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 comply with all applicable laws, rules and regulations. Our approved suppliers must verify in writing that they follow the EXPRESS Supplier Code of Conduct.
HUMAN TRAFFICKING AND CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
Express is dedicated to eliminating human trafficking and forced labor on all levels of our supply chain. Express is also committed to collaborating with others to eradicate human trafficking and support the work of international agencies and organizations dedicated to this cause. In 2015, we made a donation to the MGF Touch Foundation to support their work to prevent and end human trafficking. Express complies with the CA Transparency in Supply Chains Act.
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. We also expect our suppliers to communicate with us regarding their use of Conflict Minerals, including providing complete, accurate, and timely responses to surveys and other inquiries by Express.
SUPPLIER CODE OF CONDUCT
Express requires all suppliers and subcontractors to fully comply with the following Code of Conduct:
1. Compliance with Laws
Compliance with all laws, rules, and regulations.
2. 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.
3. 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 sixty 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.
4. No Forced Labor
Prison, indentured, bonded, involuntary, slave labor, or labor obtained through human trafficking shall not be used.
5. No Child Labor
All workers shall be at least the local minimum legal working age, or ILO standard, whichever is higher.
6. Health and Safety
The work environment shall be safe and healthy.
Workers shall be selected only on the basis of their ability to do the job and not on the basis of other personal characteristics or beliefs.
8. No Corporal Punishment
Neither corporal punishment nor any other form of physical or psychological coercion shall be used against workers.
9. 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.
Suppliers must comply with all applicable anti-corruption and anti-bribery laws, rules and regulations, and anti-bribery policies and requirements established by Express.
Suppliers must comply with all applicable environmental laws and regulations.
12. Community Involvement
Projects undertaken in partnership with community groups or local or international non-governmental organizations (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 and its subcontractors and 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 does not allow unauthorized subcontracting. A formal request must be submitted to Express for approval should a supplier require subcontracting.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
Express is dedicated to eliminating human trafficking and forced labor on all levels of our supply chain. Below are the steps Express is taking in furtherance of this goal.
1. Supply Chain Verification. 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 independent third party service provider, which specializes in supply chain compliance. First, our sourcing process includes a supplier verification procedure designed to ensure that we work only with suppliers who are committed to meeting our supply chain standards. Once a supplier is verified, the relationship begins with a written Master Sourcing Agreement (MSA) wherein the supplier agrees that it and the factories that it contracts with will adhere to our sourcing and labor standards, including those prohibiting slavery and human trafficking.
2. Audit Procedures. Each supplier that we verify must agree to allow us, or an independent third party hired by us through our independent service provider, to conduct an audit of the supplier’s business unannounced, without prior notice, to ensure compliance with our human trafficking and forced labor standards. Generally, a third party conducts announced or unannounced audits of each of our approved factories at least annually to ensure compliance. We, through our third party service provider, 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.
3. Supplier Certification. Each supplier is required to sign an MSA in which they agree that they will comply with our Supplier Code of Conduct. The Supplier Code of Conduct requires our suppliers to comply with all applicable laws and policies, including prohibitions against child labor and forced labor.
4. Internal Accountability. Express will not work with those who are unable or unwilling to meet our standards. We maintain policies and procedures which govern the consequences of non-compliance by associates or suppliers. Suppliers are informed of these policies and procedures and the consequences of non-compliance through receipt of a compliance guidebook. If any one of our suppliers falls below the standards listed in our Supplier Code of Conduct, we attempt to bring them into compliance by supporting them in making the necessary changes through corrective action plans.
5. Training. We are committed to supplier and associate education. Our third party service provider conducts annual awareness and training sessions for our suppliers on our sourcing standards in multiple countries around the world. In addition, our third party service provider engages in one-on-one training in conjunction with routine audits and corrective action plans. Also, we assure that our associates fully understand and comply with our sourcing policies and procedures. Associates directly involved in supply chain management receive training on human trafficking that discusses the risks of human trafficking and actions that can be taken to mitigate the risk of human trafficking.
6. Collaboration. We are committed to collaborating with others to eradicate human trafficking and support the work of international agencies and organizations dedicated to this cause. In 2015, we made a donation to the MGF Touch Foundation to support their work to prevent and end human trafficking.