Social Compliance Program

Ethical and Responsible: The Only Way We Do Business

Long-term and close-to-home relationships are key to our commitments and success. Bath & Body Works has a strict policy against the use of forced labor of any kind and will only work with suppliers that share our commitment to ethical and responsible business practices. We require all of our suppliers to certify that they have received, read and understand our no forced labor policy.

The Bath & Body Works online social compliance program allows our suppliers, auditors and associates to access critical information such as policies, guidance tools, supplier/factory information, audit reports, corrective action plans and remediation status at any time.

Choosing the Right Partners

We go to great lengths to ensure we are working with business partners that are willing and able to comply with our audit and compliance standards.

1. An initial supplier verification and risk assessment is conducted to prevent involvement with high-risk of forced labor use.

2. Once a supplier has passed the risk assessment, the relationship between Bath & Body Works and a qualified supplier begins with a written master sourcing agreement wherein the supplier certifies that its factories and any that it may contract with will strictly adhere to Bath & Body Works’ Supplier Code of Conduct, including codes and any applicable laws pertaining to slavery and human trafficking. No subcontracting is permitted without prior approval.

3. Each supplier must agree to allow Bath & Body Works or an independent third party hired by Bath & Body Works to conduct an audit of their production locations, including unannounced audits to ensure compliance with our Supplier Code of Conduct and supply chain standards. We may conduct more frequent reviews of factories located in countries designated as high risk by the U.S. State Department's Trafficking in Persons Report or identified through the company’s annual risk assessment process. Certain exemptions from annual audits may be granted to highly compliant factories with consistent and robust compliance. Bath & Body Works requires a pre-production audit of all new factories to ensure the factory can meet our standards before production can begin.

Supplier Training

For suppliers, factory management and associates who have direct responsibility for supply chain management, we host annual awareness and training conferences on all compliance standards. In addition, we use one-on-one training in conjunction with compliance reviews and corrective action plans to continuously educate our factories and reinforce our Supplier Code of Conduct.

Communication Sessions

During our regular Communication Sessions, various internal and external subject matter experts present on current key topics. This event provides a platform through which our suppliers can increase their understanding about critical issues and provides them with helpful tools and resources.

In addition, we are committed to providing our associates with ongoing training and educational opportunities to keep teams vigilant and fully engaged. Associates are expected to follow the standards as set forth in the Associate Code of Conduct.

Compliance Guidebook

Published and distributed to all suppliers, the ComplianceGuidebook is a collection of policies and standards that our suppliers are expected and contractually obligated to comply with. The Supplier Code of Conduct and our full compliance program, including all standards we expect our factories to meet, are included in the Compliance Guidebook as well as contacts for our suppliers to engage if they have questions or need any assistance.

Creating Checks and Balances

To ensure compliance with our Supplier Code of Conduct and supply chain standards, we have implemented an audit process. To identify and evaluate the potential risks of human trafficking, slavery or violations of other local labor standards and/or those that may be unique to Bath & Body Works and our business, we conduct our own ongoing, internal verification of our product supply chain.

Announced and Unannounced Audits

We use a combination of both announced and unannounced audits to ensure compliance. Audits are conducted for facilities that produce:

• Our branded products sold in stores, including those that are promotional

• Non-merchandise items such as gift bags, boxes, price tickets and hangtags

• Branded store fixtures

• Branded components for our core products that are produced by key tier 2 and tier 3 facilities

Our audits typically include a meeting with facility management, a factory tour (including warehouses and dormitories) and a review of relevant documents, including information on wages, benefit deductions, working hours, labor contracts, termination documents, recruitment agency contracts, training and grievance records.

Trade Audits

In addition to monitoring labor standards and workplace conditions for all factories, we conduct trade assessment audits that enable us to identify any instance where unauthorized subcontracting has taken place at our factories. Unauthorized subcontracting is considered a major violation; therefore, we monitor factories to ensure production is taking place at the factory named on the purchase order.

Third-Party Audit Firms

Our third-party audit firms have developed, and continue to develop, standard operating procedures for auditors that provide explanations for additional processes, including (but not limited to) how to handle certain situations or extenuating circumstances that may occur during an audit. Assessors must review and become familiar with all SOPs and are responsible for staying aware of any updates. Auditors are trained on labor standards and ILO forced labor indicators when they start working. They also receive video training focused on forced labor and foreign migrant workers with an online assessment test. Local offices hold regular meetings and trainings on labor standards and ILO forced labor indicators.

Auditors are registered with APSCA (Association of Professional Social Compliance Auditors) which is an industry association whose members represent a substantial majority of the social compliance audit industry. Our internal auditors are also trained on labor standards and ILO forced labor indicators when they start working. Updates on labor standards and ILO forced labor indicators are also discussed during regular team meetings.

Maintaining Audit Standards

To ensure both the Compliance Guidebook and audit tool are up-to-date with industry standards, we evaluate audit tool and the Compliance Guidebook annually, taking into consideration new laws and regulations as well as benchmarking with other auditing firms.

Ensuring Accountability

Bath & Body Works takes compliance with the law and all policies listed in the Compliance Guidebook seriously. As such, suppliers are required to comply with all laws and with the policies listed in the Compliance Guidebook and promptly respond to all Bath & Body Works requests regarding any legal requirement or Bath & Body Works policy. Failure to do so may result in any or all of the actions below:

• Warning letter

• Additional monitoring at the supplier’s expense

• Financial penalties

• Reduction or loss of business