Modern Slavery Statement
(California Transparency in Supply Chains Act of 2010 and U.K. Modern Slavery Act of 2015)
This Statement relates to our fiscal year that commenced on January 31, 2021 and ended January 29, 2022 (“fiscal year 2022”). This Statement generally discusses the efforts of The TJX Companies, Inc.
and its consolidated subsidiaries to address modern slavery because we take a global approach to modern slavery compliance. The reporting entities come within our global social compliance program.
About Our Business. TJX is an off-price retailer of apparel and home fashions with nearly 4,700 stores across three continents in nine countries offering a rapidly changing assortment of merchandise.
We source merchandise from a varying and expansive universe of approximately 21,000 vendors and more than 100 countries. As an off-price retailer, we have a complex global business model that is quite different
from other traditional retailers that, unlike TJX, may own, operate, or control the facilities that manufacture products sold in their stores and/or may purchase products from a generally consistent vendor base.
Our strategies to acquire merchandise are intentionally flexible to allow our buying organization to react to frequently changing opportunities and trends in the market and to adjust how and what is acquired
as well as when it is acquired. Sometimes, when what we are seeing in the marketplace is not the right value for our customers, meaning the right combination of brand, fashion, price, and quality, we may help
design or develop merchandise to be manufactured just for us.
Our Commitment. At TJX, we are committed to treating people with dignity, fairness, and respect. Both our TJX Global Code of Conduct, which applies to all of our employees (Associates) worldwide,
and our Vendor Code of Conduct, which applies to our merchandise vendors, reflect these principles and prohibit involuntary or forced labor. We are aware of reports of modern slavery in apparel supply chains
and, as described below, our Global Social Compliance program underscores our efforts to address and mitigate these risks, and where appropriate, take corrective action. We believe that modern slavery risks
in our own workforce are minimal due to the strength of our internal employment policies and procedures.
Our Global Social Compliance Program. Our Global Social Compliance program includes, among other things, our factory
audit program, our Vendor Code of Conduct, our training efforts, and our grievance mechanisms for vendors. As part of our program including as part of assessing its effectiveness, we regularly review factory
audits performed, remediation efforts taken, and vendor training attendance. Our Global Social Compliance Committee, which includes senior leadership, meets on a regular basis to oversee this program and review
trends in social compliance. In addition to our Global Social Compliance Committee, we also have a Global Corporate Responsibility Executive Steering Committee to help guide our global corporate responsibility
strategies and align them with TJX business priorities, oversee corporate responsibility efforts across functions and geographies, facilitate information exchange, and support enhanced corporate responsibility
reporting. This Committee is comprised of senior executives representing functions across the Company, including two executive officers reporting directly to the CEO. These executive officers are positioned
to update management and the Board on the ongoing work of the Committee.
To help us evaluate and address the risks of modern slavery in our merchandise supply chain, our actions have included membership in external multi-stakeholder initiatives that share resources and best practices
to improve efforts to combat forced labor, including the Joint AAFA/NRF/RILA/USFIA Forced Labor Working Group, the Responsible Business Alliance’s Responsible Labor Initiative, Retail Industry Leaders
Association (“RILA”) Responsible Sourcing Committee, and the American Apparel and Footwear Association Social Responsibility Committee. TJX is also an Ambassador Sponsor of the Responsible Sourcing
Network’s YESS initiative, which aims to train, support, and enable spinners and mills in the middle tiers of the supply chain to end forced labor at the raw cotton level.
Vendor Code of Conduct. As a condition of conducting business with TJX and as a means of self certification, our merchandise vendors are required to agree to comply with our Vendor Code of Conduct which prohibits involuntary or forced labor, including labor obtained through slavery or human trafficking. Our Vendor Code of Conduct further requires that the goods our merchandise vendors sell to us have
been manufactured in accordance with all applicable laws and regulations, which include those pertaining to involuntary labor, forced labor, or human trafficking. It also requires that merchandise vendors ensure
that all subcontractors and any other third parties they use in the production or distribution of goods offered for sale in our stores comply with the principles described in the Vendor Code of Conduct.
Third-Party Audits. Our Global Social Compliance Program includes factory auditing. We focus our factory auditing where we have more influence in bringing the products to market. This means our program
typically reaches factories that produce merchandise that we have helped design or develop to be manufactured just for us. We focus our auditing efforts on these factories because we believe this is where we
are most likely to be able to have a meaningful impact. We contract with both leading independent auditors (including UL, Intertek, and Omega) and other third parties (such as our buying agent) to conduct these
social compliance audits and we also accept audit reports from recognized audit sources, including BSCI, WRAP, and SEDEX. These social compliance audits evaluate and address risks of modern slavery. In fiscal
year 2022, we reviewed more than 2400 audits. Over the last two decades, we have conducted or accepted tens of thousands of audits.
We maintain a Global Social Compliance Manual, which is available in seven languages and contains an audit procedure outline and factory evaluation checklist to help factories better understand our Vendor Code of
Conduct and prepare for audits conducted on our behalf by UL, Intertek, and Omega. The audits are conducted on an unannounced basis during specified time windows, where possible, and they are intended to verify
the factory’s compliance with the standards contained in our Vendor Code of Conduct, including our prohibition of involuntary or forced labor. To this end, factory audits consider, among other things,
whether workers are responsible for any fees associated with their recruitment and evaluate policies related to passport retention. Vendors are expected to cooperate fully with the audits and to provide the
auditors with full access to their facilities, employees, and documentation. Factory audits include employee interviews in order to hear first-hand about worker treatment. We recently enhanced our audit program,
with additional forced labor questions based on recommendations from industry groups. When we accept factory audit reports from recognized third party audit sources, the audit report is evaluated against our
own internal audit requirements to determine the factory’s audit score. The factory’s score on the initial audit determines timing for re-assessment, according to a risk-based audit cycle we have
developed. Our policy is to take appropriate steps should we learn that a vendor is failing to meet our standards. These steps may include remediation, cancellation of purchase orders, or termination of our
business relationship.
TJX Global Code of Conduct. Our TJX Global Code of Conduct prohibits behavior that creates an intimidating
or hostile work environment, and it requires TJX Associates to obey all applicable laws and regulations of the countries in which we operate, including wage and hour rules. In choosing third parties to work
with, our Associates are also expected to select those that act with integrity and in a manner consistent with the ethical principles stated in our Global Code of Conduct. TJX reviews reported concerns and takes
appropriate action depending on the nature and severity of the violation.
Training. We provide regular training for Associates, including management, involved in the development and buying of merchandise, as well as cyclical training for our buying agent, certain vendors, and
their factory representatives around the world. Typically, we hold an average of 10-12 training sessions a year, focusing on various locations around the world that are regionally close to factories included
in our factory monitoring program. Among other things, this training provides guidance on recognizing and mitigating the risks of modern slavery. Due to the COVID-19 global pandemic, we initiated virtual training
in fiscal year 2021, which continued in fiscal year 2022.
Grievance Mechanisms. TJX Associates are encouraged to raise any concerns without fear of retaliation and have multiple channels to do so, including an ethics hotline staffed by independent third-party
operators. External stakeholders, including vendor personnel, may reach us via any of the phone numbers or addresses listed by locality on the "Contact Us" section of our corporate website. While an overview
of our efforts is provided here in response to the California Transparency in Supply Chains Act and the U.K. Modern Slavery Act, we invite you to explore a more comprehensive description of our Global Social Compliance program within the Corporate Responsibility section of our website at
https://www.tjx.com/responsibility/responsible-business.
This Statement was approved on 20 July 2022 by the Boards of Directors of TJX UK, TJX Europe Buying (Deutschland) Ltd. and TJX Europe Buying Ltd., which are the TJX subsidiaries subject to the U.K. Modern Slavery
Act, and signed by the undersigned Director of each of those entities as of 20 July 2022.
David L. Averill, Director
TJX UK, TJX Europe Buying (Deutschland) Ltd., and TJX Europe Buying Ltd.