Williams-Sonoma, Inc. and its affiliates (WSI or the Company) are committed to maintaining the highest level of integrity and honesty throughout all aspects of our business, and we expect our business partners, including suppliers, agents and designated third parties, to respect and adhere to the same philosophy in the operation and management of their businesses.

Our social compliance program is based on the conventions of the International Labor Organization (ILO) and the UN’s Guiding Principles on Business and Human Rights and we are committed to doing our part to eradicate human trafficking, child labor and forced labor in our global product supply chains. WSI will realize this commitment by working with Vendors/Suppliers who conduct their business with integrity and comply fully with all applicable legal requirements related to human trafficking, child labor and forced labor.

Requirements

WSI expects its existing and new Vendors/Suppliers to act in accordance with the standards set forth in this policy. We have common compliance programs and policies across the company, subject to the California Transparency in Supply Chains Act and the UK Modern Slavery Act.

Certification

All Vendors/Suppliers are expected to sign the Vendor Code of Conduct, which stipulates that:

  • Vendors/Suppliers certify that materials incorporated into WSI products comply with the laws regarding human trafficking, child labor and forced labor of the country or countries in which they do business
  • Vendors/Suppliers independently engage in verification of their product supply chain to evaluate and address any risk with child labor, involuntary labor, human trafficking or forced labor
  • Vendors/Suppliers ensure that all workers (including foreign and migrant workers) do not pay any money deposit
  • Any fees associated with employment must be transparent and permitted by the applicable law of the host and home country of the workers
  • The workers have full control of personal identity documents, and contracts are legal, truthful, and in workers’ native language, and allow freedom of movement
  • WSI may schedule internal or independent third-party factory compliance audits with any of its Vendors/Suppliers to verify compliance with these requirements
  • WSI may, in its sole discretion, either terminate the business relationship or execute permanent corrective actions in partnership with the supplier if it determines that any partner has violated these requirements

Verification & Audit

To verify compliance of suppliers to these requirements, WSI may conduct independent, third-party audits and/or require the disclosure of supplier information regarding labor practices. Audits will aim to identify any improper labor practices, including child labor, forced labor, prison labor, indentured labor or bonded labor that may exist. 

If non-conformances are identified, appropriate investigative and remedial actions will be taken. WSI will provide detailed guidance to the vendors/suppliers on our requirements and how to meet them. 

WSI has internally assessed and verified its supply chain, and additional attention regarding auditing protocol and reporting is given to Vendor/Supplier sites located in countries identified as high risk for human trafficking, child labor and forced labor. All audits will include visual inspections, review of documents and records (e.g. employee contracts), and confidential interviews with workers in their native language. 

WSI utilizes both announced and unannounced audits with factories to verify compliance, which may or may not incorporate offsite interviewing and surveillance techniques as appropriate based on perceived risk. Audits may be executed on an unannounced basis for suppliers in high risk countries for human trafficking and forced labor issues.

Internal Accountability

WSI holds its employees to the highest standards of integrity and honesty in business practices. Sourcing team members are trained on required Vendor/Supplier employment practices and working conditions, including policies on involuntary labor, human trafficking, child labor and forced labor. WSI associates are required to uphold the tenets listed in the WSI Vendor/Supplier Code of Conduct and are subject to disciplinary measures, including termination, for failing to abide by all applicable laws and company standards. 

Any employee or contractor who becomes aware of a Vendor/Supplier who does not comply with the human trafficking, child labor or forced labor laws in the country or countries in which they do business must report that suspected violation to the Director of Corporate Social Responsibility.

Training

WSI provides training to managers and above who have direct responsibility for supply chain management on human trafficking and slavery, including how to identify and report any instances of child labor, forced labor they may see while visiting vendors. This training is done regularly and will also be done as needed when determined by the Company. WSI also regularly provides information regarding its anonymous hotline for associates of any level to report any ethics issues. WSI also provides trainings to vendors regarding its labor standards and Code of Conduct, including human trafficking and slavery issues, as well as on-boarding trainings for new factories joining WSI’s business.

Williams-Sonoma, Inc. is committed to an ongoing process of developing new and additional company-wide initiatives to benefit our supply chain, and we review and report on our progress to our stakeholders on an annual basis.

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