The Limited sources goods from countries all over the world and we insist that our associates and suppliers comply both with the local labor laws that govern their businesses and with our own labor and other standards. We contract with reputable third-party production service providers to provide factory evaluations, risk assessments and audits of our vendors. These providers have auditors and inspectors who live in the communities where our vendors are located and therefore know the local laws and norms and are better suited to interview the employees at factories in the local dialect and language and then document their findings. These local specialists work with factory managers and owners to ensure they meet the standards outlined in our Code of Conduct. If we discover that a vendor is not in compliance with our standards, our first step is to attempt to bring them into compliance by supporting them in making the necessary changes through corrective action plans. We will not work with those who don’t work to meet our standards.
Our approved vendors must verify in writing that they meet the following: Code of Conduct.
Performance and Evaluation
The Limited is responsible for ensuring that our partners are in compliance with our standards. To do this, we use the services of reputable third-party production service providers to assist us with implementation of our strategic evaluation and audit process. We are committed to providing our suppliers opportunities for learning and development. To identify and evaluate the potential risks of human trafficking, slavery, or violations of other local labor standards that may be unique to The Limited and its business, we have partnered with such providers to verify our product supply chain, ensure that our Code of Conduct is prominently displayed in the factories, and that employees are familiar with our expectations. The resulting information helps ensure that we are taking actions in compliance with our own standards.
Supplier and Associate Education
As The Limited continues to foster strategic relationships with suppliers, it maintains its commitment to supplier and associate education. Relevant associates attend, and we encourage suppliers and factory management to attend, annual awareness and training sessions on all compliance standards in multiple countries around the world. We frequently use one-on-one training in conjunction with compliance reviews and corrective action plans. Also, The Limited's production staff, accountants and attorneys ensure that relevant The Limited associates fully understand and comply with our sourcing policies and procedures. The Limited maintains policies and procedures which govern the consequences of non-compliance by associates or suppliers with The Limited's sourcing and labor standards. For example, associates are subject to discipline up to and including termination for violation of The Limited's policies, and suppliers not in compliance must either adopt and carry out a corrective action plan or else are subject to termination. While we recognize that local customs and values profoundly influence individual judgments in many areas covered by our standards, we support the work of international agencies and organizations that seek to implement internationally recognized standards for labor practices.
Supplier Qualification and Audit
Our list of qualified suppliers and factories is established and maintained in reliance on specific qualification standards and protocols developed by our third-party production service providers, who implement The Limited's standards and compliance protocols. First, The Limited's sourcing process includes a supplier verification and risk assessment procedure to prevent involvement with high-risk suppliers. Once a supplier has passed the risk assessment, the relationship between The Limited and a qualified supplier begins with a written Master Sourcing Agreement wherein the supplier certifies that the factories that it contracts with and its own direct suppliers will strictly adhere to The Limited's Code of Conduct, including those pertaining to slavery and human trafficking. Each supplier must agree to allow The Limited or an independent third party hired by The Limited to conduct an audit of the supplier’s business unannounced, without prior notice. Depending on the circumstances, our third-party production service provider or another third party conducts announced or unannounced audits of each of our approved factories at least annually to ensure compliance. The Limited may conduct more frequent reviews of suppliers located in countries designated as high risk by the U.S. State Department’s Trafficking in Persons Report. Exemptions from annual audits may be granted to highly compliant factories based on the previous year’s audit scores. In addition, we benefit from the knowledge and experience of our production service providers who participate in many stakeholder initiatives (i.e., the Business Council for Global Development). Such organizations work to enhance the rule of law and labor standards, support international institutions, and advocate for policies that benefit many of the communities in which our products are produced.
LIMITED STORES, LLC
CODE OF CONDUCT
Compliance with law: Full compliance with all laws, rules and regulations applicable to the manufacture and sourcing of the goods, the facilities where they are made, the incorporation of materials into product and accommodations made available to workers.
Familiarization with and display of the Code of Conduct: Vendors shall familiarize workers with the Limited Stores, LLC ("The Limited") Code of Conduct and display this Code of Conduct, translated in the local language. It will be displayed at all their facilities in a place visible and accessible to all workers.
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.
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.
No prison or forced labor: Prison, indentured, bonded or involuntary labor shall not be used.
No child labor: All workers shall be at least the local minimum legal working age or international labor organization standard, whichever is higher.
Health and safety: The work environment shall be safe and healthy.
Non discrimination: 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.
No corporal punishment: Neither corporal punishment nor any other form of physical or psychological coercion shall be used against workers.
No corruption or bribery: Compliance with applicable laws, and agreement not to tolerate, permit or engage in bribery, corruption or unethical practices.
Freedom of association: The lawful exercise of workers’ rights of free association shall be respected and not restricted or interfered in, and workers lawfully exercising those rights shall not be threatened or penalized.
Environment: Environmental laws and regulations shall be complied with.
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.
Access: For purposes of monitoring compliance with our policies, The Limited, its subcontractors and 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.
Subcontracting: The Limited requires that all suppliers and subcontractors fully comply with our Code of Conduct. The Limited does not allow unauthorized subcontracting. A formal request must be submitted to The Limited for approval should a supplier require subcontracting.