SOURCING & LABOR STANDARDS
Express sources its products from countries all over the world, and we insist that our associates and product suppliers in our direct supply chain (“suppliers”) comply with all applicable laws, rules and regulations.
Our approved suppliers must verify in writing that they meet the following:
- Compliance w/ the Law
- Minimum Wages and Benefits
- Maximum Working Hours
- No Forced Labor
- No Child Labor
- Health and Safety
- No Corporal Punishment
- Freedom of Association
- Community Involvement
- Performance and Evaluation
- Supplier Qualification
- Supplier and Associate Education
- Conflict Minerals
Our Supplier Code of Conduct
Minimum Wages and Benefits
Payment to workers of the minimum wage prescribed by local law or the prevailing local industry wage, whichever is higher; provision to workers of benefits that conform to the better of applicable local law or prevailing local industry standards; and payment to workers of overtime compensation in compliance with all applicable laws.
Maximum Working Hours
Overtime shall be limited to a level consistent with humane and productive working conditions. Workers shall not be required, on a regularly scheduled basis, to work in excess of 60 hours (or lower if prescribed by local laws or local industry standards) per week; and, generally, workers shall be provided with at least one day off in seven.
Freedom of Association
The lawful exercise of workers’ rights of free association shall be respected and not restricted or interfered in, and workers lawfully exercising those rights shall not be threatened or penalized.
Projects undertaken in partnership with community groups, or local or international NGOs, particularly those that address educational opportunities for younger people employed in production facilities, shall be encouraged and supported.
For the purpose of monitoring compliance with our policies, Express, its subcontractors and its agents shall be given unrestricted access to all production facilities and dormitories and to all relevant records, whether or not notice is provided in advance.
Express requires all suppliers and sub-contractors to fully comply with its Code of Conduct. Express does not allow unauthorized subcontracting. A formal request must be submitted to Express for approval, should a supplier require sub-contracting.
Performance & Evaluation
We know it is our responsibility to ensure that our suppliers are in compliance with our standards. To assist us with our responsibilities, we engage third parties who specialize in supply chain compliance matters.
If we discover that our suppliers are 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.
Supplier and Associate Education
As we continue to foster strategic relationships with suppliers, we are committed to supplier and associate education. Our third party service provider conducts annual awareness and training sessions on all compliance standards in multiple countries around the world and uses one-on-one training in conjunction with compliance reviews and corrective action plans. Also, we assure that our associates fully understand and comply with our sourcing policies and procedures. We maintain policies and procedures which govern the consequences of non-compliance by associates or suppliers with our policies and procedures, including sourcing and labor standards. While we recognize that local customs and values profoundly influence individual judgments in many areas covered by these 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 us in conjunction with our third party service provider. First, our sourcing process includes a supplier verification procedure to prevent involvement with perceived high-risk suppliers. Once a supplier is verified, the relationship 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 our Sourcing and Labor Standards, including those pertaining to slavery and human trafficking. Each supplier must agree to allow us, or an independent third party hired by us, to conduct an audit of the supplier’s business unannounced, without prior notice. Depending on the circumstances, a third party conducts announced or unannounced audits of each of our approved factories at least annually to ensure compliance. We 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.
Express is committed to (1) compliance with the Conflict Minerals Rule that was adopted pursuant to Section 1502 of the Dodd-Frank Act, and (2) avoiding the use of Conflict Minerals which may directly or indirectly finance or benefit armed groups engaging in human rights abuses in the eastern Democratic Republic of the Congo. Conflict Minerals means columbite-tantalite (colton), cassiterite, gold, wolframite, and the derivatives tantalum, tin, and tungsten.