company regularly participates in the activities of leading organizations directed at workplace issues related to global and domestic sourcing. We have earned important recognition for our commitment and efforts to hold vendors and subcontractors accountable for responsible labor standards. In 1995, the Company was one of only 18 firms, and by far the largest retail company, placed by the United States Department of Labor ("DOL") on its "Trendsetter List" of companies. According to DOL, these companies "take additional steps to insure their goods are not made in sweatshop conditions." In 1996, we appeared again on an enlarged "Trendsetter List" of 31 garment manufacturers and retail companies commended by DOL.

We remain vigilant about the enforcement of our labor standards. We have had audit teams conduct spot checks of domestic and foreign vendors in response to reports or allegations of non-conformity with our policies and principles. We have developed, and will continually review and update where appropriate, specific guidelines for monitoring compliance by vendors and subcontractors.

Vendor Certification
The sourcing procedures of each affected business unit will specify procedures for obtaining vendor certification of compliance with our labor standards. Our labor standards include, without limitation, the following:

1. Compliance with the Law
Full compliance with all laws, rules and regulations applicable to the manufacture of products, the facilities where they are made and accommodations made available to workers.

2. Minimum Wages and Benefits
Payment to workers of the minimum wage prescribed by local law or the prevailing local industry wage, whichever is higher; provision to workers of benefits that conform to the better of applicable local law or prevailing local industry standards; and payment to workers of overtime compensation in compliance with all applicable laws.

3. Maximum Working Hours
Overtime shall be limited to a level consistent with humane and productive working conditions. Workers shall not be required, on a regularly scheduled basis, to work in excess of sixty hours (or lower if prescribed by local laws or local industry standards) per week; and, generally, workers shall be provided with at least one day off in seven.

4. No Prison or Forced Labor
Prison, indentured, bonded or involuntary labor shall not be used.

5. No Child Labor
All workers shall be at least the local minimum legal working age, above the oldest compulsory school age, and 14 years of age or older.

6. Health and Safety
The work environment shall be safe and healthy.

7. Nondiscrimination
Workers shall be selected only on the basis of their ability to do the job, and not on the basis of other personal characteristics or beliefs.

8. No Corporal Punishment
Neither corporal punishment nor any other form of physical or psychological coercion shall be used against workers.

9. Freedom of Association
The lawful exercise of workers' rights of free association and collective bargaining shall be respected and not restricted or interfered in, and workers lawfully exercising those rights shall not be threatened or penalized.

10. Environment
Environmental laws and regulations shall be complied with.

11. Community Involvement
Projects undertaken in partnership with community groups, or local or international non-governmental organizations, particularly those which address educational opportunities for younger people employed in production facilities, shall be encouraged and supported.

12. Access
For the purpose of monitoring compliance with our policies, the Company and its agents shall be given unrestricted access to all production facilities and dormitories, and to all relevant records, whether or not notice is provided in advance.