chapter 2 vendor compliance

Chapter 2

Vendor Compliance (Apparel & Accessories)

I. Supplier Code of Conduct ......................................................................................................................... 3

II. Supply Chain Social Responsibility Overview .......................................................................................... 5

a. Monitoring Factory Working Conditions ............................................................................................. 5 b. Transparency and Continuous Improvement ................................................................................... 6

III. Factory Ratings ............................................................................................................................................ 7

a. Overview ................................................................................................................................................ 8 b. Proposed Factories ............................................................................................................................... 8 c. Active Factories .................................................................................................................................... 8 d. Audits through Buying Agents ............................................................................................................. 9 e. Third Party Audits ................................................................................................................................... 9 f. Direct .................................................................................................................................................... 10 g. U.S. Based Vendors ............................................................................................................................. 10 h. Better Work Policy ............................................................................................................................... 10

IV. Customs and Trade Partnership Against Terrorism (C-TPAT) Overview ............................................... 11

V. C-TPAT Compliance Criteria .................................................................................................................... 12

a. Business Partner Requirements .......................................................................................................... 12 b. Container Security .............................................................................................................................. 12 c. Physical Access Controls ................................................................................................................... 15 d. Personnel Security ............................................................................................................................... 17 e. Procedural Security ............................................................................................................................ 19 f. Security Training and Threat Awareness .......................................................................................... 19 g. Physical Security ................................................................................................................................. 19 h. Information Technology Security ...................................................................................................... 20

VI. C-TPAT Factory Audits & Rating System .................................................................................................. 22

a. Proposed Factories ............................................................................................................................. 22 b. Active Factories .................................................................................................................................. 22 c. Direct Vendors ..................................................................................................................................... 22 d. U.S. Based Vendors ............................................................................................................................. 23

2

VII. Chapter 2A – Talbots Supplemental Guidelines ...................................................................................... 1

a. Introduction .................................................................................................................................................. 1

b. Supplemental Guidelines - Compliance with Talbots’ Supplier Code of Conduct ............................. 2

c. Policies and Procedures ............................................................................................................................. 3

d. Child Labor ................................................................................................................................................... 4

e. Forced Labor ................................................................................................................................................ 5

f. Foreign Contract Workers ........................................................................................................................... 7

g. Discrimination .............................................................................................................................................. 9

h. Freedom of Association ............................................................................................................................ 10

i. Harassment and Abuse ............................................................................................................................ 11

j. Health and Safety ...................................................................................................................................... 12

k. Working Hours ............................................................................................................................................ 16

l. Wages and Benefits ................................................................................................................................... 17

m. Subcontracting .......................................................................................................................................... 19

n. Environmental Practices ........................................................................................................................... 20

o. Business Integrity ....................................................................................................................................... 21

p. Sanctions .................................................................................................................................................... 22

q. Anti-Money Laundering ............................................................................................................................ 24

APPENDIX A: DEFINITIONS ............................................................................................................................... 25

APPENDIX B: POCKET GUIDE TO CHEMICAL HAZARDS ................................................................................. 27

3

I. Supplier Code of Conduct

Talbots’ Code of Conduct is based on internationally recognized human rights and

business practice standards. Detailed Standards and Expectations can be found in the

Supplemental Guidelines at the end of this chapter.

No Child Labor

Suppliers must comply with the minimum employment age and minimum compulsory education level defined by

national law or the International Labor Organization (not less than 15 years of age, subject to exceptions allowed by the

ILO and national law), whichever is higher. Suppliers must obey all legal requirements for work of authorized minors,

particularly those pertaining to hours of work, wages, minimum education, and working conditions.

No Forced Labor

Suppliers must not use any type of forced or involuntary labor, whether prison, indentured, bonded, or other compulsory

labor, and must ensure there is no forced labor or human trafficking in their supply chains.

No Discrimination

Discrimination in employment, including hiring, pay, benefits, job assignments, working conditions, training, recruitment,

promotion, discipline, termination, and retirement, on the basis of gender, race, religion, age, disability, sexual

orientation, gender identity, parental status, pregnancy, nationality, political opinion, and social or ethnic origin is

prohibited.

Respect for Freedom of Association

Suppliers must recognize and respect the rights of employees to lawfully associate and to bargain collectively. Suppliers

may not interfere with, obstruct, or prevent legitimate related activities, and must ensure workers are not intimidated,

harassed, or penalized for the non-violent exercise of their right to join or refrain from joining any organization.

No Harassment or Abuse

All workers must be treated with dignity and respect. No worker may be subjected to physical, sexual, psychological, or

other forms of mental or physical coercion, harassment, abuse or intimidation. Suppliers are expected to implement

reasonable procedures for disciplining and/or terminating workers and maintain documentation to demonstrate

compliance. The use of fines as a disciplinary practice is prohibited.

Health and Safety

Conditions in all production facilities must be safe, clean, healthy, and consistent with all applicable laws, regulations,

and supplemental guidelines of this Code, to avoid preventable work-related accidents and injuries. Supplier-provided

employee housing, bathing, and toilet facilities must be safe, clean, and adequate to the number of employees. Where

higher than the law or the Code requirement, suppliers should implement industry best practices.

Working Hours

All work must be voluntary, without threat of penalty, punishment, or dismissal. Workers must not be required to work

more than 60 hours per week (inclusive of overtime), or more than the regular and overtime hours allowed under local

law, on a regularly scheduled basis. Workers are entitled to at least one day off in every seven-day period.

Wages and Benefits

Suppliers must comply with the minimum wages and benefits required by local law or the local industry standard,

whichever is higher. Workers must be paid for overtime hours at the premium rate legally required in the country of

manufacture. In those countries where overtime compensation laws do not exist, employees must be compensated at

least equal to their hourly compensation rate.

No Unauthorized Subcontracting

Suppliers may not subcontract any operation in the manufacturing process without prior written consent from Talbots,

and only after the subcontractor has agreed to comply with Talbots’ Code of Conduc

Environmental Practices

Suppliers may not subcontract any operation in the manufacturing process without prior written consent from Talbots,

and only after the subcontractor has agreed to comply with Talbots’ Code of Conduct.

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Sanctions

Suppliers must not cause Talbots to violate U.S. and other applicable economic sanctions laws and regulations

(collectively, “Sanctions”), which are laws and regulations that restrict business with certain countries, individuals, and

entities in order to advance specific foreign policy and national security priorities.

Anti- Money Laundering

Suppliers must not cause Talbots to violate applicable anti-money laundering laws and regulations, including the

Currency and Foreign Transactions Reporting Act of 1970 (commonly referred to as the “Bank Secrecy Act”), as

amended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct

Terrorism Act of 2001 (commonly referred to as the “USA PATRIOT Act”) (all such laws, collectively, “AML Laws”).

Business Integrity

Suppliers must comply fully with the applicable laws and regulations of the countries in which they operate. In addition,

business must be carried out ethically, honestly, and fairly. Suppliers must not, directly or indirectly, make any improper or

unlawful gifts or payments to any person, entity, or government official in connection with accepting or performing

orders for Talbots, or in an attempt to impact the objectivity of third party representatives appointed by Talbots to carry

out inspections and compliance audits.

Where the Code requirements are stricter than the law, compliance with the Code is required.

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II. Supply Chain Social Responsibility Overview

Talbots has a long-standing heritage of high quality and uncompromising ethics. Our commitment

to responsible business practices includes treating the workers who make our products with

dignity and respect. Our Code of Conduct establishes standards for all of our suppliers, and in our

Supplemental Guidelines to Talbots’ Supplier Code of Conduct, we provide detailed and

practical guidance about our expectations, informing our suppliers, contractors, vendors, and

agents of the employment practices and working conditions that comprise the minimum

standards for doing business with Talbots.

This chapter outlines the tenets of our social responsibility expectations and Talbots’ supply chain

responsibility program.

a. Monitoring Factory Working Conditions

The Talbots factory social responsibility program is designed to increase Talbots’ awareness

about supply chain risks, identify areas in need of improvement, and engage with its suppliers

on working conditions.

Working conditions are an important aspect of Talbots’ assessment of overall factory

performance. Talbots’ ability to fulfill its commitment to responsible business practices requires

visibility into working conditions at all factories and all sub-contractors producing for Talbots.

As a measure and means of driving improvement in our supply chain, Talbots maintains a

program of regular social compliance audits. This includes initial compliance assessments for

the factories proposed for Talbots’ production, and regular evaluations of active suppliers, on

an announced or unannounced basis. Talbots utilizes buying agent and third-party

(unaffiliated) monitors to conduct on-site evaluations and inspections of its vendors’ and

factories’ facilities.

Talbots relies on social compliance audits conducted by its nominated audit partners for

visibility into factory working conditions. Talbots uses the results of social audits to evaluate

and rate factory working conditions according to the relevant laws and regulations and the

Talbots Code. These ratings help inform sourcing decisions. The aim of Talbots’ evaluations

and rating system is to identify problems, establish root causes, and outline appropriate steps

to achieve legal compliance and continuous, sustainable improvement. Violations or non-

compliances with the Code and/or law will be reported to the supplier for follow up and

corrective action. Talbots will monitor supplier progress toward compliance, usually by

holding management accountable to an agreed-upon corrective action plan.

Where there are egregious violations, such as child labor, forced or prison labor, bribery,

physical abuse, and/or the supplier does not demonstrate a willingness to comply, Talbots

may discontinue business with the supplier. Talbots reserves the right to make periodic

updates to its Code of Conduct and social responsibility program; we will notify vendors and

factories of any such changes.

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b. Transparency and Continuous Improvement

As a condition of doing business with Talbots, we expect suppliers to provide accurate

information and, during audits, to provide full access to the facility, workers, and records, as

well as dormitories. We expect our suppliers to openly and honestly discuss any non-

compliance issue and the underlying business challenges with Talbots or our representatives.

When violations are identified, Talbots requires vendors and associated factories to make a

sincere effort toward improvement of working conditions.

Talbots is aware that social compliance audits provide only a snapshot of factory working

conditions, and evaluations will always be somewhat subjective. We therefore seek to

cultivate transparent business relationships with suppliers committed to respect for workers,

continuous improvement in working conditions, and to build the mutual confidence necessary

to raise concerns with each other.

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III. Factory Ratings

Talbots uses audits to assess supplier factories’ compliance with the standards described in The

Talbots Inc. Supplier Code of Conduct. Audit findings are input into Talbots Factory Rating Tool,

which calculates numerical factory ratings on a scale from 0 (worst score) to 100 (best score).

Based on audit findings and other information, Talbots will assign factories an overall social

compliance rating, using a “traffic light” color rating scale.

Talbots audit tool allows us to gauge relative performance comparing one or different factories

over time. Talbots’ factory rating system takes continuous improvement, as well as persistent

problems, into account. The audit tool rewards factories that show improvements in successive

audits – even if full compliance is not achieved – but increases deductions for repeat violations.

Each audit begins with a perfect rating of 100, or “Green;” points are deducted according to

severity and frequency of non-compliance with the Code. Where appropriate, Talbots may add

points for factories implementing best practices in managing working conditions.

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a. Overview

All suppliers must agree to and/or facilitate compliance assessments of any factories

proposed for or used for Talbots production. Talbots reserves the right to conduct

unannounced audits of approved factories at any time. Factories that manufacture goods

for Talbots must allow Talbots representatives or third parties authorized by Talbots unrestricted

access to their facilities at all times, whether or not the factory is notified in advance.

Factories cannot be made active, or purchase orders written, if minimum working conditions

standards are not met. Once approved, all suppliers producing for Talbots are required to

abide by the Supplier Code of Conduct and all applicable laws and regulations. Acceptance

of Talbots PO/PM and shipment of merchandise to Talbots represent a continuing affirmation

of compliance.

On-site social compliance inspections may include, but will not be limited to:

• Interviews with employees, on or off-site

• Review of relevant records, documents, and bookkeeping, including production records

• Inspections of employee files, including time cards and wage statements

Social audits will be conducted at least once annually at all active factories to verify

compliance.

b. Proposed Factories

As part of the new factory on-boarding process, all factories under consideration for Talbots

production will undergo an initial social responsibility audit, either by Talbots’ nominated

auditing partners or Talbots’ agents.

If the proposed factory receives an unacceptable rating or a zero tolerance violation is

found, it will not be approved for production, but may have the opportunity to improve its

rating through corrective actions and subsequent follow-up audits to ensure violations have

been satisfactorily addressed.

c. Active Factories

All Talbots-approved factories remain active for production for a specific time period

determined by the factory’s social compliance rating. Talbots will communicate the length of

a factory’s active status after each audit. Before the conclusion of the active period, if

Talbots wishes to continue working with the factory, it will be re-assessed for social

compliance.

All factories that are approved for Talbots’ production will be audited by Talbots audit

partners at least once per year, with the exception of “Green”-rated factories, which can

remain active for up to 18 months.

If an approved factory receives a rating of dark orange or red, Talbots will consider this

factory “high risk,” with follow up determined on a case-by-case basis. At the least, Talbots

and/or its buying agent will work with factory management to ensure a clear plan for

corrective action is in place. If the factory fails to improve its social compliance rating to

within a specified time period, Talbots may recommend resources to help factory

management identify the root causes of non-compliance and building the proper

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management systems to avoid repeated non-compliance. However, repeated failure to

make progress will result in revocation of approval as a Talbots’ production factory.

Talbots will review audit reports and determine the need to re-audit on a case-by-case basis.

The list below is not exhaustive but is representative of the most common reasons for re-audit

requests:

• There is alleged abuse of acceptable working hours or weekly rest

• There are alleged inadequacies in wages, overtime pay, or benefits

• Working conditions are dangerous or inhumane

A timeline for completion will be developed in consultation with the factory, vendor, and/or

Talbots’ agents. Reevaluation will occur sometime after the corrective action timeline is up,

and Talbots may require re-audits to be vendor-paid.

Talbots may prohibit or terminate business with any vendor or factory that:

• Has severely violated the Supplier Code of Conduct or any local law (i.e., underage or

forced labor)

• Is unable or unwilling to address initial audit findings

• Continues to be non-compliant after attempting to address re-audit findings

In the event of termination of business as a result of observed egregious Code violations and

termination causes orders to be cancelled, Talbots will not be responsible for any ensuing

liability related to order cancellation.

Following is detailed information about Talbots’ factory audit program by type of supplier.

d. Audits through Buying Agents

Talbots works with many vendors through a buying agent. Vendors and factories should

consider buying agent’s representatives as part of Talbots’ staff and treat them as such.

Where possible, the buying agent’s social compliance team will conduct initial social

compliance audits and annual factory social compliance audits on behalf of Talbots and

provide Talbots with audit findings. Vendor and factory management are expected to

review audit findings and agree to any corrective action recommendations that result from

the factory audit. At the conclusion of the audit, factory management is expected to agree

to an appropriate course of action for each finding, as well as to a time frame in these will be

completed. To reduce the incidence of duplicative corrective action plans, Talbots will

consult with its agents, vendors, or other brands, as appropriate, to determine its involvement

with the implementation process.

e. Third Party Audits

Talbots will use a third-party audit firm to perform independent audit verification and

additional social audit services on its behalf, particularly when working through U.S.-based

vendors, pursuing orders with direct vendors, and as due diligence to verify agent audits.

Vendor and factory management must to accommodate third-party auditors’ requests. Third

party auditors will leave behind preliminary corrective action plans, and Talbots will follow up

with the agent, vendor, or factory to determine next steps and implementation.

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f. Direct

When Talbots plans to import directly from overseas vendors, a third-party audit firm will

conduct vendor-prepaid annual social audits on Talbots’ behalf. The third-party auditors will

prepare a preliminary corrective action plan, which vendor and factory management are

expected to agree to; Talbots will review the audit and determine the need for any additional

follow up.

g. U.S. Based Vendors

In cases where Talbots sources product from a U.S.-based vendor, Talbots may waive initial

social compliance audits for factory on-boarding (usually limited to overseas non-apparel

factories]. Talbots requires the U.S.-based vendor to provide completed copies of the factory

self-assessment form. This form may be accompanied by (but not substituted by) evidence of

improvements made under another corrective action plan for another entity.

Talbots Factory Self Assessment Form.pdf

Audit Fatigue

Talbots recognizes that factories often undergo multiple ethical audits and corrective action

plans each year. To minimize duplicative audit activity, Talbots will, on a case-by-case basis,

accept social audits conducted on behalf of other retailers, provided:

• Audit was conducted according to the ETI Base Code (Sedex format);

• Audit was conducted within the last 9 months;

• Audit was conducted by an independent audit company, such as Intertek, SGS, STR, BV,

Verite, or Elevate;

• Supplier includes the completed corrective action plan resulting from the audit.

Even if Talbots waives an initial independent social compliance evaluation, Talbots

reserves the right to require an audit of any proposed factory by a Talbots-approved

independent auditor at any time. Talbots also requires annual factory evaluations

for U.S. based vendors.

h. Better Work Policy

Talbots strongly supports the ILO-IFC BetterFactories/BetterWork program, and encourages its

suppliers to participate in the program. To that end, Talbots will accept evidence of active

participation in a Better Factories or Better Work program in lieu of initial social compliance

audit as well as annual factory audits. As often as possible, Talbots will seek a Better Work

buyer subscription for participating factories producing for Talbots.

http://betterwork.org/global/

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IV. Customs and Trade Partnership Against Terrorism (C-TPAT) Overview

C-TPAT is a joint effort program between U.S. Customs and Border Protection (CBP), a division of

United States Department of Homeland Security (DHS), and the trade community, to reduce the

threat of terrorism by means of protecting the integrity of cargo imported into the United

States. This effort requires building cooperative relationships to strengthen the entire supply chain.

Talbots seeks to operate with the highest ethical standards in every aspect of our business,

including our supply chain operations. We expect vendors and factories with whom we partner

to also hold themselves to these high standards and to act with integrity, transparency,

accountability, and mutual respect.

Talbots is an active, re-validated participant in the C-TPAT program. We fully support the program

and are highly compliant.

Talbots reserves the right to suspend, discontinue, or terminate its relationship with any vendor or

factory that violates this C-TPAT Compliance Criteria, or any applicable law.

Talbots also reserves the right to make periodic updates to this C-TPAT Compliance Criteria and

will notify its vendors and factories of any such changes.

The following content outlines the tenets of our C-TPAT expectations and Talbots’ Compliance

Program.

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V. C-TPAT Compliance Criteria

a. Business Partner Requirements

Talbots requires that all vendors and suppliers meet and/or exceed the minimum criteria

outlined in the C-TPAT Foreign Manufacturers Security Criteria as posted on CBP website:

http://www.cbp.gov/border-security/ports-entry/cargo-security/ctpat/security-

guidelines/foreign-manufacturers

We expect suppliers producing Talbots merchandise to embrace and comply with these

standards, but also expect continuous improvement to secure the entire global supply

chain. Vendors and suppliers must abide by all local law. In the event that local law and this

C-TPAT Compliance Criteria are in conflict, the stricter standard shall apply.

Suppliers must develop security processes and procedures consistent with the C-TPAT

Compliance Criteria, including written and verifiable processes for selection of their carriers,

manufacturers, suppliers and vendors. Periodic reviews of these suppliers’ processes and

facilities will be conducted based on risk.

Talbots will annually request information and documentation from all vendors and suppliers

regarding security compliance criteria. All information will remain confidential. Further, Talbots

will not disclose identity of the supplier without the supplier’s consent, or at the request of CBP.

• Annual Vendor Security Certification

• Supplier Security Letter (container and seal inspection reports included)

• Supplier Security Self-Assessment

Vendors and/or Suppliers who have obtained a certification in a supply chain security

program being administered by Foreign Customs Administration are required to indicate their

status of participation to Talbots’ Customs Compliance team.

b. Container Security

Container integrity must be maintained to protect against the introduction of unauthorized

material and/or persons throughout the entire supply chain. Procedures must be in place to

ensure integrity is not compromised during storage, loading, and sealing of container.

Container Inspection

Physical integrity of the container structure and reliability of its locking mechanism must be

verified prior to stuffing. The below 7-point container inspection is required for all factory

loaded containers.

1. Front Wall

2. Left Side

3. Right Side

4. Floor

5. Ceiling/Roof

6. Inside/Outside Doors, Including Locking Mechanism

7. Outside/Undercarriage

Any container with integrity found to be deficient or questionable must be rejected.

All containers must be measured to include interior length, width and height. The following

information contains detailed specifications. (Source: www.apl.com)

http://www.cbp.gov/border-security/ports-entry/cargo-security/ctpat/security-guidelines/foreign-manufacturers

http://www.cbp.gov/border-security/ports-entry/cargo-security/ctpat/security-guidelines/foreign-manufacturers

http://www.apl.com/

13

Description Metric U.S.

Cubic Capacity 33.200 Cubic Meters 1,170 Cubic Feet

Payload (Weight) 21,850 kg – 28,160 kg 48,171 lb – 62,082 lb

Tare Weight 2,150 kg – 2,220 kg 4,740 lb – 4,894 lb

Max Gross Weight 24,000 kg – 30,480 kg 52,911 lb – 67,197 lb

Internal Length 5.898 m 19’4”

Internal Width 2.352 m 7’9”

Internal Height 2.392 m 7’10”

External Length 6.058 m 19’10 ½ ”

External Width 2.438 m 8’0”

External Height 2.591 m 8’6”

Door Opening Width 2.340 m 7’8”

Door Opening Height 2.280 m 7’6”

Lashing Rings • Five on each top and bottom rails, capacity 2,000 kg

• Three on each corner post, capacity 1,500 kg









External Length 12.192 m 40’0”





Lashing Rings • Ten on each top and bottom rails, capacity 2,000 kg

20’ Standard Steel Container

40’ Standard Steel Container

14















Lashing Rings • Ten on each top and bottom rails, capacity 2,000 kg




Payload (Weight) 28,280 kg 62,350 lb

Tare Weight 4,740 kg 10,450 lb

Max Gross Weight 33,020 kg 72,800 lb








40’ High Cube Steel Container

45’ High Cube Steel Container

15


Lashing Rings • Twelve on each top and bottom rails, capacity 2,000 kg


The outside and undercarriage must be inspected before entering your facility.

Undercarriage support beams must be visible from the outside. All seven points must be

inspected for unusual repairs. Repairs should be visible from both the inside and outside of a

container. Tap on walls, ceilings, doors and floors to listen for hollow sounds. Blocks and vents

should be visible on the inside of the container near the front wall.

Container Seals

All foreign vendors and factories (who manufacture quantities large enough to load a full

container), must have written and verifiable procedures stipulating how seals are controlled,

affixed and verified. These written procedures must include steps for recognizing and

reporting compromised seals and reporting to CBP or the appropriate foreign authority. Only

designated employees should distribute container seals for integrity purposes.

All seals must be high security seals that meet or exceed current PAS ISO17712 standards. All

containers transiting via mini-land bridge (MLB) service through the west coast must have a

‘Barrier Seal Model # MS-BAR11 with cable’ also affixed to the container. Talbots Freight

Forwarder will distribute as necessary.

Seals are required for both factory-loaded full containers and less than full container truck

shipments moving from factory to consolidator.

Talbots Container and Seal Inspection Reports must be completed by the party loading the

sea container and affixing the seal. The reports must be maintained by the party loading the

container and affixing the seal. Copies of the reports must be turned over to Talbots freight

forwarder with all commercial documents.

Container Storage

All containers must be stored in a secure area to prevent unauthorized access and/or

manipulation. Written and verifiable procedures must be in place for preventing and

reporting unauthorized entry into containers or container storage areas.

• All containers and trailers that remain at the warehouse overnight should be secured

• Containers loaded with cargo should be sealed, with seal number recorded and verified

• Identification of driver should be verified before cargo is released into their possession

• Truck drivers must have appointments and supervised when picking up containers from

the facility

c. Physical Access Controls

Access controls are instrumental in stopping unauthorized entry to facilities, maintaining

control of employees and visitors, and protecting company assets. Where possible, entrance

to facilities must be restricted to one office and one warehouse door. Entrances must be

monitored to ensure positive identification of all employees, visitors and vendors.

16

Employees

• Identification (ID) badges must be issued to all employees; badges visibly worn at all times

• Access to warehouses/storage areas must be restricted to designated employees

• ID badges must to be issued and strictly controlled by security

• Procedures for the issuance, removal and changing of access devices (e.g. keys, key

cards, etc.) must be documented

• No employee must be allowed to stay in the office or facilities after the working hours

unless permission is granted by company management

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Visitors Controls

• Visitors must present photo ID upon arrival for documentation purposes

• Visitors must sign in visitors’ log upon arrival and sign out upon departure; the logbook must

include visitors name, visiting date, visiting purpose, and arrival/departure time

• A “Visitor Badge” must be issued to all visitors and must be visibly worn at all times

• Visitor badges must be temporary and different color from employee badges for easier

identification

• Visitors must be escorted at all times within company premises

Challenging and Removing Unauthorized Persons

• Written procedures must be in place to train company employees to identify and

challenge the unauthorized visitors

• Unauthorized visitors should be reported to the company security immediately

• The local police should be informed if necessary

Deliveries (Including Mail)

• Proper vendor ID and/or photo identification must be presented for documentation

purpose upon arrival by all vendors

• Arriving packages and mail should be periodically screened before being disseminated

Building Security

• Access controls must include positive identification of all employees, visitors, and vendors

at all points of entry

• Access controls to prevent unauthorized entry to facilities

• Procedures enforced to maintain control of employees / visitors to protect company assets

• Employees must be familiar with all vendors entering the facility

• Facility must have communication process in place to contact internal security personal or

local law enforcement police in the event of an emergency

d. Personnel Security

Implementing personnel security measures is an important step in securing the supply chain.

Consistent with local laws and regulations, Talbots expects all vendors and factories to screen

prospective employees prior to employment and periodically check current employees to

ensure no risk to our supply chain.

Pre-Employment Verification

• The information provided on job applications such as employment history and references

must be verified prior to employment

• Criminal history of each job applicant must be verified with local police where allowed by

local laws

Background Checks/Investigations

• Consistent with local regulations, background checks and investigations should be

conducted on prospective employees

• Current employees should be checked and reinvestigated where deemed necessary

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Personnel Termination Procedures

• Upon dismissal, employee’s ID badge must be immediately obtained and destroyed

• Access to the facility and information systems access must be blocked (i.e. facility keys

must be seized)

• Current employees should be notified of the departure of any employee

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e. Procedural Security

Security measures must be in place to protect the integrity and security of processes relevant

to the transportation, handling and storage of cargo in the supply chain.

Documentation Processing

• All relevant information used for clearing customs must be legible, complete, accurate,

and protected against the exchange, loss or introduction of erroneous information

• Computer access must be controlled by password protection; employees must be

instructed not to share their passwords with others

Manifesting Procedures

• To ensure the cargo integrity, information received from business partners must be reported

timely and accurately

Shipping and Receiving

• Export cargo should be reconciled against information on the cargo manifest before

leaving manufacturer’s premises; cargo should be accurately described, and the weights,

labels, marks and piece count indicated and verified

• Export cargo should be verified against Talbots purchase orders

• All cargo received must be counted, weighed and matched against the bill of lading

• Drivers, delivering cargo or picking up containers, must be positively identified prior to

being admitted into premises; driver’s name, driver’s company and vehicle registration

must be verified and logged

• Departure Time of the cargo from manufacturer’s warehouse and Arrival Time of the cargo

at the Container Yard or the CFS must be recorded; if delivery time exceeds allowed time

range, the trucking company and driver must be questioned

Cargo Discrepancies

• Cargo shortages, overages, and other significant discrepancies or anomalies must be

investigated and resolved. Local law enforcement authorities should be notified if an

illegal or suspicious activity is noticed.

f. Security Training and Threat Awareness

Threat awareness programs must be established to recognize and foster awareness against

any threats posed by terrorists at each point in the supply chain.

• All employees must be informed of procedures in place for situations and how to report it

• Training should be provided to employees in the shipping and receiving areas, as well as

those receiving and opening mail

• Specific training should be offered to assist employees in maintaining cargo integrity,

recognizing internal conspiracies and protecting access controls – incentives should be

offered for active employee participation

g. Physical Security

Cargo handling and storage facilities must have physical barriers and deterrents, such as

locked doors to prevent unauthorized access.

Fencing

• All cargo handling and storage facilities must be surrounded by perimeter fencing

20

• Interior fencing should be used to segregate domestic, international, high value, and

hazardous cargo

• All fencing must be inspected periodically for integrity and damage

Gates and Gate Houses

• Entrance/exit gates through for vehicles and/or personnel must be manned and monitored

• Gates must be secured after working hours to prevent unauthorized access

• Number of gates should be kept to the necessary minimum for proper access and safety

• There must be a formal process in place for documenting visitors

Parking

• Employee and visitors parking spaces must be separate and marked

• Employee parking must be separate from the dock and cargo operations.

• Private passenger vehicles should be prohibited from parking in or adjacent to cargo

handling and storage areas to prevent unauthorized access

Building Structure

• Premises must be constructed of materials that resist unlawful entry (i.e. walls must be built

with concrete material and gates must be built with steel material)

• Premises must be periodically inspected and repaired, if necessary, to ensure constant

security

• Clear zones must be maintained internally and externally to monitor the security of the

facility; brush and growth should be cleared at least 35 feet from perimeter barrier

Locking Devices and Key Control

• All external and internal windows, gates. and fences must be secured with locking devices

• Management or security must control access and the issuance of all locks and keys

Lighting

• All entrances, exits, cargo handling, storage areas, fence lines, and parking areas must

have adequate lighting

• All corners of parking lots must be illuminated at night

• Flood lighting on loading and unloading areas

• Dock doors should be illuminated at night

Alarm Systems and CCTV Cameras

Security alarm systems and CCTV cameras should be utilized to monitor the premises and to

prevent unauthorized access to cargo handling and storage areas. Record retention for

CCTV recordings is a minimum of 90 days.

h. Information Technology Security

Password Protection

• Information systems must be based on individually assigned accounts and passwords must

be changed periodically

• IT security policies, procedures and standards must be in place and easily accessible by all

employees

21

Accountability

• A system must be in place to identify the abuse of IT including improper access, tampering

or the altering of business data

• Any illegal access attempt from third parties must be prohibited by installing and

maintaining firewalls, anti-spyware or other security software on each PC

• All system violators must be subject to appropriate disciplinary actions for abuse

• All backup data should be stored at an off-site location

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VI. C-TPAT Factory Audits & Rating System

Talbots must have visibility into the security procedures at all Talbots producing factories and at all

potential new factories. Vendors must allow initial security assessments of all factories proposed

for Talbots’ production.

Approved suppliers are required to adhere to the C-TPAT Security Criteria and all applicable local

laws and regulations. Talbots reserves the right to conduct unannounced audits of approved

factories at any time. Factories must allow Talbots representatives, or third parties authorized by

Talbots, unrestricted access to their facilities at all times; whether or not notification has been

issued in advance.

The factory rating system is based on the standards described in the C-TPAT Security Criteria.

Talbots C-TPAT ratings mirror the modified “traffic light” system of Social Responsibility. All audit

assessments will be reviewed and generated a rating, which will be communicated to the vendor

along with a corrective action plan (CAP). The rating and CAP will serve as a starting point for

discussion about C-TPAT compliance performance. Talbots’ ultimate goal is to work

collaboratively with vendors, factories, and buying agents to improve supply chain security.

a. Proposed Factories

As part of Talbots’ new factory introduction process to implement new factories, all import

factories will undergo a security evaluation by Talbots’ agent or Talbots nominated auditing

partner.

If the factory receives a rating below Talbots’ minimum requirements, it will not be approved

for production, but may have the opportunity to improve its rating through corrective actions

and subsequent follow-up audits to ensure security violations have been satisfactorily

addressed.

b. Active Factories

Security C-TPAT audits must be conducted at least once annually at all active factories to

verify security compliance. A timeline for corrective action will be developed and

communicated to the vendor and Talbots buying agent. Based on the audit rating and

progress of the CAP, Talbots will determine the follow-up audit schedule.

Annual audits may be conducted by Talbots buying agent and/or Talbots nominated

auditing partner.

Talbots reserves the right to prohibit or terminate business with any vendor or factory that:

• Has severely violated C-TPAT Compliance Criteria or any local law

• Is unable or unwilling to address initial audit findings

• Continues to be non-compliant after attempting to address re-audit findings

The above scenarios are reviewed by Talbots on a case-by-case basis.

c. Direct Vendors

When Talbots plans to import directly from overseas vendors, a third-party audit firm will

conduct vendor-prepaid C-TPAT security audit on Talbots’ behalf. A preliminary corrective

action plan will be prepared, which vendor and factory management are expected to agree

to; Talbots will review the audit and determine the need for any additional follow up.

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d. U.S. Based Vendors

In cases where Talbots sources from a U.S.-based vendor, an Annual Vendor Security

Certification must be completed, signed and returned to Talbots Compliance. Talbots may

require the vendor to submit a manufacturer completed Talbots security self assessment.

1

VII. Chapter 2A – Talbots Supplemental Guidelines

a. Introduction

The Talbots, Inc. is committed to conducting its business in accordance with the highest

ethical standards and in accordance with internationally recognized human and labor

rights. The Talbots Supplier Code of Conduct (“Code) establishes social compliance

standards for all of our suppliers, including contractors, vendors, and agents, to ensure the

working conditions in our supply chain are safe, workers are treated with respect and

dignity, operations are environmentally responsible, and business is conducted in an ethical

manner. The Supplemental Guidelines to Talbots Supplier Code of Conduct

(“Supplemental Guidelines”) are an extension of the Code, providing detailed and

practical guidance about our expectations. These guidelines inform our suppliers,

contractors, vendors, and agents of the employment practices and working conditions

that comprise the minimum standards for doing business with Talbots.

Suppliers must always be familiar with and comply with all relevant laws and regulations.

Adherence to the human and labor rights in our Code is a prerequisite for doing business

with our company. Where the Talbots Code requirements are stricter than the law,

compliance with the Code is required.

Supplier compliance will be evaluated according to the relevant laws and regulations and

these guidelines. Talbots expects our suppliers will openly and honestly discuss any non-

compliance issue and the underlying business challenges with Talbots or our

representatives. Violations will be reported to the supplier for follow up and corrective

action. Where there are egregious violations, such as child labor, forced or prison labor,

bribery, physical abuse, and/or the supplier does not demonstrate a willingness to comply,

Talbots reserves the right to discontinue business with the supplier.

If you have any questions that cannot be answered by reviewing the Supplemental

Guidelines, please contact us via email at [email protected].

mailto:[email protected]

2

b. Supplemental Guidelines - Compliance with Talbots’ Supplier Code of Conduct

Talbots seeks business partners who make compliance part of their day-to-day operations

by establishing affirmative measures and accountable management systems, including

effective policies and procedures, to help ensure instances of non-compliance do not

reoccur. As a measure and means of driving improvement in our supply chain, Talbots

maintains a program of regular social compliance audits. This includes initial compliance

assessments for the factories proposed for Talbots’ production, and regular evaluations for

active suppliers, on an announced or unannounced basis. As a condition of doing business

with Talbots, we expect suppliers to be cooperative and transparent during the audit

process and provide full access to the facility, workers, and records, as well as dormitories.

Documents and records provided on site must represent actual working conditions, and

employees must not be coached on how to answer questions or respond to inquiries by

Talbots or our representatives. The aim of Talbots’ evaluations is to identify problems,

establish root causes, and outline appropriate steps to achieve legal compliance and

sustainable improvement. For non-compliances with the Code and/or law, a corrective

action plan should be put in place; Talbots will monitor supplier progress towards

compliance and hold management accountable to the plan.

3

c. Policies and Procedures

Suppliers are better able to comply with local laws, Talbots Code of Conduct, and

international labor standards by implementing effective internal policies and procedures.

Therefore, suppliers are required to:

• Review and confirm internally the ability to comply with Talbots’ expectations (as

outlined in this document) and the associated actions they will take to achieve

compliance.

• Maintain current and accurate policies and procedures for each labor and

environmental provision of the Code (for example, child labor policy, age verification

procedures, waste management policy and procedures, etc.), and designate staff

responsible for implementing these policies, procedures, and related improvements.

Documentation should be available upon request to demonstrate effective

implementation of these policies and procedures and legal and Code compliance.

• Conduct internal assessments on a regular basis to ensure conformity to legal and

regulatory requirements and the Talbots Supplier Code of Conduct. Supplier must also

have a corrective action process for improvement of deficiencies identified by internal

or external assessments, inspections, investigations, and reviews.

• Ensure compliance with all legal changes (e.g., to the local minimum wage) and work

with factory staff to ensure the necessary changes are made to policies and procedures

in a timely manner to ensure compliance with the law.

• Train managers, staff, supervisors, and workers on the supplier’s Code of Conduct and/or

Talbots Supplier Code of Conduct; ensure all legally required notices are posted in the

factory at a central location.

• Establish a formal grievance system, including grievance procedures. The system should

be properly implemented, communicated at all levels, and allow for anonymity. Issues

should be reviewed by management upon receipt, discussed and responded to with a

sense of urgency, and properly filed with the issue and resolution.

4

d. Child Labor

Suppliers must comply with the minimum employment age and minimum compulsory

education level defined by national law or by the International Labor Organization

(not less than 15 years of age, subject to exceptions allowed by the ILO and national

law), whichever is higher. Suppliers must obey all legal requirements for work of

authorized minors, particularly those pertaining to hours of work, wages, minimum

education, and working conditions.

- Talbots Supplier Code of Conduct

Supplemental Guidelines

• All employees must be at least 15 years of age or meet the minimum legal working age of the

country, whichever is higher. Proof of age documentation is obtained and validated prior to

an employee’s start date.

• Suppliers’ hiring policy specifies minimum employment age restrictions that are compliant with

child labor provisions under the law and with Talbots Supplier Code of Conduct.

• Suppliers maintain a personnel file for each worker that includes, at a minimum, a copy of the

best age verification documentation available in the country of manufacture (for example,

government identification cards, passports, travel documents, social insurance cards, etc.) as

well as a recent photo. Where relevant documentation is difficult to obtain or unreliable,

suppliers use an appropriate and reliable assessment method to confirm employees meet the

minimum legal working age.

Young Persons/Minors

• Young Person is defined as any worker over the age of a child as defined above and under

the age of 18.

• Suppliers follow the law or ILO Conventions 138 and 182, whichever is stricter, with regard to

type of work performed by minors, including prohibitions on night shifts and hazardous work;

working hour limits; and annual medical checkups. Suppliers take all necessary precautions to

ensure that minors are protected from working conditions likely to endanger their health,

safety, or their moral integrity, and/or which harm their physical, mental, spiritual, moral, or

social development.

• Where required by law, the supplier is responsible for the expenses associated with registering

young workers with the local bureau and ensuring young workers receive any required

occupational health and safety education, training, and physical examination, and to

maintain documentation to demonstrate compliance.

• Suppliers maintain a list of workers who are restricted by their age to certain hours and

operations; the list includes the workers’ names, employee ID number, position, and the legal

restrictions on their work activities.

5

e. Forced Labor

Suppliers must not use any type of forced or involuntary labor, whether prison,

indentured, bonded, or other compulsory labor, and must ensure there is no forced

labor or human trafficking in their supply chains.



• Suppliers have a policy expressly prohibiting forced, bonded, indentured and prison labor.

• Suppliers do not use prison and/or detained labor in any form.

• All work, including overtime, is voluntary and freely chosen by workers, and not obtained

through the use of any form of force, fraud, or coercion.

• Suppliers ensure workers are not forced to work against their will, ability, or in a manner outside

of the provisions of a lawful labor contract.

• Suppliers pay all wages promptly and in full.

• Workers are allowed to freely move within the facility to use the toilets, drink water, take

designated breaks, and leave the facility at the end of their shift or after giving the employer

reasonable notice. Such movement is allowed without intimidation from supplier personnel or

security guards.

• Workers are free to refuse to perform tasks that they reasonably believe to be hazardous

without penalty of termination.

• Workers are able to leave the facility before the end of their shift under extenuating

circumstances, such as personal or family emergencies or illness, without fear of disciplinary

action, discrimination, or termination.

• Where required by law, supplier signs a written labor contract with workers to establish a labor

relationship within one month after the date the worker enters the factory. Where contracts

are not required by law, supplier provides documentation to verify workers have been made

aware of and agreed to the conditions of their employment, and provided with a written

summary or a company handbook of key terms and conditions of employment. This

information should be communicated verbally if needed.

• A worker may dissolve his labor contract by giving 30 days’ notice in writing to the factory.

• Signed employment contracts should include the information outlined below:

o Duration of the contract

o Minimum wage rates and overtime wage rates to be paid. Unless mandated otherwise by

law, these rates should be the same as the rates paid to local workers in the same job

category.

o Estimated minimum net pay that the worker can expect to receive per month.

o Maximum allowable voluntary overtime hours, consistent with the laws of the host country

and The Talbots Inc. Merchandise Supply Chain Code of Conduct.

o All benefits to be provided (including medical coverage, sick leave, annual leave and

holidays).

o All deductions to be taken (including deductions for food and housing).

6

o All recruitment fee restrictions (including all administrative and processing fees and any

other amounts paid to secure employment in the home country), if imposed by host or

home country laws.

o Amount of any return fee to be refunded to any worker who paid any recruitment fees to

obtain employment and who returns to his/her home country without completing the

contractual term, regardless of reason. The return fee will equal the estimated average

recruitment fees incurred by workers in their home country, less a pro rata portion based

on the actual duration of stay vs. the contractual term.

o Summary of living conditions, including any curfews.

o When foreign contract workers are used, employment contracts must be in workers’ native

language and executed in his or her home country; the original contract belongs to the

worker.

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f. Foreign Contract Workers

When a supplier employs foreign contract workers – defined as workers who sign an

employment contract to work at a factory outside their home country – Talbots

expects vendors and factories to take special care to protect these workers’

fundamental rights of liberty and movement, guarantee equitable treatment, and

ensure foreign workers are aware of their rights under the local law. In addition to

adhering to the guidelines outlined under Forced Labor, Talbots requires the following

with respect to foreign contract workers.



• Suppliers pay all host country fees and costs, including any levies, visa, work permit, renewal

fees or other costs associated with the use of foreign contract workers. Suppliers are responsible

for all transportation costs from the home to the host country.

• Suppliers do not restrict the movement of workers by controlling identity papers (passports, work

permits, etc.), withholding monetary deposits (personal protective equipment, uniform,

working tools, etc.), requiring excessive fees, etc. Workers have full control over their passports

and other identity documents. Suppliers obtain written consent before holding passport or

other documents for any employee. Where a supplier has written consent from a worker to

hold his/her documents, supplier immediately returns the documents to the worker upon

request. Otherwise, supplier only maintains photocopies of workers’ IDs for employment

records.

• Suppliers do not use salary deductions or withholdings as repayment of a bond or payment to

a third party. Suppliers do not employ tactics to prevent workers from leaving at will, such as

withholding salary for a “year-end bonus,” or charging “guarantee money,” recruitment fees,

or imposing a penalty when a worker terminates his/her contract. Suppliers do not charge

back or accept reimbursement from any foreign contract worker to recover any fees paid by

the supplier in the recruitment of hiring said worker.

• Suppliers only use recruitment agents or firms that are legally registered/licensed in the sending

and receiving countries of foreign workers. Suppliers take all reasonable steps necessary to

ensure that it does business with reputable agencies that do not charge workers fees in excess

of what is legally permitted by any applicable law of the host or home country. Suppliers

maintain a written agreement with the agency/agencies expressly requiring that total fees

paid by the worker must not exceed any such legal limits.

• Suppliers are responsible for ensuring that each foreign contract worker is eligible to work in the

country and receives an employment contract.

• Suppliers may not impose any additional terms or requirements on the workers after the

employment contract is signed (“contract switching”), unless expressly required by law.

8

• For any foreign contract worker who wishes to leave the factory for any reason and at any

time, the supplier must arrange and pay for the worker’s airfare and/or other reasonable

transportation costs home. Supplier pays to the worker any wages, benefits or other amounts

due and owed to the worker. These are provided to the worker at the same time as his or her

return to the home country.

• Suppliers maintain and make available to Talbots or its representatives upon request current

lists of all foreign contract workers employed at the factory, including the date of arrival,

contract duration, and anticipated date of return to their home country.

9

g. Discrimination

Discrimination in employment, including hiring, pay, benefits, job assignments, working

conditions, training, recruitment, promotion, discipline, termination, and retirement,

on the basis of gender, race, religion, age, disability, sexual orientation, gender

identity, parental status, pregnancy, nationality, political affiliation, and social or

ethnic origin is prohibited.



• Suppliers expressly prohibit discrimination in hiring, compensation, training opportunities,

promotion, termination, and retirement.

• Suppliers do not show any form of discrimination toward workers who are members of a trade

union.

• Suppliers do not retaliate against an individual for filing a charge of discrimination, participating

in an investigation, or opposing discriminatory practices.

• Suppliers do not question prospective workers about their pregnancy status. Pregnancy tests

may not be conducted before hiring or as a condition of employment.

• Suppliers ensure women returning from maternity leave are given an equivalent position and

equal pay.

• Suppliers do not use medical examinations to prevent a worker from being hired or fire a worker

who becomes ill or injured.

• Suppliers’ hiring notices do not specify discriminatory factors, such as gender or race.

10

h. Freedom of Association

Suppliers must recognize and respect the rights of employees to lawfully associate

and to bargain collectively. Suppliers may not interfere with, obstruct, or prevent

legitimate related activities, and must ensure workers are not intimidated, harassed,

or penalized for the non-violent exercise of their right to join or refrain from joining any

organization.



• Suppliers recognize freedom of association and the right to collective bargaining. Where

restricted by law, suppliers establish policies and procedures providing for parallel means of

worker organizing.

• Suppliers do not interfere with workers’ activities to associate or organize and respects the rights

of workers to join or refrain from joining the trade union, seek representation, and to bargain

collectively. Prohibited practices include, but are not limited to, employee termination and/or

denial of promotion or benefits to workers who try to join a trade union or bargain collectively.

• Where the right to freedom of association and collective bargaining is restricted under law,

suppliers do not hinder the development of parallel means for independent and free

association and bargaining.

• Suppliers do not interfere with lawful activities of trade union representatives.

• Where a collective bargaining agreement exists, suppliers comply with all contractual

provisions.

• Managers are trained on respect for freedom of association and the effective right to

collective bargaining.

• Workers have the right to be collectively represented by representatives they elect, or, when

appropriate, appointed by their trade union. Suppliers do not discriminate against worker

representatives and ensure they have regular access to company management in order to

address grievances and other issues.

• Workers are able to communicate openly with management, on their own or through a worker

representative, regarding working conditions without fear of reprisal, intimidation, harassment,

or discrimination.

11

i. Harassment and Abuse

All workers must be treated with dignity and respect. No worker may be subjected to

physical, sexual, psychological, or other forms of mental or physical coercion,

harassment, abuse, or intimidation. Suppliers are expected to implement reasonable

procedures for disciplining and/or terminating workers and maintain documentation

to demonstrate compliance. The use of fines as a disciplinary practice is prohibited.



• Suppliers have standardized rules/regulations and policies and procedures on acceptable and

unacceptable disciplinary practices, and clearly communicate these to management and

employees. All disciplinary actions are documented to demonstrate compliance.

• Physical abuse or discipline, the threat of physical abuse, sexual or other harassment, verbal

abuse, or other forms of intimidation are prohibited. This includes, but is not limited to:

o Physical harassment or abuse: Use or threatened use of the any form of violence.

o Verbal abuse: Shouting, threatening, or using humiliating words towards a worker;

threatening explicitly or implicitly to withhold employees’ wages, benefits, access to food,

opportunities for advancement and employment.

o Sexual harassment and abuse: Unwelcome sexual advances, requests for sexual favors,

and/or other verbal or physical conduct of a sexual nature. Examples: Requiring any form

of sexual favor in exchange for beneficial treatment in employment, or as a condition of

maintaining employment; touching workers in any way that could be considered to have

sexual implications; and making inappropriate sexual comments to workers.

o Mental abuse: Use of words or action that are reasonably understood by a worker as

demeaning.

• Suppliers ensure the confidentiality of the grievance process to protect employees from

retaliation for reporting harassment or abusive behavior.

• Body searches, if necessary, may not be conducted by the opposite sex.

12

j. Health and Safety

Conditions in all production facilities must be safe, clean, healthy, and consistent with

all applicable laws, regulations, and supplemental guidelines of this Code, to avoid

preventable work-related accidents and injuries. Supplier-provided employee

housing, bathing, and toilet facilities must be safe, clean, and adequate to the

number of employees. Where higher than the law or the Code requirement, suppliers

should implement industry best practices.



General Health and Safety

• Suppliers comply with all applicable laws and regulations on occupational health and safety

in its operations.

• Suppliers keep abreast of industry operational best practices and must have a policy and plan

to achieve higher standards on a continuous improvement basis.

• Suppliers ensure all workers receive formal training in general safety procedures, and ensure

workers are appropriately trained and supervised to perform their jobs safely. Suppliers provide

workers with appropriate training on dangerous machinery.

• Suppliers appoint at least one qualified occupational health and safety expert (by education

or experience) responsible for governing health and safety in the workplace and/or residential

facilities.

• Suppliers establish an EHS committee with at least 50/50 representation by employees and

management (Note: Managerial/ supervisory representation shall not be in ratio greater than

employee representation, e.g. 60 managerial /40 employees.)

• Suppliers conduct regular monitoring to check that health and safety procedures are being

followed.

• First-aid kits are provided as recommended by the local medical provider or as required by

law and must be kept in sanitary condition and contain no expired items. Depending on the

risk and size of the factory, each production area/shift has an adequate number of workers

trained to treat common workplace injuries.

• All sewing machines are equipped with adequate guards (e.g. eye protection, needle guards,

pedal mats, etc.).

• Facility is kept generally clean and hygienic, in accordance with the law. This includes regular

and systematic refuse collection.

• There are a reasonable number of clean, operating toilets that offer privacy (i.e., ability to lock

doors), and a ventilation system to provide good circulation of air.

• Potable drinking water is provided to all workers; periodic testing is conducted on all drinking

water to ensure its safety.

• Food service and storage areas are kept clean and hygienic. Where required by law, suppliers

must have the necessary inspections from government health officials and must maintain

records of these inspections.

13

• Suppliers have a process for hazard/risk identification and management, and provide

appropriate training for workers involved in high risk processes, such as the use of toxic

substances and dangerous machinery.

• Chemicals are properly stored and labeled with Material Safety Data Sheets (MSDS) made

available to workers in the local language.

• Flammable and combustible chemicals are segregated from oxidizing chemicals, reactive

chemicals, electrical sources, etc. (Appendix B)

• Suppliers provide emergency eyewash stations and/or showers where corrosive chemicals or

high volumes of solvents are handled and used.

• Suppliers ensure adequate ventilation where paints, chemicals, and sprays (solvents, solder,

dust) are used to prevent accumulation of flammable vapors.

• Suppliers provide appropriate personal protective equipment (PPE)/clothing for workers and

machines, and ensure workers are trained on how to use the PPE and why it is required and

critical for safety. Further, supervisors should regularly enforce its use.

• In high noise level areas, ear protection (ear plugs) is provided, potential hazards are

communicated, and worker usage is enforced in an appropriate manner.

• Machinery, equipment, and fixtures are checked regularly to ensure that they are in safe

working condition. Documentation must be maintained to demonstrate compliance.

• Suppliers maintain injury records; all significant accidents and near misses must be investigated

and reported and corrective action performed to minimize the likelihood of any re-

occurrence.

Emergency and Fire Preparedness

Suppliers ensure:

• Fire and emergency evacuation plans are communicated and diagrams in the local

language(s) are posted in various locations around the facility. The plan illustrates critical

information such as emergency evacuation routes, “you are here” mark, correct layout

direction, location of fire extinguishers and hydrants, and instructions in the local language of

what to do in the event of an evacuation.

• Evacuation drills are conducted regularly, at least annually or more often where required by

law.

• Emergency exits remain unlocked and free from obstruction at all times. Exits are kept

unlocked, open outwards, are clearly marked, and lead to the outside. Doors that are not

exits are labeled as such, i.e., “NOT AN EXIT”.

• Exit routes are not obstructed by equipment, materials, production, etc. (internally and

externally), and are regularly checked.

• The number of emergency exits is in accordance with the local law. At a minimum, or in the

absence of the law, supplier has at least two emergency exits per floor in buildings with less

than 1,000 workers and at least three exits exist per floor in buildings with more than 1,000

workers.

• Fire alarm system is audible throughout the entire facility. The system is inspected regularly and

tested in coordination with fire drills.

• Fire extinguishers are of the correct type, and with a minimum of one fire extinguisher per 100

m2 or at least two on every level if the total surface is below 200 m2

14

• Fire equipment, including fire extinguishers, is easily accessible, clearly marked, and routinely

inspected to ensure they remain operational.

• Fire extinguishers are serviced every year; service date must be indicated on the extinguisher

or service reports must be available to demonstrate compliance.

• Emergency lighting is included in all stairways, and where needed, on exit routes. The lighting

is inspected regularly.

• Designated supplier personnel (workers and supervisors) are trained at regular intervals in fire

safety, the use of fire extinguishers, and how to administer the fire prevention procedures and

emergency evacuation plan.

• Emergency and other hazard signage is appropriate, clearly visible, and compliant with local

legal requirements.

• No smoking signs are posted in non-designated smoking areas including sensitive areas such

as chemical storage areas.

• Floors are kept clean from hazardous spills and materials.

• Fabric, yarn, and finished goods are appropriately stacked and stored in designated areas

away from production, evacuation routes and electrical sources.

• Electrical equipment and wiring is properly maintained and covered/insulated to prevent

exposure of wires.

• Gas cylinders are properly marked, used, inspected, stored, and secured.

• Railings guard all stairs, platforms, and elevated floors.

• Suppliers maintain a separate/standalone chemical area equipped with the appropriate fire

extinguishers, safety signs, ventilation, instructions on handling and disposal of the chemicals,

and personal protective equipment for workers.

• The generator and other heavy vibrating equipment, such as boilers, are not allowed beyond

the ground floor and must be isolated from any production area.

• No room or area in the facility shall be overcrowded as defined by the building permit, which

should indicate the maximum number of people the building is approved to hold.

• The structure of all buildings, including residential facilities provided by the supplier, is stable

and safe and does not put people in jeopardy.

• Buildings are not located near sources of high risk, such as chemical plants or filling stations.

• Building inspections must be conducted on a regular basis as per standard of practice or

country law.

• The building is approved for industrial use.

• The factory is aligned with the approved building plan, with no additional floors or external

retrofit structures.

• A valid Fire License is obtained for all production buildings and any residential facilities.

15

Supplier-Sponsored Dormitories

All health and safety guidelines listed above are implemented in supplier sponsored dormitory

buildings. In addition:

• Dormitories are not attached to any production or warehouse building.

• Accommodations are generally kept clean, provide a safe, hygienic living environment for

workers, and comply with all legal regulations regarding residential facilities, where provided.

• Clean and safe drinking water is provided at dormitories and regularly tested.

• Toilet and shower facilities are kept clean and separated by gender.

• Residents have their own bed, an area for personal items, and the ability to secure belongings.

• Unless local law is stricter, suppliers follow the International Labor Organization’s (ILO) with

respect to the size of sleeping rooms: 7.5 square meters in rooms accommodating two persons;

11.5 square meters in rooms accommodating three persons; or 14.5 square meters in rooms

accommodating four persons. If a room accommodates more than four persons, the floor area

should be at least 3.6 square meters per person.

• Unless local law is stricter, suppliers should follow ILO recommendations on number of operating

toilets and showers: a minimum of one toilet, one wash basin, and one bathtub or shower for

every six persons.

• Toilets offer privacy (i.e., ability to lock doors) and a good ventilation system to provide good

circulation of air to reduce odors.

• Dormitory residents are free to come and go during their off-hours under reasonable limitations

imposed for their safety and comfort.

• Hazardous and combustible materials used in the production process are not stored in the

dormitory or in buildings connected to sleeping quarters.

16

k. Working Hours

All work must be voluntary, without threat of penalty, punishment, or dismissal. Workers

must not be required to work more than 60 hours per week (inclusive of overtime), or

more than the regular and overtime hours allowed under local law, on a regularly

scheduled basis. Workers are entitled to at least one day off in every seven-day period.



Employees may work more than 60 hours in a week so long as the supplier complies with the

following supplemental requirements:

• Working hours do not exceed 12 hours per day, 6 days per week for a total of 72 hours.

• One day off per seven day period is provided, or workers are provided another day of rest

during the week. If work must be carried out on the rest day during peak season, it cannot

occur more than once in a two week time period.

• Peak season is limited to no more than 4 months or 17 weeks distributed throughout a one-year

period. The maximum 60-hour workweek for non-peak production should be employed for at

least 8 months out of 12.

• Workers are compensated for regular and overtime hours in accordance with the law.

• Suppliers use a reliable time recording system, all hours are tracked, and time cards accurately

reflect the real working hour situation in the facility.

• The timekeeping system accurately records daily start/finish times, overtime, and rest day

hours, for all hourly and piece rate employees. Further, it allows employees to record their own

start/finish times (i.e., punch in and out for themselves) and/or be regularly confirmed by

workers’ signatures.

• Manual or electronic time cards should be used for hourly workers. For “piecework” workers,

an industry recognized system, capable of audit verification, should be used.

• Legal working hours and supplier working hours/schedules are made available to all workers.

Workers have access to their own attendance records upon request.

• Attendance records are maintained on site for at least 12 months.

17

l. Wages and Benefits

Suppliers must comply with the minimum wages and benefits required by local law or

the local industry standard, whichever is higher. Workers must be paid for overtime

hours at the premium rate legally required in the country of manufacture. In those

countries where overtime compensation laws do not exist, employees must be

compensated at least equal to their hourly compensation rate.



• Wages and benefits paid for a standard work week meet, at a minimum, national legal

standards or industry benchmark standards, whichever is higher.

• Overtime wages are paid for all time legally defined to be over the regular working hours,

regardless of whether the supplier pays according to hours worked or piece rate.

• Wages are paid in a timely manner, based on the law, and in the form of the local currency.

• Suppliers maintain a payroll register documenting payment of wages to each worker by hour,

day, month, or piece as appropriate. Payroll accurately records regular hours, overtime hours,

holiday pay, etc.

• Suppliers provide benefits as required by law, including public holidays, paid leaves, social

insurance and medical benefits.

• Irrespective of worker type (part time, student workers, etc.), all employees receive at least

minimum wage. Further, suppliers provide equal pay for same or similar jobs, based on relevant

experience.

• Suppliers provide pay slips to each employee in a language he or she understands. Information

should include pay period, payment date, total pay, regular and overtime hours and wages,

itemized deductions, and any allowances, incentives, benefits, or bonuses.

• Obligations to employees under labor or social security laws and regulations arising from the

regular employment relationship are not avoided through the use of labor-only contracting,

sub-contracting, or home-working arrangements, nor shall any such obligations be avoided

through the excessive use of fixed-term contracts of employment or through apprenticeship

schemes where there is no real intent to impart skills or provide regular employment.

• Any probationary employment period cannot exceed legal limits and a worker should have

no more than one probationary period. Once the probationary period is over, a worker’s

seniority date should be the date of entry to the facility, i.e., the start date of the probationary

period.

• During any probation period, a worker’s wages may not be less than the lowest wage paid for

the equivalent job post within the facility or less than the wage agreed upon in the labor

contract, nor may it be lower than the minimum wage standard of the supplier.

• Deductions from wages as a disciplinary measure are not permitted.

• Deductions, where legal, are reasonable and appropriate, and optional when related to

services such as accommodations, transportation, and food.

18

• Suppliers provide workers with the tools necessary to perform their jobs and may not require

workers to pay for such tools.

• Current and accurate payroll, wage and hour, and personnel files for all employees, dating

back at least 12 months or as required by law. In addition, a summary of active employees is

available upon request and includes, at a minimum, each employee’s name, address, phone,

date of birth, hire date, position, etc. Records for resigned or terminated employees should be

maintained for at least 12 months after an employee leaves the facility.

19

m. Subcontracting

Suppliers may not subcontract any operation in the manufacturing process without

prior written consent from Talbots, and only after the subcontractor has agreed to

comply with Talbots’ Code of Conduct.



• Suppliers may not subcontract any operation in the manufacturing process without requesting

and receiving written consent from Talbots; any subcontractor must agree to comply with

Talbots Supplier Code of Conduct. Subcontracting includes the use of home workers.

• Suppliers ensure subcontractor(s) managers, staff, supervisors, and workers are aware of

relevant laws and Talbots Supplier Code of Conduct requirements.

• Supplier assesses all approved subcontractors, based on Talbots Supplemental Guidelines, and

monitors progress made against any Corrective Action Plan (CAP) created to address the non-

compliance issues.

20

n. Environmental Practices

Suppliers, at a minimum, must meet all relevant local and national environmental

protection laws, and must strive to comply with international environmental

protection standards.



• In the event hazardous or polluting materials are discharged improperly, suppliers notify the

appropriate authorities and take immediate remedial actions.

• Suppliers monitor their work environment for appropriate air emission levels for chemicals and

pollution, waste management procedures, and other areas that may present hazards to

employees and the community as a whole.

• Suppliers maintain and keep up-to-date, relevant health, safety and environmental permits as

required by applicable laws and regulation, and their operational and reporting requirements

are followed accordingly.

21

o. Business Integrity

Suppliers must comply fully with the applicable laws and regulations of the countries in

which they operate. In addition, business must be carried out ethically, honestly, and

fairly. Suppliers must not, directly or indirectly, make any improper or unlawful gifts or

payments to any person, entity, or government official in connection with accepting

or performing orders for Talbots, or in an attempt to impact the objectivity of third party

representatives appointed by Talbots to carry out inspections and compliance audits.



• Suppliers should have an anti-corruption and bribery policy and procedures to prevent

employees or persons associated with its business from committing offences of bribery or

corruption.

• The offering, paying, soliciting, or accepting of bribes or kickbacks, including facilitation

payments, is strictly prohibited.

o A bribe may involve giving or offering ANY form of gift, consideration, reward or advantage

to someone in business or government in order to obtain or retain a commercial

advantage or to induce or reward the recipient for acting improperly or where it would be

improper for the recipient to accept the benefit. Bribery can also take place where the

offer or giving of a bribe is made by or through a third party, e.g., an agent, representative

or intermediary.

o Facilitation payments are small payments or fees requested by government officials to

speed up or facilitate the performance of routine government action (such as the provision

of a visa or customs clearance). Such payments are strictly prohibited.

• Suppliers may not offer compensation of any value (gifts, discounts, services, loans, facilitation

payments) to any Talbots associate, service provider, or government/political official to

influence any act or decision to secure a business advantage.

• Suppliers, representatives, and their employees comply with all applicable anti-bribery and

corruption laws.

22

p. Sanctions

Suppliers must not cause Talbots to violate U.S. and other applicable economic sanctions laws and

regulations (collectively, “Sanctions”), which are laws and regulations that restrict business with

certain countries, individuals, and entities in order to advance specific foreign policy and national

security priorities.



Suppliers should not, in the course of business related to Talbots:

• Conduct any business involving, directly or indirectly, countries or territories subject to

Comprehensive Sanctions (as defined below) unless authorized under Sanctions, or

• Engage, directly or indirectly, in any business with persons (i.e. individuals or entities) that are

designated on U.S. or other applicable restricted party lists.

The U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”), is the primary U.S.

government agency responsible for administering U.S. Sanctions. OFAC maintains four types of

sanctions programs, summarized as follows:

I. Comprehensive Sanctions U.S. persons (defined as U.S. citizens, U.S. lawful permanent

residents, persons located in the United States, and U.S.-incorporated entities and their

non-U.S. branches) cannot engage in any direct or indirect (e.g., through a third party)

transactions or dealings with any counterparty located in a comprehensively

sanctioned country, unless authorized under U.S. law.

As of February 28, 2022, the list of comprehensively sanctioned countries are CUBA,

IRAN, NORTH KOREA, SYRIA AND THE CRIMEA, DONETSK, AND LUHANSK REGIONS OF

UKRAINE. In addition to the above programs, as of February 28, 2022, OFAC is

maintaining an embargo on the Government of VENEZUELA, which when combined

with the other sanctions on Venezuela described herein, makes Venezuela a country

subject to nearly comprehensive Sanctions.

II. List-Based Sanctions - OFAC sanctions target entities and individuals designated on

OFAC’s sanctions lists, including the List of Specially Designated

23

III. Nationals and Blocked Persons (the “SDN List”) OFAC considers any entity 50% or more

owned, directly or indirectly, and in the aggregate, by individuals or entities identified

on the SDN List to be “blocked” and subject to the same restrictions as SDNs, even if

the entity is not itself designated on the SDN List.

The SDN List is available on OFAC’s website at http://www.treasury.gov/resource-

center/sanctions/SDN- List/Pages/default.aspx Other OFAC sanctions lists are found

at:http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/Other-

OFAC-Sanctions-Lists.aspx.

VI. Sectoral Sanctions - These sanctions target specific sectors of a country’s economy.

Designated persons under the sectoral sanctions are added to OFAC’s Sectoral Sanctions

Identifications (“SSI”) List. Unlike with persons added to the SDN List, U.S. persons and

companies may engage in business with persons on the SSI List in some instances, as only

certain types of dealings are prohibited.

As of February 28, 2022, the main sectoral sanctions that OFAC imposes relate to the

Russia/Ukraine/Belarus and Venezuela sanctions programs.

Talbots, and other U.S. persons, are prohibited from providing assistance of any kind that would

facilitate transactions with sanctioned countries or persons by third parties, including referrals of

sales opportunities, approvals, or brokering. Talbots will review the identity and location of third

parties prior to dealings in order to ensure compliance with Sanctions.

http://www.treasury.gov/resource-center/sanctions/SDN-%20List/Pages/default.aspx

http://www.treasury.gov/resource-center/sanctions/SDN-%20List/Pages/default.aspx

http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/Other-OFAC-Sanctions-Lists.aspx

http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/Other-OFAC-Sanctions-Lists.aspx

24

q. Anti-Money Laundering

Suppliers must not cause Talbots to violate applicable anti-money laundering laws and regulations,

including the Currency and Foreign Transactions Reporting Act of 1970 (commonly referred to as

the “Bank Secrecy Act”), as amended by the Uniting and Strengthening America by Providing

Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (commonly referred to

as the “USA PATRIOT Act”) (all such laws, collectively, “AML Laws”).



The Company is not a financial institution or money services business, and as such, certain

aspects of U.S. AML Laws do not apply to its operations. It is the Company’s policy to comply with

its obligations under U.S. AML Laws, specifically with risks associated with third parties.

Any Supplier who suspects, in the course of business related to Talbots, that any activities or

arrangements that appear suspicious or indicative of money laundering or other unlawful

conduct should report them immediately to Talbots. Suppliers may not inform any other party,

including the third party in question, regarding any such suspicion, as doing so could be a

violation of AML Laws.

The following is a non-exhaustive list of “red flag” indicators and arrangements that may

generally be considered suspicious under AML Laws, and that may arise at any time during a

third-party relationship:

• Presentation of identifying documents that appear forged, altered, or otherwise invalid

• Multiple persons or accounts that share the same name, address, telephone number, or

other identification, but otherwise appear unrelated;

• Accounts funded by one individual or entity and then transferred to an apparently

unrelated individual or entity; and

• Financial activity that generally appears inconsistent with a third party’s stated objectives

or financial circumstances, or the Company’s understanding of the third party.

SUPPLEMENTAL GUIDELINES

APPENDIX A: DEFINITIONS

Bonded Labor

Work for an employer not for compensation received by the worker, but to pay off a debt, which is

often incurred by another worker offering the worker’s labor in exchange; a form of forced labor

Collective Bargaining

The negotiation of wages and other conditions of employment by an organized body of

employees, often a trade union

Corrective Action

A corrective action is a change implemented to address a weakness or non-compliance identified

in an audit. It is the action taken to correct any non-compliance which has been found in an

assessment to an agreed standard.

Corrective Action Plan (CAP)

The document completed after the audit which confirms the findings and any agreed necessary

corrective actions that must be improved to meet Talbot’s compliance standards and/or local law

Excessive Fees

Fees charged to a worker in excess of the amount legally permitted by any applicable law of the

host or home country, or, in the absence of such law, fees substantially above the prevailing market

rate

Freedom of Association

The principle of freedom of association and the effective recognition of the right to collective

bargaining guarantees to workers the right to join or form an organization of their own choosing

and to act together to protect their own economic interests. When protected by law in the

country in which merchandise is manufactured, workers must be able to carry out trade union

activities without interference from their employer or from public authorities.

Forced Labor

All work or service that is extracted from any person under the menace of any penalty for which

said person has not offered him/herself voluntarily; work or service demanded as a means of

repayment of debt (see bonded labor). The fact that the worker receives a salary or a wage is

irrelevant to determine if a situation can be considered as forced or compulsory labor.

Grievance Procedures

A process or procedure for workers who may feel that they have been treated unfairly to voice

their concerns without fear of repercussion

Harassment

Any offensive conduct or actions, whether physical, verbal, sexual, or psychological in nature, that

threatens human dignity and worker morale

Hazardous Work

Hazardous work includes working with dangerous machinery/ equipment (e.g. knives, saws);

chemicals or hazardous substances; noisy environments; lifting heavy things; extreme cold or hot

conditions. Hazardous work is one of the worst forms of child labour, as defined in ILO Convention

No. 182. For details on Children in Hazardous Work, click here.

http://www.ilo.org/ipecinfo/product/viewProduct.do?productId=17035

Human Rights

A set of principles defined in the Universal Declaration of Human Rights (1948), based on the

recognition of the inherent dignity and the equal and inalienable rights of all members of the

human family as the foundation of freedom, justice and peace in the world

Indentured Labor

Work performed on behalf of an employer who forbids workers from leaving employment at the

worker’s discretion

International Labor Organization (ILO)

The ILO is the international organization responsible for drawing up and overseeing international

labor standards. It is the only 'tripartite' United Nations agency that brings together representatives

of governments, employers, and workers to jointly shape policies and programs promoting Decent

Work for all.

ILO Convention No. 138 on the Minimum Age for Admission to Employment and Work

This Convention was adopted in 1973 by the International Labor Organization. It requires ratifying

states to pursue a national policy designed to ensure the effective abolition of child labor and to

raise progressively the minimum age for admission to employment or work. For details on ILO

Convention No. 138, click here.

ILO Convention No. 182 on the Worst Forms of Child Labor, 1999

Convention No. 182 helped to focus the international spotlight on the urgency of action to

eliminate as a priority, the worst forms of child labor, without losing the long term goal of the

effective elimination of all child labor. Click here for details on ILO Convention No. 182.

Juvenile Worker (or “Minor”)

Any worker over the age of a child as defined by local or national law and under the age of 18

Material Safety Data Sheet (MSDS)

A material safety data sheet is a form that references the properties of a substance and proper

handling instructions. A MSDS is not intended for general consumer use, but rather

industrial/manufacturer users and safety personnel that may come in direct contact of the

substance. MSDS forms may contain detailed information such as physical property data, health

effects, first aid, storage recommendations, disposal requirements, necessary protective equipment

for handling, and instructions on how to handle spills, etc.

Piece Rate

A method of paying workers by the number of items they produce, rather than the number of hours

they work

Subcontractor

A business, individual, or group of individuals to whom a supplier outsources the manufacture of a

product or part-product

Trade Union (or “Union”)

An organization of workers that promotes and protects the interests of its members in issues such as

wages and working conditions, especially through collective bargaining negotiations with

employers

http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO:12100:P12100_ILO_CODE:C138

http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO:12100:P12100_ILO_CODE:C182

SUPPLEMENTAL GUIDELINES

APPENDIX B: POCKET GUIDE TO CHEMICAL HAZARDS

Chemical Name Fire

Hazard Category Potential uses Target Organs/Health Hazards /Routes Chemical type

Acetic Acid Y Combustible Reagent, used in

washing

Eye, skin, nose, throat irritation; eye, skin burns;

skin sensitization; dental erosion; black skin,

hyperkeratosis; conjunctivitis, lacrimation

(discharge of tears); pharyngeal edema,

chronic bronchitis

Colorless liquid or crystals

with a sour, vinegar-like odor

[Note: Pure compound is a

solid below 17°C/62°F. Often

used in an aqueous

solution.]

Acetone Y Flammable

Softener, diaper rinse

ingredient, feed

additive

Eye, nose, throat irritation; headache,

dizziness, central nervous system depression;

dermatitis

Colorless liquid with a

fragrant, mint-like odor

Alcohol Methyl Y Flammable Solvent

Eye, skin, upper respiratory system irritation;

headache, drowsiness, dizziness, nausea,

vomiting; visual disturbance, optic nerve

damage (blindness); dermatitis


characteristic pungent odor

Ammonia Reactive

Universal reagent

diluted with water and

used in aqueous form

Inhalation, ingestion (solution), skin and/or eye

contact (solution/liquid) irritation eyes, nose,

throat; dyspnea (breathing difficulty),

wheezing, chest pain; pulmonary edema;

pink frothy sputum; skin burns, vesiculation;

liquid: frostbite

Colorless gas with a

pungent, suffocating odor

[Note: Shipped as a

liquefied compressed gas.

Easily liquefied under

pressure.]

Antistain

(Group of chemicals) Non Flammable

De-staining agent/

stain remover

Eye irritant, avoid eye contact; use eye

protection

Solution containing sodium

per carbonate and sodium

carbonate

Benzene Y Flammable

Strong oxidizers, many

fluorides &

perchlorates, nitric

acid

Eye, skin, nose, respiratory system irritation;

dizziness; headache, nausea, staggered gait;

anorexia, lassitude (weakness, exhaustion);

dermatitis; bone marrow depression;

[potential occupational carcinogen]

Colorless to light-yellow

liquid with an aromatic

odor. [Note: A solid below

6°C/ 42°F]

Bleaching Powder

Laundry Non Flammable

Bleaching agent

/washing/disinfectant

Avoid inhalation, ingestion, eye and skin

contact; irritation possible

Solid containing sodium

sulphate and alkyl aryl

suphonate

Detergent Liquid Non Combustible Used in washing

/process cleaning Eye irritant, harmful if swallowed

Viscous fluid, soluble in

water

Diesel Y Combustible Fuel Skin irritation, allergy on prolonged exposure

through physical contact

Liquid with petroleum /

hydrocarbon odor

Chemical Name Fire


Dry Cleaning Solvent

(Stoddard solvent) Y Flammable Solvent cleaner

Eyes, nose, throat irritation; dizziness;

dermatitis; chemical pneumonitis (aspiration

liquid); in animals: kidney damage


kerosene-like odor

Enviro Floc Salt (Combustible) Flocculent for water

treatment etc. Skin, eye contact, mild irritation

Solid, odorless white

granules (hydrated

ammonium and calcium

nitrate)

Enzymes Non Flammable

Used in reaction for

hydrolysis of cellulose

etc.

Skin, eye irritation also irritation to mouth and

throat

Amber color liquid or solid

with characteristic order

Ethylene Dichloride Y Flammable Solvent/degreaser

Eyes, skin, kidneys, liver, CNS, cardiovascular

system, (stomach, mammary gland and

circulatory system cancer in animals)


pleasant, chloroform-like

odor [Note: Decomposes

slowly, becomes acidic &

darkens in color]

Ethylene Oxide Y Flammable /

Reactive Sterilizing agent

Eyes, skin, respiratory system, liver, CNS, blood,

kidneys, reproductive system (peritoneal

cancer, leukemia)

Colorless gas or liquid

(below 11°C/51°F) with

ether-like odor

Formaldehyde Combustible Preservative Eyes, respiratory system (nasal cancer)

Nearly colorless gas with a

pungent, suffocating odor.

[Note: Often used in

aqueous solution (see

specific listing for Formalin).]

Hydrochloric Acid Reactive

Reagent for process/

lab use / reaction

neutralization

Inhalation, ingestion (solution), skin and/or eye

contact, irritation nose, throat, larynx; cough,

choking; dermatitis; solution: eye, skin burns;

liquid: frostbite; in animals: laryngeal spasm;

pulmonary edema

Colorless to slightly yellow

gas with a pungent, irritating

odor. [Note: Shipped as a

liquefied compressed gas.]

Hydrogen Peroxide

(Concentrate) Oxidizer Bleach

Eye, nose, throat irritation; corneal ulcer;

erythema (skin redness), vesiculation skin;

bleaching hair

Colorless liquid with a slightly

sharp odor

Liquefied Petroleum

Gas (LPG) Y Flammable Fuel Inhalation, skin and/or eye contact (liquid)

Colorless, noncorrosive,

odorless gas when pure.

[Note: A foul-smelling

odorant is usually added.

Chemical Name Fire


Shipped as a liquefied

compressed gas.]

Methyl Isocyanate Y Combustible Urethane mfg. Eyes, skin, respiratory system

Methyl Chloride Y Flammable Solvent CNS, liver, kidneys, reproductive system (lung,

kidney & stomach tumors in animals)

Colorless gas with a faint,

sweet odor which is not

noticeable at dangerous

concentrations. [Note:

Shipped as a liquefied

compressed gas]

Methyl Ethyl Ketone Y Flammable Solvent Eye, skin, nose irritation; headache; dizziness;

vomiting; dermatitis


moderately sharp, fragrant,

mint- or acetone-like odor

Methylchloroisothia-

zolinone Y Combustible Preservative Eyes, skin, respiratory system

Biocide added in PPM levels

liquid

Nitric Acid Reactive Reducing agent/

reagent Inhalation, ingestion, skin and/or eye contact

Colorless, yellow, or red,

fuming liquid with acrid,

suffocating odor. [Note:

often used in aqueous

solution. Fuming nitric acid is

concentrated and contains

dissolved nitrogen dioxide.]

Phenoxyethanol Y Combustible Preservative Eyes, skin, respiratory system Colorless oily liquid

Polydimethylsilo-xane Combustible Softener silicones None known at present

In general, inert, non-toxic,

and non-flammable; also

called dimethicone

Potassium

Permanganate Salt

Oxidizing agent,

reagent, disinfectant Possibly corrosive to eyes and skin

Solid, odorless tastes

sweetish, astringent

Soda Ash Non Combustible General usage/

washing/ reagent

Severely irritating to eyes and skin avoid

contact, avoid inhalation Whit solid odorless granules

Sodium

Bicarbonate(Baking

Soda)

Non Combustible

Leavening agent,

cleaner ingredient,

bath salt ingredient,

water softener

No potential health effects anticipated; avoid

skin/eye contact/ exposure White odorless granular solid

Sodium Chloride Salt (Non

Flammable)

Reagent/ water

softener/general use Avoid exposure to eye and skin

Solid crystalline powder with

saline taste

Chemical Name Fire


Sodium Hydro Sulphite Salt (Combustible) Make up chemical,

reagents. Inhalation, ingestion, skin and/or eye contact

White crystals or powder

with a slight odor of sulphur

dioxide

Sodium Hydroxide Reactive Bleach/

neutralization/solvent

Eye, skin, mucous membrane irritation;

Pneumonitis; eye, skin burns; temporary loss of

hair

Non-combustible Solid, but

when in contact with water

may generate sufficient

heat to ignite combustible

materials

Sodium Hypochlorite Salt (Combustible) Disinfecting agent

Irritant of the nose and throat, causing

coughing, difficulty breathing, and pulmonary

edema

Strong chlorine odor. Clear,

greenish-yellow solution

Sodium Metabisulfite Non Combustible

Food and

pharmaceutical

preservative,, waste

water de-chlorinating

agent

Can affect respiratory system, eyes, and skin;

use personal protective equipment to avoid

Inhalation

Solid white crystal with

pungent sulphur dioxide

odor

Sodium Thiosulphate Non Flammable General usage/

Washing/ Regent

Hazardous in case of ingestion, of inhalation;

Slightly hazardous in case of skin contact

(irritant), of eye contact (irritant)

White, odorless solid

Sulphuric Acid Reactive Reagent for Process/

Lab use Inhalation, ingestion, skin and/or eye contact

Colorless to dark-brown, oily,

odorless liquid. [Note: Pure

compound is a solid below

11°C/51°F. Often used in an

aqueous solution.]

Tetrachloroethylene Y Flammable Solvent/ Degreaser

Irritation eyes, skin, nose, throat, respiratory

system; nausea; flush face, neck; dizziness,

incoordination; headache, drowsiness; skin

erythema (skin redness); liver damage;

[potential occupational carcinogen]

Non-combustible Liquid, but

decomposes in a fire to

hydrogen chloride and

phosgene

Tetrahydrofuran Y Flammable Solvent/ Vinyl Adhesive

Eye, upper respiratory system irritation;

nausea, dizziness, headache, central nervous

system depression

Class IB Flammable Liquid:

Fl.P. below 23°C/ 73°F and

BP at or above 38°C/100°F

Toluene Y Flammable Solvent/Adhesive Eye, skin, respiratory system, central nervous

system (CNS), liver, kidneys

Colorless liquid with a sweet,

pungent, benzene-like odor

Trichloroethane Y Flammable Solvent/ Degreaser Eye, skin irritation; headache, lassitude

(weakness, exhaustion), central nervous

Colorless liquid with a mild,

chloroform-like odor

Chemical Name Fire


system depression, poor equilibrium;

dermatitis; cardiac arrhythmias; liver damage

Trichloroethylene Y Flammable Solvent Eyes, skin, respiratory system, heart, liver, CNS

(liver & kidney cancer in animals)

Colorless liquid (unless dyed

blue) with a chloroform-like

odor

Source: National Institute for Occupational Safety and Health (NIOSH)

Disclaimer: For Reference only, No Authenticity claimed. For additional Information, refer to the chemical’s Material Safety Data Sheets (MSDS)

Substances to be stored away from other substances listed

Substances not to be stored with cid

High Fire Hazard

Substances not to be stored with Acids, Oxidizers, and Bases. Have their own fire hazard-risk of fire if vapor exists in electrical fittings, hazards, spark,

etc.

No reactivity /danger known. However, in case of fire in other product situation, handle with care