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California Transparency in Supply Chains Act of 2010

As a retail seller doing business in the state of California, we are required to provide you with details of our efforts to address the issue of slave labor and human trafficking in our supply chain.

Sears Holdings has a Global Compliance Program to ensure that suppliers for Sears, Sears Canada, Kmart, and Lands' End comply with applicable local laws as well as Sears Holdings' internal standards related to child labor, wages and benefits, working hours, harassment/abuse, discrimination, health and safety, factory security, freedom of association, environmental compliance, and forced/slave labor, human trafficking.

A summary of specific efforts from the Sears Holdings Global Compliance Program includes:

  • Supplier Requirements. Suppliers who produce merchandise for Sears, Sears Canada, Kmart, or Lands' End are provided and expected to adhere to the Sears Holdings Global Compliance GUIDEBOOK to Program Requirements, which outlines our expectations pertaining to social compliance, including slave labor and human trafficking. Click here to review this publication.
  • Supplier Audits. Factories that produce our merchandise are audited when we believe there is high risk for slave labor and human trafficking. The audits are conducted either by our own full time auditors or by approved 3rd party audit firms on our behalf. All auditors are trained to understand our Program, our expectations, and the specific local language and laws in each country. The audits are conducted on site, and involve discussions with workers, management interviews, a review of pertinent factory records, and a physical inspection of the factory and dormitory. After the audit, any violations of our standards are documented, and a detailed corrective action plan is required. Regular follow-up visits are also conducted to ensure efforts are made to correct any violations.
  • Supplier Training. We provide our vendors annual training to review and reinforce our Global Compliance Program Requirements in detail. Our training specifically reviews our Requirements related to slave labor and human trafficking, and how to identify high risk situations and potential non-compliance. As further reinforcement of our training, in December of 2011, we issued a notification to all of our merchandise suppliers outlining our policy related to the California Transparency in Supply Chains Act of 2010, and our right to terminate a supplier if violations related to slave labor or human trafficking are cited.
  • Internal Training. We provide routine training on all of our Program Requirements both to auditors employed by Sears Holdings, as well as auditors employed by 3rd party audit firms who conduct social compliance audits on our behalf. In addition, Sears Holdings employees who visit factories as part of their job responsibilities are made aware of the indicators of slave labor and human trafficking, and are required to report any potential issues for further investigation.
laborc@searshc.com

http://www.searsholdings.com/govern/docs/Global_Compliance_Program_Guidebook.pdf