Guideline n the prmtin f fair wrking cnditins in the supply chain 1. Intrductin and mtivatin In several cuntries, the fundamental wrking and scial standards adpted by the United Natins is nt cnsistently and cherently implemented by respnsible natinal gvernments. The expsure f insufficient cnditins in the supply chain nt nly harbrs risks fr internatinal purchasing rganizatins, but als amng lcal manufacturers and their staff. Infringement f minimum scial standards can cause cnsiderable ecnmic damage as well as ther frms f damage. Mst cnsumers expect that glbal human rights and eclgical standards are cmplied with within the framewrk f prductin. This is why the ban n child labr, frced labr and any frm f explitatin has been a fundamental element f purchasing agreements by Galeria Kaufhf since 1997. With this guideline, Galeria Kaufhf is cmmitted t cntrlling the wrking cnditins in all factries in which its wn-brand items are manufactured in s-called risk cuntries and, if needed, t prvide supprt t suppliers in the imprvement f wrking cnditins by means f training. Galeria Kaufhf fcuses n the standards f the Internatinal Labur Organizatin (ILO) and bligates its suppliers tgether with the parent cmpany, Hudsn s Bay Cmpany ("HBC"), t cmply with the HBC Supplier Cde f Cnduct, which is based n the Cde f Cnduct f the Business Scial Cmpliance Initiative (BSCI). 2. Objectives and strategies We want t cntinually imprve the wrking cnditins in the manufacture f ur prduct range and thus cntinue t meet ur custmers' expectatins. All suppliers wn-brand and manufacturer brands must give written cnfirmatin f their cmpliance with ILO standards in the manufacture f gds. Suppliers f wn-brand prducts must als transparently substantiate this by submitting recgnized audit reprts/certificates. -1-
Tgether with ur wn-brand suppliers, Galeria Kaufhf aims t further develp the transparency f the supply chain. Fr this purpse, Galeria Kaufhf will implement a supplier database, in which by mid-, all wn-brand suppliers shall disclse the names and addresses f all factries perfrming the final prcessing steps and must submit a valid audit in accrdance with a recgnized standard. Recgnized standards in the sense f this guideline are: Business Scial Cmpliance Initiative (BSCI), Electrnic Industry Citizenship Calitin (EICC), Ethical Trade Initiative in accrdance with the SMETA Standard (ETI), Fair Labur Assciatin (FLA), Fair Wear Fundatin (FWF), ICTI Care Fundatin (ICTI), Respnsible Jewelry Cuncil (RJC) r SA8000 Fr items that are manufactured in accrdance with the Glbal Organic Textile Standard (GOTS) and that bear the label f the standard, cmpliance with requirements shall be deemed as verified. Factries in Bangladesh must als submit the inspectin results fr building safety and fire prtectin in accrdance with the prvisins f the Bangladesh Accrds r the Bangladesh Alliance fr Wrkers Safety. By the end f 2018, wn-brand textile suppliers shall als disclse the names and addresses f all factries in which s-called wet prcesses are perfrmed alng with infrmatin n the wrking cnditins in place there. By the end f 2018, all factries in Bangladesh, in which wn-brand prducts are manufactured, must submit an inspectin result n building safety and fire prtectin with a result f at least "Yellw" r a cmparable result. By the end f 2019, all factries in which wn-brand prducts are manufactured must be able t prve cmpliance with fair wrking cnditins with a valid audit and a result f at least C r a cmparable result. Factries in need f imprvement are required t demnstrate cntinuus imprvement f the results within an apprpriate perid f time. Independent auditr reprts will be supplemented with visitatin reprts f the buyers at the factries. -2-
By early 2020 at the latest, Galeria Kaufhf will discuss further bjectives and measures fr the imprvement f wrking cnditins in the supply chain internally with its suppliers. Galeria Kaufhf cmmunicates its purchasing plicy t its emplyees and trains its emplyees accrdingly. If needed, strategic suppliers will be supprted with training measures r required t take part in third-party training prgrams. 3. Scpe f applicability f the guideline Galeria Kaufhf implements this guideline in the prcurement f gds fr sale at Galeria Kaufhf in Germany. The bligatin t prvide prf by means f recgnized audits applies t all factries in a cuntry defined as a risk cuntry by the BSCI, in which the last value-added step in the supply chain is perfrmed in the manufacture f wn-brand prducts. All wn-brand suppliers with factries in nn-risk prductin cuntries and manufacturer brands must hwever submit at least a self assessment t be eligible fr listing. 4. Cntractual arrangements The bligatin f the suppliers t cmply with the minimum standards defined by the Internatinal Labur Organizatin (ILO) is a cntractual element. Every supplier is required t sign this passage and t implement it. All suppliers f Galeria Kaufhf are infrmed f the HBC Supplier Cde f Cnduct and are bligated t prvide all items in cmpliance with this guideline. -3-
Infrmatin n the prductin facilities and their audits must be entered by the suppliers in the supplier database. Purchasing may nly place rders with factries that have been set up in the database and that have been apprved by Vendr Cmpliance Management (VCM) fllwing inspectin f all submitted dcuments. Fr new wn-brand suppliers r newly registered factries, a scial standard audit with a grade f at least C r a cmparable result are a fundamental prerequisite fr inclusin in the listing prcess. 5. Cllabratin with suppliers Galeria Kaufhf will expand its dialg with its suppliers n the issue f fair wrking cnditins. Galeria Kaufhf wishes t supprt suppliers with an audit result f C r less by means f targeted FTA training and fr strategic suppliers, external training will aid in imprving the wrking cnditins in the factries sustainably in the lng term. Within the framewrk f factry visits by Galeria Kaufhf emplyees, identified ptential pints fr imprvement are discussed with the suppliers and additinal measures are implemented if necessary. Strategic suppliers with factries perfrming wet prcesses utside the EU, which are nt yet certified in accrdance with the accepted standards f chemical requirements shuld receive training by an external supplier. The tpic f scial standards shall als be integrated int the training. The active participatin in BSCI cmmittees is part f ur aspiratin t cntinuusly adapt the standard in line with latest develpments and t cntribute t the imprvement f wrking cnditins in risk cuntries. 6. Emplyee training Galeria Kaufhf infrms its emplyees n a regular basis n the cntent f this guideline and prvides regular training within the framewrk f mandatry events. Galeria Kaufhf requires that all buyers prcure prducts exclusively in cmpliance with this guideline. 7. Infrming custmers Galeria Kaufhf keeps its custmers infrmed with regard t the prmtin f measures fr fair wrking cnditins n its website. A list f all factries that have cnsented t their publicatin -4-
in writing will be made available n the website f HBC Hlding as well as the website f Galeria Kaufhf. 8. Implementatin and mnitring f the guideline The respnsible individuals in buying department are als respnsible fr implementing the crrespnding measures. Vendr Cmpliance Management (VCM) inspects the supplier data in the supplier database. The Quality Management and Sustainability department will cnduct jint annual training sessins fr buyers and prvide training mdules fr strategic suppliers. Galeria Kaufhf will measure the prgress f the implementatin by means f the fllwing indicatrs: Number f brand and wn-brand suppliers The number f factries in which wn-brand prducts f Galeria Kaufhf are manufactured (divided int risk cuntries and nn-risk cuntries, int risk cuntries with grades better than r equal t C and prer) The number f factries in which wn-brand prducts f Galeria Kaufhf are manufactured in Bangladesh (divided int results better than r equal t yellw and prer) 9. Enfrcement This guideline shall enter int frce n March 1,. -5-