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.