We source goods from numerous countries and take very seriously the requirement that our suppliers comply with our labor and other standards. As such, we are acutely aware of the compliance challenges posed by global supply chains. In order to address these challenges, we are pursuing initiatives that go beyond the traditional model of monitoring and auditing factories in our supply chain. We are increasingly adding and supporting programs that build the capacity of indigenous governments and other institutions to raise labor standards and improve legal compliance, and that build the capacity of our suppliers to comply with our labor standards.

We have been actively engaged, and helped to develop, innovative initiatives to build the capacity of factories, monitors, and governments to advance labor standards in meaningful ways. We have undertaken these initiatives in collaboration or consultation with other leading companies, US and international NGOs, labor groups, and international organizations. For example, we are having our suppliers in several countries participate in, and we are actively supporting, training programs administered by the International Labor Organization. Another example is our work in Lesotho on an innovative labor standards and human resources training program for factory managers, workers, and government officials. We are also involved in efforts to improve rule of law development in the countries we source from.

We seek active and constructive engagement with labor groups and NGOs focused on solving problems that arise at vendor facilities in our supply chain. We believe that such engagement serves as both an early warning mechanism of potential problems and a mechanism for developing innovative solutions.

We hope through these efforts to develop effective models for addressing the challenges we face that are sustainable and can be replicated throughout our supply chain.

Why We Have Sourcing Policies and Procedures
Honesty, integrity and fair treatment of associates, customers and suppliers are fundamental values of the Company. We insist that our business be conducted according to ethical standards that we can point to with pride. Those standards, which apply to our entire business, are set forth in our general code of business conduct known as WHAT WE STAND FOR. This policy statement supplements our general code with respect to issues affecting the sourcing of merchandise.

Our customers are increasingly demanding diverse and affordable merchandise of the highest quality and integrity. We are meeting their demands by developing a sourcing base predicated on strategic partnerships with key vendors who commit not only to our commercial objectives, but also to our values. As our businesses continue to grow both domestically and internationally, we must take special care that the principles we hold most dear are not compromised. This policy statement responds to that challenge.

We and our vendors must fully and completely comply with all laws and regulations applicable to our businesses, including laws and regulations governing the importation of goods into the United States. We must also assure that the merchandise we sell is produced only in accordance with our labor standards. All associates must actively support these principles through three concurrent activities.
  • First, we must understand our legal obligations and vigilantly adhere to them.
  • Second, we and our strategic partners must be advocates of our principles throughout our supply chain and must work together to develop a supplier base that constantly improves its quality and labor standards.
  • Third, we must guard against violations of either the letter or spirit of our principles.
Given the gravity and centrality of these principles to the future of our business, nothing less than a full commitment is required by all of us. It is important that every associate involved in the sourcing process understands the policies that guide our relationships with our vendors and their subcontractors and suppliers. Our relationships with others say a great deal about us. We all share a responsibility for improving the world in which we live, and it is up to each one of us to implement our standards in order to fulfill this responsibility in every community in which we live and work. Our associates who are involved in selecting, educating, training, monitoring and inspecting vendors must exercise particular vigilance in this regard.
Oversight of Implementation and Enforcement of Compliance Responsibilities
The Board of Directors of the Company has established a Business Ethics Committee. This Committee is responsible for: (1) facilitating the implementation and enforcement of the Company's polices and procedures bearing on legal compliance and business ethics; (2) providing guidance whenever necessary with respect to the interpretation and application of those policies and procedures; and (3) improving or modifying those policies or procedures as circumstances warrant. The Committee is comprised of three permanent members - the Chief Financial Officer, the Chief Human Resources Officer and the General Counsel - and three rotating members, each of whom is nominated by the Chairman of the Board of Directors to serve a three year term. The Committee reports to the Chairman and to the Audit Committee of the Board of Directors annually and at such other times as is necessary to fulfill its mandate.

In addition to its other responsibilities, the Committee will oversee the implementation of and adherence to the policies set forth in this policy statement. The manner in which the Committee shall discharge this responsibility is set forth in its Operations Guidelines.
What You Should Do If You Believe There May Be a Problem
From time to time, you may become aware of a situation or may be confronted with a transaction where you are unsure whether acting in a certain way would be in compliance with the letter or spirit of our policies. In such a situation, you should consult your supervisor. If you are uncomfortable raising the matter with your supervisor, or if you are not satisfied with the resolution of the matter at that level, you should contact your business unit's Compliance Officer. If you remain dissatisfied with the resolution of the matter, you may contact the Company's General Counsel:

Douglas L. Williams
Senior Vice President, General Counsel
P.O. Box 16000
Columbus, Ohio 43216
toll-free telephone: 888-884-7218
fax: 614-415-7188

If your concern relates to suspected violations of law, you should communicate your concern directly to your business unit's Compliance Officer, or the General Counsel. Except as otherwise directed by counsel for the Company, you should not discuss those concerns with other parties, including associates, your supervisor, customs brokers, freight forwarders, consultants, accountants, service providers, suppliers, customers, or your spouse or relatives.

If you see something that you think is wrong, don't worry about the repercussions of sharing it. In no event will you or any associate be subject to reprisals, retribution or any career disadvantage for complying with the reporting or other requirements of this policy statement. All inquiries, as well as the identity of reporting associates, will be kept confidential (except in instances where the Company is required to reveal information in order to enforce its policies or by applicable law or judicial process). Of course, false reporting of violations — when done knowingly or recklessly — will not be tolerated; but if you have actual knowledge of or a reasonable basis for suspecting a violation, you should err on the side of making the report.
What Happens When There is a Violation of Our Policies
All violations of the policies contained in this policy statement or in your business unit's sourcing procedures, no matter how trivial they may seem at the time, are harmful to the interests of the Company and will be treated accordingly. Violations will result in appropriate disciplinary action, up to and including termination of employment, recovery of damages and filing of criminal charges.