California Transparency in Supply Chains Act of 2010
Jo-Ann Stores LLC
Jo-Ann Stores, LLC, doing business as JOANN Fabric and Craft Stores, contractually requires all of its vendors to comply with all applicable laws, including federal, state and foreign laws regarding slavery and human trafficking. If JOANN learns that a vendor has failed to comply with its legal obligations, JOANN will take appropriate action against that vendor.
For goods sourced directly by JOANN, including products that are sold under the “Jo-Ann” name or sold under one of our private-label trademarks, JOANN manages a factory audit program to evaluate and address risks of human trafficking and slavery. The details of this factory audit program are outlined under “Audits” below.
For goods sourced by JOANN from domestic (U.S.-based) suppliers, in which those domestic suppliers import the goods into the United States and then sell the goods to JOANN, JOANN does not engage in verification of product supply chains to evaluate and address risks of human trafficking and slavery.
Direct-source Goods: For goods sourced directly by JOANN, and for which JOANN is the importer of record, JOANN manages a factory audit program to ensure that the manufacturers of these goods comply with our standards, including compliance with human trafficking laws.
To monitor compliance with these standards, the foreign factories doing business with JOANN pre-authorize JOANN and its sourcing agent to conduct scheduled and unscheduled inspections of their factories (“social compliance audit”). Most social compliance audits will be announced and scheduled by the vendor, but JOANN reserves the right to request or conduct unscheduled audits at our discretion. Audits are conducted by third parties un-related to the factory.
If a factory already has performed a social compliance audit for someone else, JOANN will review existing audit reports, and if internal criteria are met, and depending on the results, the reports may be accepted. To be valid, all social compliance audits must have been completed within the previous 12 months. The social compliance audits measure the factory’s compliance with JOANN’s Vendor Workplace Code of Conduct, which is outlined below.
Vendor Workplace Code of Conduct
Vendor must comply with the following workplace ethics and business practices:
- • Child, indentured, involuntary or prison labor must not be used or supported.
- • Workers’ wages and benefits must meet or exceed legal and industry standards.
- • Vendors must comply with the laws addressing human trafficking and slavery of the country or countries where Vendors do business.
- • Vendors must maintain reasonable employee work hours in compliance with applicable laws.
- • Vendors shall not discriminate against employees in hiring practices or any other terms or conditions of work on the basis of race, color, gender, nationality, age, religion, maternity or marital status, disability, sexual orientation or political opinion.
- • Vendors shall maintain a clean, safe and healthy work environment. Vendors must comply with applicable laws governing occupational health and safety and must not utilize any form of mentally abusive or physical disciplinary practices. Employees must be treated in a dignified and respectful manner. Vendors shall comply with applicable laws regarding harassment (including sexual harassment) in the workplace.
- • Vendors must not illegally interfere with workers who wish to lawfully and peacefully associate, organize or bargain collectively.
- • Vendors shall comply with applicable environmental laws, rules and regulations.
- • Jo-Ann does not support the use of animal testing on merchandise carried in its Stores. Vendors must disclose this information to JOANN prior to submitting all merchandise quotes.
- • Vendors will take all necessary steps to ensure that JOANN’s Code of Conduct is communicated in writing to employees and factories and must make those records available to JOANN upon request.
Factory audits are scored and given either a color code or a risk priority that ties to the validity period of the audit. Depending on the score, a subsequent audit must be conducted within 60 days, 6 months, 12 months, or 18 months later. When audit scores are below a defined threshold, the Vendor must complete a corrective action plan and submit the corrective action plan to JOANN for approval, as well as complete a re-audit.
Goods from Domestic Sources: For goods sourced by JOANN from domestic (U.S.-based) suppliers, in which those domestic suppliers import the goods into the United States and then sell the goods to JOANN, JOANN does not conduct audits of suppliers. As noted above, JOANN contractually requires all of its vendors to comply with all applicable laws, including federal, state and foreign laws regarding slavery and human trafficking.
Our commercial agreement with foreign suppliers and with U.S.-based suppliers requires the suppliers to comply with the laws addressing human trafficking and slavery of the country or countries in which the suppliers conduct business. Our commercial agreement includes a Vendor Workplace Code of Conduct, as set forth above under “Audits.” All vendors, domestic and overseas, are required to comply with this Code.
For a description of how suppliers of direct-sourced products are held accountable, please see the section titled “Audits” above. In addition, JOANN operates a whistleblower program in which all employees can report violations anonymously. The following excerpt below comes from JOANN’s Code of Business Conduct and Ethics.
If a Team Member becomes aware of a situation in which he/she believes that a legal requirement or JOANN policy has been violated, or he/she is being pressured or being asked to compromise the Company’s values, it is the Team Member’s responsibility to communicate this concern through the appropriate channels, as described below. A Team Member will not be disciplined, lose his/her job or be subject to retaliation in response to asking questions or voicing concerns about the Company’s ethical or legal obligations, so long as the Team Member is acting in good faith. Good faith does not necessarily mean being correct – but it does imply the belief that the Team Member is providing truthful information.
Listed below are the ways a Team Member can ask questions or voice concerns.
• In person. A Team Member’s manager is the most immediate resource. He/she may have the information needed or may be able to refer the question to another appropriate source. Other Team Members you may contact include any Company officer, another Company manager, a Human Resources Representative or a Company attorney.
• Via email. Jo-Ann has a confidential email account, email@example.com, where anyone can send a message with a question or concern.
• Via phone. The Get Help Hotline (1-877-9GETHELP (or 1-877-943-8435)) is a confidential number where callers can remain anonymous, if they desire. If you call the Hotline, please provide sufficient information so that the concern you raise may be investigated thoroughly.
• Via mail. Correspondence should be sent to:
Jo-Ann Stores, LLC
5555 Darrow Road
Hudson, OH 44236
Please address your correspondence to one of the following:
SVP, General Counsel and Secretary,
EVP, Human Resources, or
VP, Internal Audit and Loss Prevention
In all cases, when a question or concern is raised, all reports are:
Handled promptly, discreetly and professionally. Discussions and inquiries will be kept in confidence to the extent appropriate or permitted by law.
Investigated by people who do not directly supervise the persons or conduct being investigated.
Kept on file to document how the Company addressed the report or concern.
In the event that an investigation is initiated, Team Members are expected to cooperate fully with the investigation and answer any questions truthfully and to the best of their ability. Concealing or covering up an ethical or legal violation is itself a serious violation of our Code. If a Team Member engages in concealing or covering up such violations, or fails to cooperate with an investigation, the Team Member will be subject to discipline, including possible discharge.
If the investigation confirms a violation of law or Company policy, appropriate corrective action will be taken, and Team Members found to have participated in the violation will receive appropriate disciplinary action, up to and including termination of employment.
Retaliation is Not Tolerated
A Team Member will not be disciplined, lose his/her job or be subject to retaliation in response to asking questions, voicing concerns or assisting in a Company investigation, so long as the Team Member is acting in good faith. Good faith does not necessarily mean being correct – but it does imply the belief that the Team Member is providing truthful information. Retaliation is grounds for discipline up to and including termination of employment.
If you believe that you have been subjected to retaliation, report it promptly to your manager, another appropriate Company manager; a Human Resources Department Manager or Director; the Executive Vice President, Human Resources; the General Counsel; or the Vice President, Internal Audit and Loss Prevention.
Goods that are direct-sourced and imported by JOANN require a valid vendor number and factory identification number before purchase orders can be issued to the factory. A factory cannot obtain an identification number unless the factory submits a social compliance audit to JOANN for review.
Jo-Ann is developing training materials for its employees who have direct responsibility for sourcing goods that are imported by JOANN and sold under the “Jo-Ann” name or sold under one of our private-label trademarks.