Transparency in Supply Chains Statement
Feb. 17, 2022
The California Transparency in Supply Chains Act of 2010 (SB657) requires large retailers and manufacturers to disclose efforts to prevent slavery and human trafficking in their supply chains. At Bath & Body Works, we strive to ensure the ethical production of our merchandise and have an established Social Compliance program in place to monitor for this type of activity and ensure compliance with our supplier requirements and Supplier Code of Conduct (collectively, the “Requirements”). As set forth in our Requirements, we aim to prevent the use of slavery and human trafficking in our supply chain. Failure to meet our Requirements can result in corrective action, which includes consequences as severe as the supplier being removed from our approved vendor list.
Our efforts at preventing slavery and human trafficking in our supply chains include:
1. Verification
Our suppliers are required to disclose all domestic and foreign manufacturing locations to us before production. We utilize multiple data sources, like the Worldwide Governance Indicators from the World Bank, the U.S. State Department Trafficking in Persons Report and our compliance audit history, when assessing the risk associated with new suppliers and their locations. Careful consideration is taken before allowing new production to take place in countries that may have higher potential for any type of forced labor.
2. Auditing
We monitor our suppliers throughout the production cycle to identify, assess and manage the risks of slavery and human trafficking. We use a risk-based approach to focus our audit efforts on factories located in high-risk areas for slavery and human trafficking. Audits can occur anytime during an agreed upon two-week window. Audits are conducted by an independent, third-party monitoring firm and focus on identifying concerns related to slavery and human trafficking, working conditions, and compliance with our Requirements as a whole. Audits include a full factory tour, worker interviews, management interviews and a robust records review to get a full understanding of the practices occurring in the factory. If we find or suspect any use of slavery or human trafficking or believe there is noncompliance with our Requirements, appropriate corrective measures are taken.
3. Certification
Our suppliers agree to comply with all applicable laws and regulations and Bath & Body Works’ policies (which include compliance with the Requirements) when they enter into a Master Sourcing Agreement with us. Moreover, each Purchase Order that a supplier accepts references and reiterates the applicability of the terms of the Master Sourcing Agreement.
4. Internal Accountability
Our associate Code of Conduct provides clear guidelines for associates who engage with any of our suppliers and states we will not knowingly partner with suppliers that engage in any form of modern slavery or that are unwilling to commit to, or comply with, our supplier standards. Potential violations of our policy can be reported to our Global Ethics and Compliance Department through internal and external channels.
5. Training
We periodically conduct Modern Slavery Awareness training for our sourcing team and for other teams who engage with our suppliers. The training drives awareness and understanding of slavery and human trafficking issues and educates associates about their role in preventing such abuses. We also require all of our associates to be trained on our associate Code of Conduct, which mandates that we only deal with responsible suppliers and prohibits us from knowingly partnering with suppliers that engage in any form of slavery or human trafficking or that are unwilling to commit to or comply with our Requirements.