IPS

SUPPLIER
COMPLIAN
CE
GUIDEBOO
K
r Partner,

oria’s Secret & Co.’s success is built upon a foundation of leading with our values and working to improve the lives of our
ciates, customers, partners and communities. As a supplier partner, you are a respected and valued part of our team, and
are reliant upon you to uphold our company values, policies and guidelines. This extends to our Independent Production
ices (IPS) Compliance Guidebook that codifies our expectations for adherence to our Supplier Code of Conduct.

IPS team maintains the Guidebook as a tool to help all of us better understand and fully comply with applicable legal,
latory and business standards for our industry around the globe – outlining clear expectations on labor standards and
kplace conditions, brand protection, trade compliance and supply chain security.

global company, we are committed to engaging with suppliers who respect human rights, provide safe and inclusive
kplaces and promote environmentally sustainable practices. We believe that relationships based on transparency,
aboration and mutual respect are integral to making this happen.

re committed to our supply chain to ensure human rights are protected. This is a top priority for us, and we are truly
reciative of your partnership in upholding this commitment each and every day.

h respect,

tin Waters, Chief Executive Officer

Co & Victoria’s Secret
 3a. Transparency & Traceability . . . . . . . . . . . . . . . . . . . . . 20 3b.
TABLE OF CONTENTS Subcontracting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 3c. Anti-
Corruption/Anti-Bribery . . . . . . . . . . . . . . . . . . . . .21
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . .
. . .1 VULNERABLE WORKERS . . . . . . . . . . . . . . . . . 22
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
1. Women
Who is IPS? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
Workers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
What is the IPS Compliance Guidebook? . . . . . . . . . . . . . . . . .1
2. Foreign Migrant Workers . . . . . . . . . . . . . . . . . . . . . . . . . . .
Where to Learn More . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
23
3. Authorized Young Workers. . . . . . . . . . . . . . . . . . . . . . . . . .
A . SUPPLIER CODE OF CONDUCT & 23
4. Other Workers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
POLICIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
23 D . TRADE COMPLIANCE . . . . . . . . . . . . . . . . . .
. . . . . .2
1. Supplier Code of Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 24
2. Policies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
2a. Cotton Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1. Program Assessment Standards . . . . . . . . . . . . . . . . . . . 24
2b. Conflict Minerals Policy . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2. Subcontracting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2c. Foreign Migrant Worker Policy . . . . . . . . . . . . . . . . . . . . 5
2d. 24-Hour Notification Policy. . . . . . . . . . . . . . . . . . . . . . . 5 24 E . SUPPLY CHAIN SECURITY . . . . . . . . . . . . 25

B . IPS COMPLIANCE AUDIT PROGRAM . .8 Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1. Risk Assessment & Review . . . . . . . . . . . . . . . . . . . . . . . . 25
1. IPS Audit Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 2. 2. Program Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
IPS Audit Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3. Importer Security Requirements . . . . . . . . . . . . . . . . . . . 28
3. Audit Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
4. New Factories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Factory Evaluation for Pre-Production F . REMEDIATION . . . . . . . . . . . . . . . . . . . . . . . .
Authorization Flow Chart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 . . . 29
Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
VS&Co Corrective Action Plan Process Flow Chart . . . . . . 30
C . LABOR STANDARDS & WORKPLACE
CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . .
G . SUPPLIER RESPONSIBILITIES &
. . . .11
1. A Fair & Respectful Workplace . . . . . . . . . . . . . . . . . . . . . . .11
MANAGEMENT SYSTEMS . . . . . . . . . . . . . . . . 31
1. Management
1a. Forced Labor, Slavery & Human Trafficking . . . . . . . . .11
Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31
1b. Child Labor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
2. Communicate with
1c. Discrimination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13
IPS . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31 3. Communicate with
1d. Harassment or Abuse . . . . . . . . . . . . . . . . . . . . . . . . . . . .14
Factories & Sub-Suppliers . . . . . . . 32 4. Due
1e. Freedom of Association, Right to Organize
Diligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
& Collective Bargaining . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
1f. Wages & Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
1g. Working Hours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 H . PLATFORMS . . . . . . . . . . . . . . . . . . . . . . . . . .
2. Health & Safety in the Workplace . . . . . . . . . . . . . . . . . . . .17
2a. Health & Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17
2b. Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 . . 33 I . BRAND PROTECTION . . . . . . . . . . . . . . . .
3. Open & Honest Communication . . . . . . . . . . . . . . . . . . . . 20
. . .34
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Program Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Section A: Photos . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Section B: Samples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Section C: Subcontracting Control on Printing,
Embroidery or Washing Processes . . . . . . . . . . . . . . . . . . 35
Section D: Control of Raw Materials with
VS&Co Logos or Trademarks . . . . . . . . . . . . . . . . . . . . . . . 35
Section E: Control of Finished Goods . . . . . . . . . . . . . . . . 35
Section F: Destruction Control . . . . . . . . . . . . . . . . . . . . . . 35
Section G: Sell-off Control . . . . . . . . . . . . . . . . . . . . . . . . . . 36

CONTACT LIST . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . 37

SUPPLIER CODE OF CONDUCT . . . . . . . . . . 38

 The Guidebook does not replace the local laws of each country
INTRODUCTION where suppliers and factories are located. If our compliance
standards differ from local laws, we expect our suppliers to follow
the stricter standard. Each supplier and factory should be familiar
Overview with and comply with all laws and regulations relevant to their
Victoria’s Secret & Co. (VS&Co) is fully committed to ensuring our business.
products are ethically sourced. Partnerships based on responsible
sourcing strengthen our supply chain and the businesses within it. If we discover that a supplier or factory is not in compliance [with
This commitment starts with our leaders and cascades throughout local laws and/or our standards and policies], we will partner with
our organization. We hold ourselves and each other accountable to them to bring them into compliance. We are committed to
our values in all that we do. In that spirit, we strongly believe that continuous improvement and will not partner with suppliers and
the quality of our merchandise begins with the treatment of the factories that are unwilling or unable to work with us to achieve
people who create our products. compliance.

Suppliers are a respected part of our team, and we look to you to IPS expects suppliers and factories to refer to this Guidebook when
live to our company values as well, which are reflected in specific they have questions about VS&Co standards, the IPS compliance
company policies and guidelines. VS&Co only works with suppliers audit process, or want to better understand how to partner and
that share our commitment to ethical and responsible business communicate with IPS. If you have any questions that are not
practices. This commitment is embedded in the many measures by answered by reviewing the Guidebook and referring to local laws,
which we evaluate supplier partners and has been part of our please contact IPS for guidance.
comprehensive and proprietary approach to how we do business
for decades.

Where to Learn More

IPS is committed to supplier education and hosts annual awareness
Who is IPS? and training sessions on compliance standards in multiple countries
Independent Production Services (IPS) is a function within VS&Co around the world or virtually when in person trainings are not
that works with suppliers to ensure goods are sourced from possible. The training sessions are for suppliers and associates who
factories that meet or exceed VS&Co’s compliance standards and have direct responsibility for supply chain management. We also
policies. IPS is responsible for monitoring and enforcing VS&Co‘s use one-on-one training along with compliance audits and
social compliance program and has been supporting global corrective action management to continuously educate factories
compliance for more than two decades, enabling improvement and reinforce VS&Co’s Supplier Code of Conduct and compliance
in working conditions, supply chain security, trade compliance standards.
and brand protection in our supply chain through monitoring,
remediation, capacity building and training. To learn more about IPS and our compliance programs and
standards, please visit IPS’ website at http://ips .steton .com or
IPS defines “supplier” as the vendor or partner who has signed contact IPS directly by referring to the Contacts section within this
the Master Sourcing Agreement (MSA) directly with VS&Co. Guidebook.

A. SUPPLIER CODE OF
What is the IPS Compliance Guidebook?
The IPS Compliance Guidebook (Guidebook) includes a set of
mandatory requirements which all our suppliers as well as their
CONDUCT & POLICIES
factories, sub-suppliers and subcontractors need to meet to be able VS&Co has a longstanding commitment of working with suppliers to
to do business with VS&Co. We encourage our suppliers to move improve manufacturing conditions and minimizing negative impacts
from the mandatory requirements to industry best practices to workers, local communities and the environment. We align
whenever possible. ourselves only with suppliers that share this commitment. As the
VS&Co suppliers must sign the MSA before VS&Co can issue industry evolves and new issues arise, standards for brands and
purchase orders and the supplier can begin producing our products. retailers are raised. Therefore, VS&Co continuously reviews internal
The MSA states that suppliers must comply with VS&Co policies, policies to align with industry standards and best practices. In
which includes the Guidebook – a collection of policies and all recent years we have evolved our standards and programs to drive
applicable laws and regulations. improved outcomes for the workers in the supply chain and the
communities where our suppliers operate. VS&Co has a Supplier

1 IPS Supplier Compliance Guidebook

 Code of Conduct and important policies in place to guide our The update to our Supplier Code of Conduct does not represent a
suppliers to meet our standards and clearly specify our major change in our requirements for suppliers. Rather, the
expectations. Our company policies and guidelines help us mitigate changes elevate key expectations to emphasize the depth of our
risk and build trust among consumers. work and standards.

The Supplier Code of Conduct sets forth standards – in addition to

all relevant laws, regulations and conventions – that apply to
1 . Supplier Code of Conduct suppliers and their factories, sub-suppliers and subcontractors.
The Supplier Code of Conduct (see page 38) was updated in 2021 to Suppliers must adhere to these standards and communicate them
more accurately reflect current standards and requirements, and to to all workers in all countries in which they operate, in the
enhance value for VS&Co and our suppliers while leveraging preferred language(s) of the workers. The Supplier Code of Conduct
industry best practices. is based on core ILO Conventions (ILO Conventions), the Universal
Declaration of Human Rights, and Principles 1-6 of the UN Global
Compact.
2 . Policies
2a . Cotton Policy
VS&Co updated its Cotton Policy and requires all cotton fiber, cotton yarn, cotton fabric and cotton products originate from or be spun in one or
more of the following approved countries as designated:
COTTON PROCESSING1 AND
COTTON FIBER MAY ONLY COTTON YARN SPINNING MANUFACTURING ALLOWED IN:
COUNTRY/REGION
ORIGINATE FROM: ALLOWED IN:

Australia   
Bangladesh
(Note: Only designated facilities upon IPS  
approval)

Benin   
Brazil   
Burkina Faso   
Colombia  
Costa Rica  
Dominican Republic 
Egypt   
El Salvador 
European Union2  
Guatemala  
Haiti 
Honduras  

2 IPS Supplier Compliance Guidebook

 India   
Indonesia  
Israel   
Jordan 
Kenya 
Madagascar   
Mali   
COTTON PROCESSING1 AND
COTTON FIBER MAY ONLY COTTON YARN SPINNING MANUFACTURING ALLOWED IN:
COUNTRY/REGION
ORIGINATE FROM: ALLOWED IN:

Mauritius  
Mexico  
Peru   
Philippines 
South Africa  
South Korea  
Sri Lanka 
Tanzania   
Thailand  
Togo   
Turkey   
U.S.A.   
Uganda   
United Kingdom  
Vietnam  
Zambia   

3 IPS Supplier Compliance Guidebook

 NOTE1: Cotton processing includes knitting, weaving, dying and printing. All other cotton processing facilities must be approved by IPS on a case
by case basis.

NOTE2: European Union Includes Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece,
Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain And Sweden.
Verification and Due Diligence law and do not pay for their employment nor incur debt related
We expect our suppliers to undertake appropriate due diligence to to their recruitment or hiring process.
confirm compliance with this policy. Suppliers are required to Workers must retain control of their travel documents, have
retain all documentation for the origin of raw materials, processing freedom of movement and be informed on the basic terms of their
and manufacturing to ensure transparency and traceability of our employment before leaving their home country/ region.
cotton supply chain. Independent Production Services (IPS) may
conduct chain of custody audits to verify cotton fiber, cotton yarn,
cotton fabric and cotton product originated from an approved
The United States Securities and Exchange
country.
Commission (SEC) adopted the Conflict Minerals rule
in 2012 as a result of Section 1502 of the Dodd-Frank
2b . Conflict Minerals Policy Act. The goal of the rule is to end violence and human
VS&Co prohibits its suppliers from using conflict minerals which rights abuses perpetrated by armed groups during
may directly or indirectly finance or benefit armed groups in the the extraction of natural resources in the Democratic
Democratic Republic of the Congo and its adjoining countries in Republic of Congo (DRC). The natural resources most
accordance with the Dodd-Frank Conflict Minerals Provisions. often involved in these atrocities are tin, tantalum,
According to U.S. federal law (Dodd-Frank Act, Section 1502), all tungsten, and gold (3TG). These minerals and their
U.S. public companies, including VS&Co, are required to perform a derivatives are commonly known as “conflict
country of origin (COO) investigation for any 3TG (tin, tantalum, minerals” when they originate in the DRC or its nine
tungsten and gold) in their products, including whether sourcing of adjoining countries (DRC+9) and their extraction
those metals may have benefited non-state armed groups in the contributes to the conflict in the DRC. This rule
Democratic Republic of Congo (DRC) or its nine adjoining countries requires U.S. companies like VS&Co to determine if
(collectively known as the “DRC+9”). their products contain 3TG that is necessary to the
product’s function or production and disclose
We require our suppliers to retain records related to conflict
whether those minerals were sourced from the
minerals supply chain inquiries for a minimum of five years and
DRC+9.
make them available to VS&Co or its designee during audits or upon
request. This includes but is not limited to declarations from sub-
suppliers, purchasing records, and other supporting documents to
substantiate where the 3TG material originated.
2d . 24-Hour Notification Policy

Compliance Requirements
2c . Foreign Migrant Worker Policy
As part of our due diligence and risk assessment, certain practices at
The Supplier Code of Conduct states that forced, prison,
factories are identified as elevated risk and require immediate
indentured, bonded, and slave labor as well as labor obtained
notification to IPS within 24 hours. They may be identified by a
through human trafficking are prohibited throughout our supply
factory, supplier, auditor, VS&Co associate or any other actor that
chain. Foreign migrant workers who travel across country borders
identifies such practices. The practices considered elevated risk are
to obtain employment are most vulnerable to modern slavery.
the following:
Therefore, we have established a policy to ensure that we
minimize any risk of modern slavery in our supply chain. The
1 . Forced Labor, Slavery & Human Trafficking
policy requires an executive approval process to use a factory that
• Forced, prison, indentured, bonded, and slave labor as well
employs foreign migrant workers. Approval will be contingent on
as labor obtained through human trafficking
positive results found during a specialized audit developed in
• Deposits or recruitment fees being paid by workers
accordance with the International Labour Organization’s
• Workers paying a fee or deposit to secure a job
Handbook on Combatting Forced Labour (ILO Handbook).
• Employers retaining workers’ personal identity documents
Factories that employ foreign migrant workers are closely
or lack of freedom of movement
monitored to ensure workers are treated in accordance with the

4 IPS Supplier Compliance Guidebook

 • Workers not being allowed to legally terminate their • Fire at a factory site
contracts or termination results in an illegal penalty • No separation of men and women in dormitory rooms
• Factories using un-registered or illegal labor agencies
• Labor contracts not meeting legal requirements 9 . Subcontracting
• Workers not receiving a copy of their labor contracts in their • Unauthorized subcontracting
preferred language before leaving their home 10 . Transparency & Traceability
country/region • Worker/payroll records not being available during an audit
2 . Freedom of Association, Right to Organize & Collective or being inaccurate
Bargaining • More than 10% of payroll records not being available during
• Workers’ rights to freedom of association and collective an audit or a finding of inconsistent records
bargaining not being respected • A situation of our company representative, subcontractors
• Workers not being able to join a union or bargain freely in and authorized agents not given unrestricted access to all
the factory where legally allowed to do so workers, production facilities and dormitories, and not being
• Union activities not being allowed or not being recognized granted access to all relevant records related to production
by the employer facilities and sub-suppliers, whether or not notice is
• Union members being discriminated, intimidated, or provided in advance
terminated because of a legal union affiliation or organizing • Factories not having a system in place or documentation to
efforts support worker was eligible to work in the country where
the factory is located
3 . Child Labor
• Workers not being the local minimum legal working age or 11 . Other
International Labour Organization standard, whichever is • Bribes or anything of value are offered, gifted, authorized,
higher requested, accepted or received to improperly influence
someone or gain an improper advantage
4 . Wages & Benefits • Supplier dropping a factory for labor standards issues raised
• Workers not being paid the minimum wage, not being by another client
compensated for all overtime worked and not being • Suspected violations of laws and regulations or labor
provided benefits as stipulated by local laws standards including, but not limited to, United States laws
• Workers not being able to control withdrawals from their and/or regulations relating to the country of origin or
bank accounts country of destination of goods produced for or sold to
• Pay day being 30 days late VS&Co
• “Suspected violations” shall be interpreted broadly to
5 . Hours of Work include all facts and circumstances that suggest any
• Workers unable to refuse overtime significant possibility that a violation of any law
• Workers raising concerns of being penalized or facing or regulation or labor standard has occurred or will occur
retaliation/retribution when they refuse overtime • If a governmental or non-governmental agency, United
States or otherwise, begins an investigation or inquiry into
6 . Discrimination the supplier or its factories or subcontractors that relates to
• Discrimination in employment, including hiring, issues arising under laws and regulations or labor standards
compensation, advancement, termination or discipline • Confirmed supply chain security incident where a security
seal was broken and there is evidence that container was
7 . Harassment or Abuse entered, regardless of whether product was removed or not
• Harassment or abuse or workers not being treated with • Theft or diversion of VS&Co goods
respect and dignity • Workers or their supporters make public demands such as
• Employers using threat of violence demonstrations, internet campaigns, letter writing
• Workers raising concerns about being uncomfortable while campaigns, strikes, work stoppage, etc.
authorized personnel of any gender conduct physical
security searches

8 . Health & Safety

• Health and safety violations including workplace accidents
that result in serious injury, illness or death

5 IPS Supplier Compliance Guidebook

 Findings of • The name of the factory and any other manufacturing facility
such involved in the incident
practices • The status of any individuals involved when integrity of
The U.S. government passed a law in 2016 called the require health, safety or wellbeing are a factor
Trade Facilitation and Enforcement Act. As a result, • The purchase order number for any order impacted during
U.S. companies are prohibited from importing goods the incident, if applicable
made with convict, forced or indentured labor. In • A description of the potential elevated risk incident, inquiry,
investigation or other occurrence
2017, the U.S. government passed an additional law
called the Countering America’s Adversaries Through
After a thorough investigation is conducted to determine root
Sanctions Act. This law recognizes that North Korea
causes of the violation(s) found and overall compliance of other
has forced many of its citizens to migrate to China or
VS&Co standards, remediation may take place if it is decided the
other countries to work in certain factories; the U.S. factory can remain active for VS&Co production contingent on
government views this as forced labor. The law executive leadership approval.
prohibits the importation of goods made wholly or in
part by North Korean nationals or citizens working as
convict, forced or indentured laborers. Action for Non-Compliance
Suppliers are required to comply with all laws and policies listed in
It is critical that our suppliers do not use any kind of this Guidebook and respond to all VS&Co requests regarding any
forced labor in the production of our goods or use legal requirement or VS&Co policies. Failure to do so will result in
raw materials or components made by or obtained escalation to VS&Co executive leadership and may result in any or
with forced labor. The supplier must be able to all of the following actions.
demonstrate that VS&Co products were not made
using forced labor by providing documentation • Warning letter
including but not limited to a factory profile, a • Additional monitoring at the supplier’s expense
description of production processes performed, • Financial penalties
support for raw materials purchases, daily • Reduction or loss of business with VS&Co
production records, attendance and payroll records,
worker contracts and documents to support the NOTE: Penalty actions will be taken against the Supplier at IPS’
factory’s hiring process and policies. discretion and determined on a case-by-case basis.

IPS defines “supplier” as the vendor or partner who

investigation and internal escalation to IPS Leadership. In instances
has signed the Master Sourcing Agreement (MSA)
when a supplier is aware of any of these practices taking place at
directly with VS&Co
one of their factories producing for VS&Co, the supplier must notify
IPS with a written report via email within 24 hours. The report must
include:
countries where they and their factories operate. IPS or our
B. IPS COMPLIANCE designated third-party auditor is responsible for verifying that the
supplier and its factories meet compliance standards in the four

AUDIT PROGRAM
areas listed below:

• Labor Standards and Workplace Conditions

• Supply Chain Security
Overview • Trade Compliance
Improving factory conditions is a critical element of our overall • Brand Protection
commitment to global compliance, as well as a commitment to
strong corporate governance and ethical business practices. To that Each supplier is required to sign VS&Co’s MSA, which states that the
end, we have a comprehensive internal audit program managed by supplier’s factories and subcontractors involved in producing goods
IPS. Suppliers are expected to comply with our standards and for VS&Co must cooperate fully in any audit or other review.
observe all relevant laws, regulations and conventions in all Factories must give auditors full access to the facility being audited

6 IPS Supplier Compliance Guidebook

 and provide all required documents for review. IPS or our third- IPS will provide a two-week window for semi-unannounced audits. If
party auditor has the right at any time to: an audit is unannounced, IPS or the assigned third-party auditor will
arrive with identification to show they are from IPS or one of our
1. Conduct audits at the location where product manufacturing third-party audit partners. In addition, the auditor will bring a signed
takes place letter notifying the factory of the unannounced audit and the
2. Conduct capacity monitoring or any other compliance review telephone number of IPS management should the factory want to
at any facility doing any type of production for VS&Co contact IPS to confirm the audit arrangement.
products
3. Inspect any or all documents or other records required to be Audits may take one or more days to complete depending on the
maintained or provided areas to be audited and the size of the facility. Audits consist of the
VS&Co’s normal practice is to bear the cost of initial and annual following procedures:
audits and not pass the cost on to our suppliers. However, suppliers
will be charged for the audit if a factory is dropped after the audit is 1. An opening meeting to explain the areas the audit will cover
already confirmed, or in cases when repeated violations or elevated 2. A factory tour
risk issues are identified during subsequent audits. 3. Review of any documents, photos or other records needed to
verify compliance requirements
4. Worker interviews*
5. A closing meeting to review any audit findings
IPS reserves the right to conduct audits on an
announced, semi-unannounced or unannounced
Supplier partners are encouraged to join audits along with the
basis.
factory management and the factory compliance manager.
*
During a labor standards audit, the audits performed by assigned third-party auditors
include worker interviews in the workers’ preferred language. IPS expects that the
supplier or their factories or sub-suppliers will not interfere, discourage or punish
workers for communicating with our appointed auditor. We also expect that workers
1 . IPS Audit Objectives are able to interview freely, without other workers or factory management
participating or listening in.
IPS’ goal is to support ongoing compliance with our standards and
show factories how operating in a socially responsible way can
improve their business. IPS does not aim to pass or fail a factory
audit, rather, the objectives of our audit program are to:
3 . Audit Results
After an audit is conducted and approved by IPS management, the
• Assess whether potential new factories are capable of
supplier will receive an automatic Audit Result Notification from
complying with our standards
[email protected], with an alert that audit reports are
• Ensure that existing factories continue to comply with our
available in RizePoint (refer to section H to learn about the RizePoint
standards and work to continuously improve their compliance
Platform). Suppliers will be given access to the audit report for each
performance
area reviewed. If an automatic notification is not available, IPS will
• Identify non-compliance with VS&Co standards and relevant
email the supplier to notify them that the audit report is available
laws, regulations and conventions
and to advise if corrective actions are required. Suppliers are
• Assess a factory’s compliance level in each audit area
responsible for sending audit reports to their factories and
• Detect unauthorized subcontracting
partnering with them to review and complete corrective action
• Identify best practices plans.
Audit reports include a summary showing the score for each area
We also use audits to validate that our suppliers and their factories and an overall score. The total score does not indicate a “pass” or
are being transparent and expect that only complete and accurate “fail” result. Instead, the score represents the compliance level of
documentation be presented during an audit or other type of
the factory in each area.
review.
2 . IPS Audit Process Depending on the score achieved, IPS may waive the factory’s audit
Audits may be conducted by IPS or one of our third-party audit for the following year. For an audit to be waived, scores must reflect
partners. Audits may consist of any combination of the four areas a low risk level and the supplier and factory must not have a history
listed in the previous Overview section. of violations. Audit waivers are granted at the discretion of IPS
leadership and VS&Co executive leadership.
All audits may be announced, semi-unannounced or unannounced.
A specific date will be scheduled in advance of an announced audit.

7 IPS Supplier Compliance Guidebook

 IPS defines “supplier” as the vendor or partner who
has signed the Master Sourcing Agreement (MSA)
directly with VS&Co.

4 . New Factories
A labor standards and workplace conditions audit must be
conducted in all potential new factories before production may
begin. After the audit is conducted, IPS will review the audit result,
determine if the factory is authorized for production and notify
our brand partners and the supplier of the decision.

Suppliers should enter potential new factories into RizePoint at least

30 days prior to planned production so the pre-production audit can
be conducted. If the supplier has a labor standard audit report for
the new factory, and the audit was conducted by a reputable audit
firm within six months prior to the approval request date, the report
may be shared with IPS for review. IPS may accept the audit instead
of conducting a pre-production audit.

The following sections will provide details on our standards for the
four areas IPS monitors: Labor Standards and Workplace Conditions,
Supply Chain Security, Trade Compliance and Brand Protection.

IPS conducts pre-production audits for all new

factories.

8 IPS Supplier Compliance Guidebook

 FACTORY EVALUATION FOR PRE-
PRODUCTION AUTHORIZATION
FLOW CHART
Factory identified as new, a reactivation request,
relocating, or name change

Factory Set-up Form submission

required in RizePoint.
At minimum, 30 days prior to
planned production

YES Does a satisfactory audit exist for NO

evaluation to
authorize the factory for
production?

IPS reviews shared report IPS coordinates with

and planned production supplier for audit scheduling
details and completion

YES
Does audit identify Does audit identify
unacceptable risk levels to unacceptable risk levels to
the business? the business?

Factory NOT authorized for

production

Factory authorized for

NO production NO

9
 • Workers enter employment voluntarily and
C. LABOR freely, without threat

STANDARDS &
Termination of Employment
• Workers are free to legally terminate their
contracts without penalty and accurate
supporting records must be on file

WORKPLACE • No restrictions for workers when terminating

their employment (e.g., loss of wages or
benefits)

CONDITIONS
1 . A Fair & Respectful Workplace
1a . Forced Labor, Slavery & Human Trafficking
IPS Supplier Compliance Guidebook

Code Principle
Employment Agents
Forced, prison, indentured, bonded, and slave labor
• Factories use legally approved/registered labor
as well as labor obtained through human trafficking
agencies in accordance with local law
are prohibited throughout our supply chain.
• Factories are responsible for conducting
Employers must not require workers to provide
thorough due diligence on all labor agents used
deposits or recruitment fees. If recruitment fees
in the recruitment and employment of foreign
exist, the employer is responsible for payment of all
migrant workers
employment eligibility and recruitment fees. The
• Workers do not pay a fee or deposit to secure a
employer is not entitled to retain workers’ personal
job
identity documents and all workers must have
• Factories are responsible for all fees associated
freedom of movement. [ILO Conventions 29 and
with employment agencies
105]

Employment Contracts & Documentation

Requirements
• Labor contracts for all workers meet all legal
Freedom of Movement
requirements
• Workers have freedom of movement within
• Workers receive a copy of their labor contracts
their designated work areas during work hours
before leaving their home country/region of
and within their dormitories during non-work
origin in a language they can understand
hours, including access to toilets, bathroom
• Employers explain the contract contents to
facilities, canteens, drinking water stations, etc.
workers in their preferred language before the
• Workers are free to leave the facility during
contract is signed, and in the case of foreign
meal periods or after work hours
migrant workers, before the workers leave their
home country/region
Freedom of Overtime
• Factories have a formal contract with all legally
• Overtime is voluntary without fear of negative
approved/registered staffing agencies used to
consequences or retaliation/retribution
obtain temporary labor
• Staffing agency contracts indicate which party is
Prison Labor
responsible to verify workers’ employment
• No form of prison labor, nor work with
eligibility and have supporting documents
subcontractors and sub-suppliers that allow any
available
form of prison labor is to take place
• Factories have a system in place to verify that
all workers are legal citizens or are eligible to
Freedom of Employment
work in the country of factory location

10 IPS Supplier Compliance Guidebook

 VS&Co requires suppliers to comply 1b . Child Labor
with the Employer Pays Principle, to
ensure factories producing for us do Code Principle
not charge recruitment fees to workers All workers shall be at least the local minimum legal
or use debt bondage or irregular, working age or ILO standard, whichever is higher.
delayed, deferred or non-payment of The facility must take all necessary precautions to
wages. ensure that authorized young workers, under the
age of 18, are protected from working conditions
that could pose a danger to their health, safety, or
development. [ILO Conventions 138 and 182]
Control Over Personal Documents
Requirements
• Workers retain original copies of personal
Underage Workers
documents (i.e., birth certificates, passports,
• All workers meet or exceed the minimum legal
work permits, residence cards, labor contracts
working age prior to their date of hire
and national identity cards, etc.)
• Only persons at or above the minimum legal
Debt Bondage & Recruitment Fees
working age are present in the work areas
• Employers do not use irregular, delayed,
deferred or non-payment of wages as a means
Screening Procedure & Documentation
to bind workers to employment
• Employers have systems in place to ensure age
• Employers do not force workers to work in
documents are accurate and complete at the
order to repay a debt
time of recruitment
• Recruitment fees or deposits are not charged to
• Employers provide training to all hiring staff on
workers, inclusive of fees for travel visas, health
methods to verify the age of workers using
checks, employment registration, work permit,
effective interview techniques and ways to
agency/management fees or referral fees
identify falsified documents
• Employers ensure workers have full control of
• Personnel files contain copies of identification
their bank account(s) if they are paid by direct
documents such as birth certificates, national ID
deposit into a bank
cards or school certificates throughout the term
of employment
Best Practices
 Employers have a written policy prohibiting the
Authorized Young Workers
use of forced labor of any kind within their
• Authorized young workers are registered with
entire supply chain
the local labor bureau where required by law
 Employers make every effort to employ workers
• Contracts are signed by a parent or guardian as
directly
required by law
 Employers provide regular forced labor
• Employers protect the authorized young
awareness training to all workers
workers from working in hazardous areas
• Employers adhere to all local regulations
regarding working hour restrictions for young
workers, including regular hours, night hours
For any factory employing or planning and overtime hours
to employ foreign migrant workers • Authorized young workers have access to
(excluding management and office proper health examinations as required by local
staff), the supplier must notify IPS. Our law
policy requires a specialized audit in
these cases. Apprenticeship/Trainee/Internship Programs
• Employers ensure that any participation in an
apprenticeship/trainee/internship program is in

11
 accordance with local law and follow the
minimum age legal requirements
• Wages are not less than the legal minimum
wage for apprentices, trainees and interns
• The apprenticeship and training programs are
only for jobs that develop technical skills for the
operations performed at the factory
• The total number of program participants does
not exceed the total number of permanent
workers as required by law
• Employers do not use long-term
apprenticeships or training programs to employ
workers in low-wage or temporary positions

Best Practices
 Employers have a tracking system for all
authorized young workers (e.g., young workers
registry)
 Employers require at least two forms of
age/identity documents, preferably ones that
have a photo ID

Authorized young workers are workers

who are under the age of 18 but above
the legal minimum age requirement
and protected from working conditions
that could pose a danger to their
health, safety or development.

12 IPS Supplier Compliance Guidebook

 1c . Discrimination • Employers provide breastfeeding and childcare facilities as
needed or where required by law
Code Principle • Employers do not demote, reduce wages, or terminate a woman
Workers must be selected only on the basis of their ability to do the worker because she is pregnant, immediately before maternity
job. Employers must not discriminate in employment, including leave, during maternity leave or after returning from maternity
hiring, compensation, advancement, termination, or discipline, on leave
the basis of sex, gender identity, race, religion or belief, age, • Employers do not reduce salaries from pregnant workers for
disability, illness, sexual orientation, pregnancy, marital status, civil taking leave for prenatal medical checks throughout pregnancy
partnership, nationality, political opinion, social or ethnic origin, or • Employers allow workers to take additional leave after the three
other protected status. All workers, regardless of gender, shall months maternity leave period, if allowed by law
receive equal pay for work of equal value. [ILO Conventions 100 and • Pregnant women who work while standing are provided with
111] chairs near their workstations for rest breaks
• Employers allow pregnant women to rest for half-an-hour every
Requirements four hours of work and do not assign pregnant women in areas
Awareness with hazardous working conditions
• Factories have policies and hiring procedures regarding
discriminatory awareness and actions in the workplace Support for Special Needs
• Employers provide training to all workers on discrimination • Employers are aware of women’s special needs, particularly
awareness, particularly as it relates to gender equality after childbirth, and provide them with benefits and facilities for
• Regular training is provided to Human Resources staff to ensure meeting those needs
they understand hiring policies • Employers are aware of vulnerable workers with special needs
• Regular training is provided to all workers in their preferred (e.g. elderly workers, disabled workers, pregnant workers, etc.)
language(s) to ensure they understand non-discriminatory and provide proper support including but not limited to lighter
policies work, proper breaks, and flexible time options

Non-Discrimination
• Employers do not discriminate during employment, including
Pregnancy testing is not a condition for employment,
hiring, compensation, advancement, termination, or discipline,
nor is it demanded from workers.
on the basis of sex, gender identity, race, religion or belief, age,
Best Practices
disability, illness, sexual orientation, pregnancy, marital status,
 Employers maintain effective policies and procedures that
civil partnership, nationality, political opinion, social or ethnic
promote gender equality and anti-discrimination
origin, or other protected status
 Employers have a job performance evaluation process that
• The use of medical examinations, such as pregnancy or HIV/AIDS
includes data on productivity, absenteeism, work quality and
tests, to prevent a worker from being employed is prohibited
other areas of job performance
• Medical tests if required by law comply with requirements and
 Employers provide maternity leave benefits if not defined by
are not to be used in any discriminatory manner
local law
• Workers are not forced or pressured to use contraception
• Pregnancy, disability, illness, union lead, or worker
representative is not used as a basis for discriminatory practices
like termination, demotion, etc.
• Religious observance, prayer breaks, and religious holidays are Employers do not implement factory policies or
permitted practices that favor one group of workers over
Equality another.
• Factories ensure non-local workers are treated fairly and on an
equal basis with local workers
• Women and men receive equal pay for work of equal value,
equal evaluation of the quality of their work assignment, 1d . Harassment or Abuse
promotion, and equal opportunities to fill open positions
• Employers do not implement factory policies or practices that Code Principle
favor one group of workers over another Workers must be treated with respect and dignity. No worker
• Foreign migrant workers or domestic migrant workers are shall be subject to humiliating or corporal punishment, and the
treated fairly and on an equal basis with its local workers workplace must be free from all forms of physical, sexual,
psychological, or verbal punishment, coercion, intimidation,
Pregnant Women harassment or abuse. [ILO Convention 190]

13 IPS Supplier Compliance Guidebook

 Requirements  Factories post and maintain records of resolutions to complaints
No Harassment & Abuse that all workers can access
• Employers do not use threat of violence, rude or abusive  Factories form grievance committees with worker
language, physical abuse, lewd remarks, sexual harassment, representatives where applicable
corporal punishment, psychological or verbal abuse, or any  Factories track, collect and screen data for all grievances,
other form of harassment or abuse against workers complaints and resolutions based on gender of workers
• Employers have clear and established anti-harassment or abuse
policies made available to all workers
• Physical security searches are applied equally to all workers and
are performed in the open by authorized personnel who are of IPS defines “supplier” as the vendor or partner who
the same gender as the worker and with respect for the has signed the Master Sourcing Agreement (MSA)
individual directly with VS&Co.
1e . Freedom of Association, Right to Organize & Collective
Discipline Practices Bargaining
• Discipline rules and practices are in compliance with local law Code Principle
and communicated to all workers in writing and verbally Workers’ rights to freedom of association and collective bargaining
• Employers do not use monetary fines as a form of discipline must be respected, as well as rights to refrain from participating in
• All disciplinary actions are recorded organizations of their choosing. Facilities must not interfere with,
harass or intimidate workers who lawfully and peacefully associate,
organize or bargain collectively. [ILO Conventions 87, 98, 135 and
Grievance Mechanisms 154]
• An effective worker grievance mechanism is available for all
workers in their preferred language Requirements
• Factories develop multiple channels for workers to raise Workers’ Rights of Association & Bargaining
concerns and provide input to management anonymously • All workers are free to form/join a trade union of their choosing
• Each grievance mechanism protects worker privacy, protects or choose not to belong to a union
against retribution and allows concerns to be escalated to • Employers do not discriminate nor terminate those who choose
someone other than direct supervisors to form or join unions, who participate in union activities, or
• Factories train workers how to use grievance mechanisms in the choose not to belong to a union
preferred language(s) of workers, to report concerns, grievances • Employers are open to cooperation with union representatives
and potential violations without fear of retaliation
• Employers establish written procedures for filing and recording Freedom of Association/Worker Committee
grievances and follow-up discussions of grievances are kept on • In countries where the law restricts freedom of association and
file collective bargaining, factories facilitate alternative means to
• Factories are transparent on the status of each grievance (e.g., establish worker representation, such as worker committees
grievance received, investigated, resolved, closed, etc.) • Records of meetings, including minutes and agendas with the
union or worker committee, are on file and available for review

Union Fees
• Factories do not deduct union membership dues, fees or fines
An effective worker grievance mechanism should be
from workers’ wages without written approval from the worker
available for all workers in their preferred language.
Best Practices
 Employers meet with trade unions or worker representatives
regularly to understand worker concerns
Best Practices
 Employers provide private meeting space at the workplace for
 Factories have progressive discipline methods to correct a
union (where legally recognized) or worker committees to host
worker’s behavior toward becoming a productive member of
their meetings
the company. The disciplinary procedure should include:
1f . Wages & Benefits
1. Verbal warning
2. First written warning
Code Principle
3. Second written warning
Employers must compensate workers with at least the minimum
4. Dismissal
wage prescribed by local law, the prevailing industry wage or the
wage negotiated in a collective bargaining agreement, whichever is

14 IPS Supplier Compliance Guidebook

 higher. Employers shall compensate all overtime work at a premium • Employers share information on all related legal withholdings
rate and provide benefits as stipulated by local laws. Suppliers with workers
should strive to pay a wage sufficient to meet workers’ basic needs
and provide some discretionary income. Illegal or disciplinary Records & Communication
deductions are not permitted. [ILO Conventions 1, 95 and 131] • All pay records are complete, accurate and made available upon
request
Requirements • All related payment records clearly indicate the pay period
Basic Pay covered, the date workers are paid and acknowledged by
• All workers, including contract/agent workers, are paid the legal workers
minimum wage, wages based on a collective bargaining • Employers provide workers a comprehensive wage statement,
agreement (CBA), or wages based on a contractual agreement which includes all hours worked, basic wage or piece rate
whichever is higher earned per day, overtime premiums, bonuses, allowances,
• If workers are paid by piece rate wage instead of hourly rate, benefits and legal or contractual deductions
the worker receives a wage equal to or above the legal • Employers communicate to workers the content of wage
minimum wage, without the use of overtime statements and train them on the calculations in their preferred
language
Overtime Pay • Any variations to the normal payroll schedule or wage
• Overtime premiums follow local law or rates set forth by a CBA, statement are communicated to workers in their preferred
whichever is higher language and documented with worker acknowledgment
• Overtime wages are paid for all time legally defined to be over • All workers are provided a mechanism to dispute any wage
regular working hours discrepancies

Employers communicate to workers the content of

Minimum wage and overtime premiums must meet
wage statements and train them on the calculations
legal requirements.
in their preferred language.

Pay Date
Best Practices
• Pay date follows local law
 Employers strive to pay workers a wage that meets the basic
• When no time limits are defined by law, compensation is paid
needs of the workers and their families, with some discretionary
at least every 30 days
income
 A fair compensation system is in place according to workers’
Deposits, Deductions or Fines
skill, experience, seniority and qualifications
• Employers do not hold deposits in any form for any reason
 Employers regularly assess and adjust wages and benefits to
• Any deductions follow local law or a legal CBA
reflect the cost of living, industry standards and basic needs
• Illegal or disciplinary deductions are not permitted
 Factories have a system in place to enhance efficiencies, cost
• Employers do not impose fees on workers in any form for any
savings and apply a portion of the savings towards improving
reason, including but not limited to fees for tools or other items
worker wages
required for their job
 Factories pay workers through digital payments
Benefits
 Digital payments are on the payment date or period stipulated
• All workers, including trainees, are provided benefits in
by the local law
accordance with local law or as set forth by a CBA, whichever is
 Workers are trained on how digital payments work in the
higher
workers’ preferred language
• Benefits include, but are not limited to social Insurance, entitled
leave and holidays
1g . Working Hours
• Benefits are paid during work stoppages, if any take place, as
required by law
Code Principle
• The facility correctly and accurately calculates legal withholdings
Overtime must be limited to a level consistent with humane and
(e.g., taxes, social security, pension, or healthcare from worker
productive working conditions. Workers shall not work more than
wages) and file these with appropriate government authorities
48 regular hours (or lower if required by local laws or local industry
in a timely manner as required by law
standards) and shall not exceed 60 hours a week on a regularly

15 IPS Supplier Compliance Guidebook

 scheduled basis. Workers must be given at least one day off in must have access at all times to sanitary facilities, which should be
seven. All overtime must be voluntary. Workers must be provided adequate and clean. Workers must be provided at no cost with all
with adequate breaks as legally required. [ILO Conventions 1, 14 the appropriate personal protective equipment. Where dormitories
and 30] and canteens are provided to workers, the same standards apply.
[ILO Convention 155]
Requirements
Working Hours Requirements
• Regular and overtime hours follow local law Evacuation Plan
• Regular weekly working hours are not more than 48 hours and • Evacuation plans are available in all workers’ preferred
do not exceed more than 60 hours, including overtime hours language(s), are legible, large enough and have clear direction
• Reasonable meal and rest breaks comply with local laws to an exit
• Employers have policies with defined procedures and approval
processes for determining overtime and securing worker Fire Extinguishers/Hydrants
consent • All fire-fighting equipment, including fire sprinklers/
extinguishers/hydrants, are available, visible, unblocked, in their
Consecutive Days Worked designated area and properly maintained
• Workers are provided at least one day off in seven • Training on the proper use of fire equipment is provided to
• A day off is provided and is at least 24 hours of continuous rest workers responsible for fire safety, where required by local law,
with complete training records kept on file
Time Attendance Records
• Records are complete and accurate for all workers, including Fire Alarm System
contract/agent workers, for at least 12 months or longer if • Fire alarm and detection systems are available, visible,
required by law unblocked and properly maintained as required by local law and
• All hours worked are tracked to ensure correct payment of the fire safety standards
legal minimum wage and overtime premiums • A visible and audible fire alarm is installed in all work areas
• Workers record their own hours, including start and stop times, Fire Drills
and have access to their attendance records upon request • Fire drills are conducted at least semi-annually (every six
months) with attendance records and photos on file
• Fire drills cover all shifts, floors and buildings within the whole
facility
Workers are provided at least one day off in seven. • Designated emergency assembly points are large enough to
Best Practices accommodate all workers
 Employers have processes in place to assess their production
capacity in order to avoid excessive overtime hours Two Fire Exits
 Employers have a system to reduce overtime by improving • At least two accessible fire exits are available, unlocked and
workers’ skills through training, mentoring and coaching to unblocked
improve productivity and reduced rework • Emergency exit doors’ design and installation meet all legal
 Employers provide a day of rest that is scheduled on the same requirements
day of the week every week, in order for workers to plan ahead
for that day Exit Signs & Emergency Lighting
 Employers conduct regular internal assessments to ensure the • Exit signs are available in all workers’ preferred language(s), are
time attendance system is being used properly and all working legible and visible
hours are accurately recorded • Emergency lighting is functional in all evacuation passageways,
staircases and exits

Passageways
2 . Health & Safety in the Workplace • Passageways are clear and unobstructed
• Fire routes lead to safe assembly points without obstruction
2a . Health & Safety
Health Monitoring
Code Principle • A system for identifying common illnesses that affect workers is
Employers must provide a clean, safe and healthy work in place and includes analysis of factory clinic health records and
environment and take steps to prevent accidents, illness and injury sick leave records
arising out of or occurring during the course of work. All workers

16 IPS Supplier Compliance Guidebook

 • Employers conduct and cover costs for regular occupational • Chemicals and hazardous substances have secondary containers
health checks for workers as legally required in place
• Chemical fume detectors (where applicable) are available,
Drinking Water functional, properly maintained and monitored
• Adequate and clean drinking water is accessible, with testing • Workers who handle chemicals and hazardous substances are
reports conducted semi-annually (every six months) properly trained
• Factories conduct regular chemical drills (e.g., chemical leakage,
Lavatories accident drill) for all workers handling chemicals or hazardous
• Clean toilets are available and provide appropriate privacy (stalls substances
with doors) • Factories maintain a current Chemical Inventory that lists all
• Fresh water is accessible for toilet flushing and hand washing chemicals utilized with the chemical supplier’s name and
• The number of workers per toilet is at a minimum 25 workers contact information
per toilet, or fewer if required by law • Chemicals and hazardous waste are separated from general
waste and are appropriately handled and disposed of as legally
First Aid required
• First aid kits are properly stocked and accessible • Chemicals and hazardous substances are stored in a designated
• First aid equipment is functional, with maintenance records covered area that is equipped with all necessary safety
properly filed in proximity of the work area measures and equipment as required by law Safety Signs/Labels
• First aid training is provided to workers with complete records • Safety signs/labels are available in all workers’ preferred
on file language(s), are legible and visible
• Emergency eyewash station and/or showers are provided where
corrosive chemicals or high volumes of solvents are handled and Certificates/Permits
used • Factories have all appropriate licenses, registrations and permits
• Factories with onsite clinic and staff have any necessary licenses to perform their current operational activities
up to date and available if required by law • Operator certificates for specialized equipment are valid and
available
Personal Protective Equipment (PPE) • Official safety certificates, licenses and inspection records are
• Appropriate PPE is provided with training and enforcement for kept on file as legally required
worker use
Canteen
Electrical & Machine Safety • Canteens are clean and accessible at all times and have updated
• All electrical equipment/machinery is properly grounded, licenses
insulated, unblocked and has safety labels where required • Cooks have updated health licenses
• Electrical wiring is safe and covered
• All equipment/machinery is properly guarded Working Environment
• Workers are trained on how to use machinery and follow safety • Adequate ventilation and lighting are provided for all
procedures workstations
• Machines and equipment have proper emergency stop switches, • Air quality, temperature and noise levels are reasonable,
with lockout/tagout mechanisms where applicable maintained and monitored as required by local law and all
• Specialized machinery and equipment have all required and up- records are kept on file
to-date licenses/permits
• Qualified professionals (electrician, hired or outsourced) Building Safety
maintain electrical system on a regular basis or as needed, • An official construction approval is available for the building
based on type of equipment, as required by local law • Buildings are regularly maintained and inspected with records
on file
Chemical Safety Data Sheet (CSDS)/Material Safety Data • Factories have updated certificates if needed based on building
Sheet (MSDS) inspections
• CSDS/MSDS are available in all workers’ preferred language(s) • Building structures do not exceed the maximum expected loads
and are legible described by the building’s certificate of occupancy
• Safety training is given to workers with complete training
records on file Childcare Facilities
• A childcare facility is available where required by law
Chemical Management • Childcare facilities are separated from production areas and
• Chemicals are properly identified and stored staffed with sufficient and trained caregivers

17 IPS Supplier Compliance Guidebook

 Dormitories  Chemical storage areas have appropriate fire extinguishers,
• The dormitory is not to be located in the same building with safety signs, ventilation, anti-explosive lights and instructions on
factory workshops and warehouses handling and disposal of chemicals, with personal protective
• Reasonable dormitory space (the greater of 2 square meters per equipment available for workers
person or the space required by local law) is provided for each  A risk assessment should be conducted by a health and safety
worker consultant to identify hazards and risk factors. Control measures
• Workers are provided with individual storage space with a are implemented as a result of the consultation(s)
personal locking mechanism  A crisis management plan to support workers during pandemics,
• Clean toilets are available and provide appropriate privacy (stalls natural disasters, etc., is in place
with doors)  VS&Co is a member of the Sustainable Apparel Coalition (SAC), a
• Fresh water is accessible for toilet flushing and hand washing collaborative partner and trusted leader for industry
• The number of workers per toilet is at a minimum of 25 workers sustainability. The Higg Facility Social & Labor Module (FSLM) is
per toilet or fewer if required by law a self-assessment tool that measures social and labor
• The number of workers per shower is at a minimum of 18 compliance at facilities. Facilities should aim to complete the
workers per shower or fewer if required by law. Hot water for FSLM tool and share findings with VS&Co through the Higg Co .
workers’ cleaning purposes is available website.
• Workers are segregated by gender in different rooms
2b . Environment
Regular Health & Safety Reviews
• An occupational health and safety process is in place and Code Principle
includes a committee to ensure compliance to all VS&Co Facilities should have policies and procedures in place to ensure
standards environmental impacts are reasonably minimized with respect to
• Records and investigation for all accidents, injuries, fatalities, energy, air emissions, water, waste, hazardous materials and other
fires and other emergencies are on file for at least 12 months significant environmental risks. Facilities are expected to make
• A system for identifying common illnesses that affect workers is sustainable improvements in environmental performance.
in place and includes analysis of factory clinic health records and
sick leave records Requirements
• Employers conduct and cover costs for regular occupational Certificates/Permits
health checks for workers as legally required • All legally required and updated environmental certificates,
permits and licenses are available

Procedure for Accidents/Emergency

IPS defines “supplier” as the vendor or partner who • Factories have procedures for notifying local environmental and
community authorities in the event
has signed the Master Sourcing Agreement (MSA)
of accidental discharge or any other environmental emergency
directly with VS&Co.

Best Practices
 Factories have policies and procedures in place to ensure
Best Practices environmental impacts are reasonably minimized with respect
 Dormitories do not have more than 8 people per room; there to energy, air emissions, water, waste, hazardous materials and
are no triple bunks and beds are not directly on the floor other significant environmental risks
 Dormitory ceilings are at least 2.1 meters high  Factories are expected to make sustainable improvements in
 Factories have a process for external medical treatment of environmental performance
workers in the event of occupational injury or illness  Factories have an annual plan to reduce hazardous waste
 Factories have a system for identifying, evaluating and generation and discharge
minimizing risk from physically demanding work and highly  Factories conduct a risk assessment of the impact hazardous
repetitive tasks to prevent work-related injuries or health substances pose in surrounding ecosystems and identify risk
impacts management
 There is clear identification of fire brigade members, health and  Factories have a formal process for complying with local and
safety committee members and first aid leads on production national environmental laws
floors  Factories track and measure – at least annually – the following
 Workers are incentivized to adopt and maintain good health and (if applicable):
safety practices
 Exits lead directly to the exterior of buildings where possible

18 IPS Supplier Compliance Guidebook

 • Energy usage (including energy used on-site (direct), - Payroll records
purchased energy (indirect), as well as fuel use for on-site - Attendance records
transportation) - Worker files
• Water consumption (both quantity and quality) - Employment contracts
• Wastewater discharge (both quantity and quality) - Staffing agency contracts
• Hazardous waste generation (including treatment/ disposal - Benefit/Incentive records
methods) • All documentation required for an audit must be kept on file at
 VS&Co is a member of the Sustainable Apparel Coalition (SAC), a least one year
collaborative partner and trusted leader for industry • All responses to requests should be provided in the requested
sustainability. The Higg Facility Environmental Module (FEM) is a timeframe
self-assessment tool that measures environmental performance • Top management is expected to be committed to transparency
at facilities. Facilities should aim to complete the FEM tool and • Policies, guidelines and systems should be developed to drive
share findings with VS&Co through the Higg Co . website. internal commitment to transparency
• Organizational resources should be structured to support
transparency in all scenarios

3 . Open & Honest Communication Lack of transparency with IPS during the audit process will result in
the factory being categorized as a “higher-risk” site and will result in
3a . Transparency & Traceability
additional corrective action work. Demonstrating transparency
during the audit may expose some deficiencies, but all remediation
Code Principle
will be isolated to those identified issues.
Our Company, subcontractors and authorized agents must be given
unrestricted access to all workers, production facilities and
Traceability Guidelines
dormitories, and be granted access to all relevant records related to
Traceability is a critical expectation for VS&Co business partners. All
production facilities and sub-suppliers, whether or not notice is
suppliers should actively maintain the following data elements: •
provided in advance.
Company profile
• Sub-supplier lists and profiles • Production information
Requirements
• Material sourcing information
For the purpose of monitoring compliance with our policies and
• Production records
meeting the expectations from external stakeholders as needed,
• Shipping records
VS&Co and our subcontractors and agents need to be provided
• Other known relevant data tied to VS&Co production
unrestricted access. This includes, but it is not limited to, access to
all production facilities, dormitories, all relevant records (including
If needed to support a request, VS&Co will reach out directly to
those for temporary workers) and workers/staff (when applicable
suppliers who will be required to provide all necessary
for interviews).
documentation in a reasonable amount of time. All suppliers need
to meet the following:
Transparency Guidelines
• Maintain consistent reference numbers on internal documents
VS&Co anticipates that business partners operate with honesty and
to support the following: - Tie back to purchase orders
accountability related to business transactions and the fair
and style numbers
treatment of workers. However, VS&Co recognizes that suppliers
- All support documents need to be accurately translated to
may face challenges meeting some compliance standards and is
English when submitted
committed to partnering with honest suppliers to improve their
- Where applicable, additional information should be willingly
workplaces over a period of time. For supply chain transparency,
provided
substantiated supporting documents and open communication are
a requirement for sustaining the IPS and Supplier relationship,
The requirements of transparency and traceability benefit each
which also enables identifying actual areas for improvement.
business partner by supporting stability within their organization,
reducing non-compliant events and creating a competitive
For all communication with IPS and its representatives, the
advantage over suppliers who do not operate within these
following practices must occur:
guidelines.
• Only accurate and relevant information should be shared (false
3b . Subcontracting
documentation should not exist nor be submitted; key data
should not be excluded)
Code Principle
• During an audit, all documentation requested should be
We do not allow unauthorized subcontracting and require all
provided, which includes, but should not be limited to:
suppliers to formally request the use of new facilities and

19 IPS Supplier Compliance Guidebook

 subcontractors. Suppliers, sub-suppliers and subcontractors must approval, please contact VS&Co brand partners and IPS, which will
not use any form of home working arrangement for the redirect the questions to the Customs department to determine the
manufacturing of our products. process to follow.

Requirements 3c . Anti-Corruption/Anti-Bribery
Unauthorized subcontracting is not permitted. Unauthorized
subcontracting is where the origin-conferring step of production has Code Principle
been contracted to a facility not listed on the active purchase order Suppliers must comply with all applicable anti-corruption and anti-
(that factory would be considered to be the “subcontractor”). The bribery laws, rules and regulations.
origin conferring step is the production step that changes the raw
materials into a form that most resemble the finished product and Requirements
occurs prior to any finishing work. Suppliers must formally request VS&Co is committed to engaging in honest and ethical business
adding new facilities and subcontractors when changing production practices and expects the same for all business partners. Suppliers
from the original location the purchase order was written to. must follow all applicable local laws, anti-corruption laws and anti-
bribery laws. VS&Co does not tolerate any form of unethical
A change in production locations for orders may be authorized behavior, especially the offering, giving, authorizing, accepting,
when each of the following steps are taken to ensure proper receiving, requesting or promising of a bribe or anything of value
compliance verification and accuracy for all U.S. with the intent to improperly influence someone or gain an
Customs declarations and product traceability: improper advantage.
• Communicate with VS&Co brand partners for written approval
to move a purchase order to a different factory Anti-corruption Laws
• IPS must be alerted of any NEW factories and the location must • Anti-corruption laws prohibit activities or exchanges that are
be submitted to the RizePoint system and confirmed by IPS intended to persuade or influence officials to act for your
- If a new factory is planned for production, no production or benefit
movement of raw materials may occur until IPS has • The term “Official(s)” can be inclusive of:
confirmed written authorization to approve the factory • Government employee (international and domestic)
• An updated purchase order must be issued identifying the • Officer or employee of a public international organization
accurate factory where the origin-conferring step is completed • Person acting in an official role or on behalf of a government,
• All agreements with subcontractors and records of payment department, agency or public international organization
transactions between involved parties must be maintained and • Political party, political party official or candidate for political
made available to IPS or authorized agents upon request office
• Origin labels must correctly include the factory ID of the facility • Family member(s) of persons described above
that completed the origin-conferring production
• Shipping documents must name the accurate manufacturer of Items of Value to Avoid Offering •
the item Anything of Value is defined
• All authorized subcontracting facilities MUST meet the same as:
compliance standards as any regularly utilized partner factory - Cash - Meals
- Cash Equivalents - Transportation (discounts,
If all the requirements noted are not taken and unauthorized gift certifi- - Lodging
subcontracting is detected, IPS will report the incident to brand cates, etc.) - Favors
leadership and treat the situation as a Supplier Code of Conduct - Loans - Job Offers
violation. Unauthorized subcontracting will - Gifts - Business
result in a warning letter being issued, potentially a monetary - Entertainment Opportunities
penalty issued, and it may lead to loss of business for the factory
• Facilitation Payments
and supplier involved.
- Payments or other offerings for non-authorized fees claimed
to speed up official actions
For any questions related to the origin-conferring process and
determining which subcontractor or factory to submit to IPS for

20 IPS Supplier Compliance Guidebook

 VULNERABLE WORKERSRequirements
Special Needs Related to Pre
gnancy

• Employers are aware of women’s special needs, -particu

larly after childbirth, and provide them with benefits and
We require our suppliers to comply with all Supplier Code
facilities for meeting those needs
of Conduct standards as specified in the previous section,
• Employers do not demote, reduce wages, or terminate
particularly as it applies to vulnerable workers, such as
a woman worker because she is pregnant, immediately
women and foreign migrant workers.
before maternity leave, during maternity leave or after
returning from maternity leave
• Employers do not reduce salaries from pregnant workers
1 . Women Workers for taking leave for prenatal medical checks throughout
Women are an important part of VS&Co’s supply chain pregnancy
and we believe they deserve equal opportunities. VS&Co is • Pregnant women who work while standing are provided
committed to respecting women’s rights as per the ILO’s with chairs near their workstations for rest breaks
mandate on gender equality to promote equality between • Employers allow pregnant women to rest for half-an-hour
all women and men in the world of work. The mandate is every four hours of work and do not assign pregnant
grounded in ILO Conventions of relevance to gender equality women in areas with hazardous working conditions
• Employers provide breastfeeding and childcare facilities
- especially the four key equality Conventions - which are the
Discrimination (Employment and Occupation) Convention, as needed or where required by law
Equal Remuneration Convention, Workers with Family • Employers allow workers to take additional leave after
Responsibilities Convention, and the Maternity Protection the three months maternity leave period, if allowed
Convention. The following highlights the requirements that by law
should be applied with special attention to women.
Sexual Harassment
Gender Equality Sexual harassment is defined as unwanted conduct of
Requirements a sexual nature, verbal or physical advances, or sexually
• Women and men receive equal pay for work of equal derogatory/discriminatory statements or acts.
value, equal evaluation of the quality of their work Requirements
assignment, promotion, and equal opportunities to fill • Employers treat all women workers with respect and
open positions dignity
• Employers provide training on discrimination awareness,• Employers do not subject women workers to corporal
particularly as it relates to gender equality punishment, physical, sexual, psychological, or verbal
• Pregnancy testing is not a condition for employment, harassment or abuse
nor is it demanded from workers
• Workers are not forced or pressured to use
contraception

Women and men receive equal pay for work

of equal value, equal evaluation of the quality
of their work and have equal opportunities for
promotions and open positions.

21 IPS Supplier Compliance Guidebook

 2 . Foreign Migrant Workers 3 . Authorized Young Workers
Foreign migrant workers are workers who travel across • Authorized young workers are registered with the local
country borders to obtain employment and are often labor bureau where required by law
subject to modern slavery. Factories that employ foreign • Authorized young workers have their contract(s) signed
migrant workers are closely monitored to ensure workers by a parent or guardian as required by law
are treated in accordance with the law, no worker pays for • Employers protect authorized young workers from
their job or incurs a debt related to the recruitment process, working in hazardous areas
workers retain control of their travel documents, workers • Employers adhere to all local regulations regarding
have full freedom of movement and workers are informed working hour restrictions for young workers, including
of the basic terms of their employment before leaving their regular hours, night hours, and overtime hours
home country/region. • Authorized young workers have access to proper health
examinations as required by local laws
Debt Bondage
Requirements
• Employers do not use irregular, delayed, deferred or 4 . Other Workers
non-payment of wages as a means to bind workers to
employment • Employers are aware of vulnerable workers with special
• Employers do not force workers to work in order to repay needs (e.g., elderly workers, disabled workers, pregnant
a debt workers, etc.) and provide proper support, including, but
• Recruitment fees or deposits are not charged to workers, not limited to, lighter work, proper breaks and flexible
inclusive of fees for travel visas, health checks, employ
- time options
ment registration, work permit, agency/management
fees or referral fees
• Workers retain original copies of personal documents
(i.e., birth certificates, passports, work permits,
- resi
dence cards, labor contracts and national identity cards,
etc.)
• Employers are responsible for conducting thorough due
diligence on all labor agents used in the recruitment and
employment of foreign migrant workers
• Labor contracts meet all legal requirements and a copy
is shared with workers in their preferred language before
leaving their country of origin
• Workers do not pay a fee or deposit to secure a job
• Employers are responsible for all fees associated with
employment agencies
• Employers ensure workers have full control of their bank
account(s) if they are paid by direct deposit into a bank

22 IPS Supplier Compliance Guidebook

 1 . Program Assessment Standards
D. TRADE Our Trade Compliance program has set forth expectations to assess
compliance at factories. All factories must meet the following

COMPLIANCE
requirements:
• Complete documents which demonstrate the flow of production
from raw materials to finished goods (e.g. purchase orders,
material planning sheet, material purchase receipt, transfer
Overview notes, invoice, internal transfer, production records, export
As an importer, VS&Co is legally responsible to report the accurate documents, payment records, etc.)
country of origin and place of manufacture to U.S. Customs and • Accurate information including dates, order numbers, product
Border Protection (CBP) for each purchase order we import. To do reference, color, quantity and persons or companies responsible
so, it is imperative that we ensure the factory is capable of making during transfer in the manufacturing process, and authorized
the product, noting the appropriate manufacturer name and signatures
address on commercial shipment documents, and is not • Linkage between documents though a unique reference number
subcontracting orders without our explicit approval. listed on all related documents
• Records must be on file for at least two years
The objective of the Trade Compliance program is to assess the
factory’s ability to provide complete and accurate documentation
2 . Subcontracting
to support a product’s country of origin and place of manufacture in
For our subcontracting requirements, please see the Labor
various stages upon request from CBP. IPS will assess the factory’s
Standards and Workplace Conditions section of the Guidebook
production process and capacity by observing the factory set up as
(section B under Open & Honest Communication 
well as reviewing documentation systems and records.
Subcontracting).

The supplier must require each of its factories that manufacture all
or any part of the goods contracted for VS&Co to maintain
production documentation for a period of at least two years (or
IPS defines “supplier” as the vendor or partner who
longer if specified by IPS) following the shipment of goods. Such
records are necessary to establish the origin of all goods produced
has signed the Master Sourcing Agreement (MSA)
and to satisfy any other regulatory requirement that may rely on directly with VS&Co.

E. SUPPLY CHAIN
manufacturing records.

The factory is expected to maintain evidence of raw materials

sourced and received prior to production, production records for
each process performed at the factory and commercial shipment SECURITY
documentation reflecting the correct factory name and address.

Overview
Supply chain security is a critical function for supporting
Suppliers and factories are expected to maintain a international trade and promoting safety throughout the VS&Co
complete list of material sub-suppliers and also supply chain. The Customs Trade Partnership Against Terrorism
provide awareness training to all sub-suppliers on (CTPAT) program is a partnership between U.S. Customs and Border
Protection (CBP) and the trade community aimed at achieving a
documentation to keep on file to trace down all
maximized level of security for the movement of product. To
materials in their supply chain.
achieve this goal, CTPAT created a common set of criteria that
IPS or the approved third-party auditor has the right to require the
manufacturers and importers must meet or exceed when shipping
supplier or its factories to permit access to any and all records
product from origin to a final destination.
required to conduct origin verifications or capacity monitoring. The
supplier agrees that such records will be maintained in a form and
VS&Co is dedicated to the CTPAT program and maintains a Tier 3
at locations that will allow them to provide these records to IPS or
level importer status. The Tier 3 status represents a supply chain
our approved third-party auditor in a prompt manner.
that exceeds the established criteria and challenges each of their
partners to also go beyond the basic criteria. As a result of this
effort, our Supply Chain Security program is comprehensive, and
the requirements enable our partners to maximize their security

23 IPS Supplier Compliance Guidebook

 efforts in each of their facilities and for all of their business Section A – Physical Security
partners. 1. Physical barriers/fencing or deterrents are present to
prevent unauthorized access, especially to cargo loading and
1 . Risk Assessment & Review trailer yards (Criteria 9.1 and 9.2)
IPS performs an annual risk assessment of all production facilities 2. Limited access points that are staffed/monitored with
to assign a risk level based on country of origin, previous audit inspection (Criteria 9.4)
results and open source data on country threat levels. Areas 3. Separate parking areas with no passenger vehicles permitted
reviewed during the risk assessment include, but are not limited in cargo handling, storage areas or conveyances (Criteria 9.5)
to, the following: • Business allocation percentage (Core vs. 4. Adequate lighting inside and outside facility, especially in
Transactional) secure areas (Criteria 9.6)
• Country of origin 5. Facility should utilize an alarm system or CCTV cameras to
• Mode of transportation monitor facility, especially key areas pertaining to the
• Previous supply chain security audit results import/export process (Criteria 9.7 and 9.13)
• Prior reported security breaches 6. Designated security personnel or security system must
• Potential for terrorist activity in the country of shipment monitor all high-risk areas with documented procedures,
• Risk of transshipment reviews and access rights; records should be maintained for
• Other socio-economic issues that may increase risk levels six months (Criteria 9.8, 9.10, 9.12,
Factories are grouped into the corresponding risk level to 9.15 and 10.10)
determine the scope of supply chain security reviews they will be 7. Ensure there are written policies and procedures for security
subjected to, which may include: personnel and that they have a reliable means of
• Supply Chain Security Questionnaire to provide information on communication to report any issues (Criteria 10.10)
the policies and procedures in place, 8. CCTV cameras should be recorded for a sufficient amount of
• Performance of a desk review, where support documentation time to facilitate an investigation should an issue be
for various CTPAT requirements will be requested without a discovered upon importation to the United States; VS&Co
physical site visit, or requires recordings to be kept for at least three months
• Performance of a full supply chain security on-site review or (Criteria 9.16)
submission of completed third-party audit 9. Records of any inspection, testing, repair work or new
installation of security systems or cameras must be
Per VS&Co’s Supplier Code of Conduct, our company, maintained for a period of six months (Criteria 9.15)
subcontractors, and authorized agents must be given unrestricted 10. Procedures should be in place for the issuance and
access to all workers, production facilities and dormitories, and be recordation of physical keys to the facility, with a key log
granted access to all relevant records related to production facilities (Criteria 10.1)
and sub-suppliers, whether or not notice is provided in advance.
This includes information pertaining to supply chain security Section B – Physical Access Controls
controls and procedures. 1. Facility should have a written policy for the issuance and
retrieval of identification badges to/from permanent and
2 . Program Requirements temporary workers and controls in place to limit system and
Minimum Security Criteria for Foreign Manufacturers are outlined facility access based on job description (Criteria 10.1)
by CBP. The following is a summary of the areas tested during a full 2. Workers are to show badges for access to facility and have
on-site supply chain security review and the corresponding criteria. them visible while in the building (Criteria 10.1)
3. Written policy for what can be brought into the facility,
Foreign manufacturers must meet each of these requirements to be including a screening process
in full compliance and receive the maximum score during a full 4. Visitors and contractors are required to show a photo
supply chain security audit. Not all criteria (must vs. should) ID with a log being kept for a period of six months
outlined in the CBP publication will be tested with assigned scoring (Criteria 10.2)
during an on-site; however, evidence will be required to ensure that 5. Visitors must be issued a badge with a tracking number, and
a supply chain security program is in place and that controls are badges must be recorded as returned upon departure from
created/adapted based on risk. This includes having a management the facility (Criteria 10.2)
system in place, wherein dedicated individuals are responsible for 6. Visitors must be escorted while on the premises
establishing and testing the controls in place. Section references are (Criteria 10.2)
based on the areas tested during an internal IPS supply chain 7. All vehicles are stopped and inspected prior to entering the
security audit. facility, with a log being kept for a period of six months
(Criteria 10.4)

24 IPS Supplier Compliance Guidebook

 8. All inbound trucks are stopped and inspected prior to 1. Facility must have thorough written container loading
entering the facility, including paperwork and seals procedures for identification, storage, inspection and
(Criteria 10.3 and 10.4) loading of all trailers/containers entering the facility
9. Policy in place for challenging unauthorized persons, with (Criteria 5.2)
training provided to all workers (Criteria 7.24) Section C – 2. Prior to loading, a 7-point inspection is performed on all
Personnel Security containers/trailers and a 10-point inspection on all tractors
1. Pre-employment screenings include a criminal history check for damages or issues with structural integrity; completed
(if legally possible); employees in key positions should have inspection reports are to be signed by the employee
periodic checks performed to ensure they have not been performing the inspection and a witness, with records
involved in any criminal activity after the date of hire (Criteria retained for six months (Criteria 5.3, 5.4,
11.1 and 11.2) 5.5, 5.6 and 5.8)
2. Facility must have a written code of conduct outlining
7-Point Container Inspection
expectations of acceptable behavior and provide training to
3 . Right Side
all employees on both facility and customers’ codes of
6 . Ceiling/Roof
conduct, with proper records kept on the trainings (Criteria
11.5) 5 . Front Wall

3. Facility must have a written procedure for employees who

leave the company, which includes the recovery of badges
and termination of any system access; records must be
maintained for six months 4 . Left Side

Section D – Education & Training Awareness

7 . Floor (Inside )
1. Factory must have a point of contact responsible for the
supply chain security program and documentation 1 . Outside/Undercarriage
2 . Inside/Outside Doors

maintained that all activities and issues are communicated to

leadership (Criteria 1.1, 1.2, 1.3 and 1.4) 3. Procedure for loading and inspection include an inspection
2. Training for new hires includes policies on supply chain for agricultural pests (insects, eggs, webs, nests), which is
security, with an attendance log maintained for six months documented on the inspection report
(Criteria 12.1 and 12.2) (Criteria 5.2, 5.7, 7.2 and 8.1)
3. Annual refresher training is provided on an annual basis, with 4. All full container loads leaving the facility must be sealed
records kept (Criteria 12.1) with a high security bolt seal meeting ISO 17712
4. Security program includes an incentive program to encourage requirements (Criteria 6.2 and 6.5)
workers to report security issues; this program is 5. Facility must have documented procedures for the receipt,
communicated to all workers storage/inventory and application of the security seal,
5. Periodic checks of the security program and workers’ including seal integrity using the View, Verify Tug, Twist and
knowledge of the requirements are performed, with Turn (VVTT) process (Criteria 6.1,
complete records, including corrective action plans, kept for 6.6 and 6.7)
six months (Criteria 12.4) 6. Containers stored on site must be maintained in a controlled
6. Emergency contact information is posted in the factory in all area monitored by CCTV cameras or security (Criteria 5.1
workers’ preferred languages and 7.1)
7. Digital photographs are taken during stages of the loading
process (beginning, middle, end), including the closing of the
doors and application of the seal; photographs should be
It is important that a list of emergency contacts is taken that clearly show the container and seal number and
posted in multiple locations throughout the factory in should be retained for six months (Criteria 7.5)
languages understood by the workers, in order for 8. Seal numbers are indicated on the shipping documentation
workers to know who to contact in case of an and records are retained for six months (Criteria 7.6, 7.7. 7.8
emergency. The factory should assign a main and 7.30)
emergency contact, and the person should be trained 9. Security procedures must contain escalation policy for
on all emergency procedures. reporting any issues with containers/trailers or seals to the
Section E – Security Loading Procedures supplier, with full records (Criteria 5.29 and 7.37)

25 IPS Supplier Compliance Guidebook

 10. Factory must have documented procedures for validating k. If employees are allowed to use personal devices to
the pick-up party of loaded containers, including validating access system, facility must ensure that these meet the
driver and supporting documentation security requirements (Criteria 4.10)
11. Factory must have documented procedures to show l. Immediate termination of access of workers that are
shipments are tracked to the consolidator/port and that an separated from company
escalation policy exists should any discrepancies or evidence 4. Facility must have documented procedures for system
of tampering be found (Criteria 5.14 and 7.23) maintenance, data recovery, disposal/sanitization of IT
12. Same procedures must be followed for Loose Container equipment and an escalation policy to report any issues
Loads (LCL) (Criteria 4.3, 4.4, 4.6, 4.12 and 4.13)

Section G – Business Partner Review

1. Facility has documented procedures for the selection and
Suppliers are responsible for contacting IPS within screening of business partners, including verifying business
24 hours in the case of a supply chain security license and performing a criminal background check; criminal
breach and must provide a complete report of the background checks are required for all drivers/companies
initial incident, pending items and a full explanation responsible for moving goods and materials in/out of the
of the remaining actions that will be taken. Post- facility
incident updates are required to keep IPS informed (Criteria 3.1)
of the status of pending items and progress of 2. Business partners are provided written communication on
CTPAT requirements, with record (Criteria 3.5)
remediation steps implemented as a result of the
3 . Importer Security Requirements
breach.
In January 2010, CBP began the enforcement of the Importer
Security Filing (ISF) and additional carrier requirements regulation
(referred to as the 10+2 rule) that requires importers and ocean
carriers to electronically provide advance shipment information to
Section F – Cybersecurity
CBP for U.S.-bound ocean cargo.
1. Facility must have a written cybersecurity policy that is
reviewed and communicated annually to employees with
It is imperative that suppliers ensure accurate ISF shipment data is
systems access; records must be kept for six months (Criteria
provided to freight forwarders and ocean consolidators and in
4.1)
response to any ISF requests. Suppliers must also verify that any
2. Annual cybersecurity training must be provided to employees
related information, including purchase orders and systems, are
with systems access (Criteria 12.8, 12.9 and
accurate. CBP may issue penalties of $5,000 per violation for the
12.10)
submission of an inaccurate, incomplete or untimely filing. Non-
3. Cybersecurity controls need to be in place to prevent/ deter
compliant cargo may also be subject to further inspection on arrival,
unauthorized access (Criteria 4.2), including: a.
causing delivery delay. (Criteria 7.6, 7.7 and 7.8)
Monitoring for unauthorized use or tampering
with data (Criteria 4.5)
Where to Learn More
b. Disciplinary action for unauthorized use
For additional details on each criteria please click HERE for details
c. Prevention of attacks through common social
issued by CBP.
engineering methods
d. Ensuring only properly licensed technology
products are used (Criteria 4.11)
e. Having an intrusion detection system (i.e., firewall)
in place ISF requirements - Shipment Data Required
f. Regular security updates and testing • Seller name and address
g. Individual user logins and passwords (Criteria 4.8) • Buyer name and address
h. Defined strength requirement for passwords and a • Importer of record number
requirement that these be updated at least every • Consignee number
90 days (Criteria 4.8) • Ship to party name and address
i. System access restricted by user role (Criteria 4.7) • Manufacturer name and address
j. System in place to allow/monitor remote access • Country of origin
and prevent remote access by unauthorized users • Commodity HTS 6-digit number
(Criteria 4.9) • Container stuffing location

26 IPS Supplier Compliance Guidebook

 • Consolidator name and address • Supplier partnership with factory to identify root cause issues
• Container status messages for findings and develop sustainable solutions
• Vessel stow plan • Supplier’s initial submission of Corrective Action Plan (CAP)
made in RizePoint within 30 days of receiving the audit report

F. REMEDIATION • Communication with IPS regarding any challenges relative to

meeting the Guidebook standards
IPS is committed to continuous improvement of compliance within • All corrective action plan submissions must include accurate and
our supply chain. Factories producing Victoria’s Secret, PINK, and translated supporting documents
Victoria’s Secret Beauty products must work to achieve sustainable • Full remediation for all non-compliant findings must be
compliance with VS&Co standards through remediation actions for completed within 90 days of receiving the audit report
all non-compliant items identified.

Requirements
IPS strives to work with suppliers to drive continuous improvement Suppliers should work with their factory on a
in working conditions and achieve sustainable compliance with corrective action plan (CAP) and review all
VS&Co standards, policies and local law. Remediation is required information and supporting documents the
when issues are identified during the audit. Depending on the level factory provides before they submit the
and type of non-compliance identified, IPS will determine next information into RizePoint. It is the supplier’s
steps, which may include, but are not limited to, corrective action, responsibility to submit all corrective actions
consulting services and follow-up audits. within 30 days of notification and complete them
within 90 days.
Critical milestones and activities required in the remediation
process include:

27 IPS Supplier Compliance Guidebook

 VS&CO CORRECTIVE ACTION
PLAN PROCESS FLOW CHART
Remediation from Date of Report Issued to 90 Days Beyond 90 Day CAP Deadline

Immediate Supplier/
IPS meeting held to
0-30 Days Audit Completed discuss missed
Initial CAP must be (Annual or CAP deadline
submitted Preproduction)

0-90 Days
Supplier will
continue to YES NO
submit CAP details
and support until
all line items are CAP complete 30
closed Audit report issued through days later?
RizePoint for supplier
access

NO YES

CAP Required CAP is completed/ closed

Supplier provides
remediation for Warning letter issued to
No action required
non-compliance to Supplier
RizePoint

NO
Brand and IPS evaluate
Supplier
status and determine next
IPS team review of steps
CAP

CAP items complete and

supported?

YES

28 IPS Supplier Compliance Guidebook

 CAP is completed/ closed

G. SUPPLIER
RESPONSIBILITIES &
MANAGEMENT
SYSTEMS
1 . Management Systems
• Establish a point of contact in the company to be responsible
for compliance matters
• Maintain an updated factory base with complete details,
including ownership structure, name and address in RizePoint
• Review the IPS Compliance Guidebook, understand IPS’
requirements and ask questions if something is not clear
• Ensure that the factory has management systems, policies and
internal controls in place to facilitate compliance with VS&Co
standards and local laws
• Ensure that factories receive and display a copy of the VS&Co
Supplier Code of Conduct
• Work with factory representatives on compliance
• Ensure factory management is aware of local and national labor
laws
• Verify that factory management and workers have a formal
training process for compliance requirements
• Confirm that your company and factory management are aware
of applicable anti-corruption/anti-bribery laws and regulations
• Develop a robust social compliance process to strengthen
capacity building as it relates to meeting compliance with
minimum requirements and achieving best practices
2 . Communicate with IPS
• Notify IPS of any changes to your company’s contacts
• Notify IPS of all issues under the “24-Hour Notification Policy” in
section A, under Policies
• Coordinate with IPS on audit schedules and logistics
• Provide a root cause analysis to determine reasons for non-
compliance
• Submit corrective action plans in RizePoint within 30 days of
audit notification and complete all corrective actions within 90
days
• Attend IPS’ Communication Sessions and other training
programs as requested by VS&Co
• Notify VS&Co and IPS if your company has a name or address
change; any name or address change of a supplier will need to
be updated in our database

29 IPS Supplier Compliance Guidebook

 • Notify VS&Co and IPS if a factory name or address changes; any •Review corrective action support provided by each factory to
name or address change of the factory will be classified as a ensure that it meets IPS’ requirements
new factory, which will require an audit and approval before • Ensure all training and communication is delivered in the
production can begin if the factory is new or for production to preferred language(s) of workers
continue if the factory is already approved • Communicate VS&Co standards and provide training to sub-
• Notify VS&Co and IPS if a factory name and address on the suppliers
purchase order are not correct 4 . Due Diligence
• Request VS&Co and IPS’ approval if an order needs to be • Visit factories frequently to verify that they meet VS&Co
subcontracted compliance standards
• Notify IPS if VS&Co goods will be produced in factories that use • Ensure sub-suppliers meet VS&Co compliance standards
foreign migrant workers • Attempt to be present during audits and ensure factories are
transparent and cooperative
• Work with factories on any corrective action required as a result
of the audit and encourage them to complete corrective actions
The IPS Compliance Guidebook (Guidebook) includes
within 90 days
a set of mandatory requirements which all our • Review RizePoint at least once every month, to ensure that
suppliers as well as their factories, sub-suppliers and corrective action items are not outstanding
subcontractors need to meet to be able to do • Review factory base often; add any new factories in RizePoint
business with VS&Co. and inform IPS of factories that are no longer producing for
3 . Communicate with Factories & Sub-Suppliers VS&Co
• Ensure that the factory receives and displays a copy of the • Plan ahead with current list of approved factories and
VS&Co Supplier Code of Conduct poster in the language(s) subcontractors to ensure there is capacity to meet production
workers understand needs and continuously monitor factories for capacity changes
• Distribute a copy of the IPS Compliance Guidebook to each through visits
factory that produces for VS&Co • Gather information about any conflict minerals used in the
• The IPS Compliance Guidebook (Guidebook) includes a set of goods produced for VS&Co and respond to VS&Co’s annual
mandatory requirements which all our suppliers as well as their conflict minerals information request within the requested
factories, sub-suppliers and subcontractors need to meet to be timeframe
able to do business with VS&Co • Gather information about upstream suppliers for VS&Co and
• Educate factories on critical non-compliances and assist respond to IPS in a timely manner in regards to requests for
factories in establishing compliance management systems sub-supplier information in the supply chain
• Forward audit reports to the factories • Maintain accurate and complete records as specified through
• Work with factories to create corrective action plans the Guidebook

H. PLATFORMS
VS&Co respects the privacy of all our suppliers. We handle digital information about suppliers responsibly. The systems that IPS utilizes to
manage VS&Co’s social compliance program allows our suppliers, auditors and associates to access critical information. Some of the information
stored includes policies, guidance tools, supplier and factory information, audit reports, corrective action plans, remediation status and ongoing
surveys. IPS has partnered with the platforms listed below to help manage VS&Co’s supply chain data as it pertains to our social compliance
program.

IPS Platforms RizePoint Sourcemap

Overview RizePoint is an internet-based system used by

IPS to maintain supplier and factory Sourcemap is a supply chain transparency
information for our brands. platform that provides supply chain mapping
and transparency.
We use RizePoint mainly as a repository for
audit results. We use Sourcemap for:
• Mapping our supply chain
• Supplier Surveys

Users and Access Primary users are Suppliers, who can give
Primary users are Suppliers. access to factories if needed.

30 IPS Supplier Compliance Guidebook

 • Users must be invited into the platform
Note: It is IPS’ policy that RizePoint access is granted by “Sourcemap Inc.” to get access
only to suppliers and not to factories. The supplier is
responsible for communicating IPS’ compliance • Users register using their emails
requirements and audit reports to the factory. The • Users can invite members of their
supplier is also responsible for submitting any company to register and gain access to
corrective actions on behalf of the factory. It is a Sourcemap
violation of IPS’ policy to provide your username and
password to a factory to access RizePoint.

Functionalities Authorized users can access the following

pages via the Account page:
RizePoint allows suppliers to: 1. Edit surveys
1. Download compliance standards and 2. Submit surveys
program guidance 3. Invite other members of their
2. Submit a new factory via the Factory company to edit and submit surveys
Set-Up form for audit arrangement 4. Edit their account description, address,
3. Download audit reports upon receipt and logo
of system email notification
4. View active and prohibited factory
lists
5. Submit corrective action plans and
supporting documents and/ or photos
onto Corrective Action
Management (CAM) module in
RizePoint
6. Submit Reorder request for VS
& Co Supplier Coder of Conduct Poster
7. Submit Sell-off request

Resources Users can learn more by logging on to

Suppliers can download step-by-step
Sourcemap or you can contact the IPS team.
system guidelines by selecting the
Guidance icon on the RizePoint Home page
and clicking on the “RizePoint Guidance”
link.

If guidance is received from VS&Co business partners that

I. BRAND conflicts with the guidance in this Guidebook, please contact
Brand Protection (BrandProtection@lb .com) for clarification.

PROTECTION Brand Protection Definitions

• Counterfeiting – Is a crime, involving the manufacturing or
distribution of goods that are being passed off as originals, or
Overview genuine, without the trademark holders’ permission
The primary responsibility of the Office of Brand Protection (Brand • Diversion – Product diversion occurs when genuine product is
Protection) is to protect VS&Co’s intellectual property and the sold outside an authorized distribution channel
reputation of our brands. Because VS&Co is expanding, and our • Intellectual Property Rights - Rights given to persons over the
brands are internationally recognized, our brands are potential creations of the mind, such as inventions (Patents); literary and
targets for illegal activities such as counterfeiting, diversion, artistic works (Copyrights); designs; and symbols, names and
trademark infringement and intellectual property rights violations. images used in commerce (Trademarks)
Each of these activities negatively impacts our business and our • Trademark Infringement – Is the unauthorized use of a
supplier relationships. They put our brands at risk and may result trademark, or service mark (or a substantially similar mark) on
in larger issues for VS&Co. competing or related goods or services

IPS conducts the Brand Protection audit on behalf of the Office of

Program Standards
This section lists the compliance standards for the Brand Protection
Brand Protection. Any questions about the audit program and the
program. Factories must meet each of the standards listed to
destruction or sell-off processes should be directed to the Office of
receive the maximum score in an audit. If a factory meets some or
Brand Protection.

31 IPS Supplier Compliance Guidebook

 none of the criteria it will receive a partial score or a zero for the • All subcontracting records are kept for at least two years
question. • Records must include the customer purchase order or factory
lot number, a description of the item, the SKU/ style number (if
Section A: Photos applicable), the subcontractor’s name, the quantity and date
Photo Control sent to the subcontractor and the quantity and date received
• Only VS&Co associates are permitted to photograph VS&Co back from the subcontractor
products and designs
• Do not allow photographs on the factory premises or in its Section D: Control of Raw Materials with VS&Co Logos or
offices unless prior approval from factory senior management is Trademarks
obtained The following section refers to any raw material, trim or other
• Signs must be posted in the factory for awareness accessory that includes Victoria’s Secret or PINK logos or
trademarks.
Section B: Samples
Showroom Storage
• Samples are not displayed in the showroom until at least three • Components, raw materials, trims, labels, accessories, and other
months after the bulk order is shipped to VS&Co items containing VS&Co intellectual property for current
• Accurate records must be maintained, indicating the production or leftover items are clearly identified and stored in
article/style number and the date of the bulk shipment, for each a controlled area with accurate and complete records
sample displayed in the showroom Section E: Control of Finished Goods
• Do not display current production in a showroom at any time This section refers to any finished good that includes
Victoria’s Secret and PINK logos or trademarks.
NOTE: VS&Co beauty & home items cannot be used for marketing Storage
or showroom display purposes. • All finished goods in current production, including samples,
overproduction, cancellations and returns to vendor (RTVs), are
Sample Management clearly identified, and stored in a controlled area with accurate
• All production, quality and other samples not maintained in the and complete records
showroom should be managed during production and after the
bulk shipment; accurate and complete records are maintained
Section C: Subcontracting Control on Printing, Embroidery or
Washing Processes Any questions about the brand protection program or
The following section refers to products or their components, the destruction and sell-off processes should be
artwork, print screens or other items containing VS&Co intellectual directed to the office of brand protection.
property that are shipped to a subcontractor for a secondary
process (e.g., printing, embroidery or washing). The factory must
have a one-for-one process, meaning that all products or
components sent to a subcontractor must be returned to the Section F: Destruction Control
factory, including defective items. Defective items must be stored in Any items containing Victoria’s Secret or PINK logos, or trademarks
a controlled area and destroyed or sold according to the guidance in must be destroyed or recycled using the process below. For the
sections D and F. purposes of this section, “Destroyed,” means either converting
goods to an unusable state as refuse, waste-to-energy, or the
Return of VS&C’s Intellectual Property recycling of the goods into another product. The following section
• All items sent to subcontractors are returned to the factory refers to the processes for all Victoria’s Secret or PINK samples,
(including defective items) with accurate and complete records finished goods, components, artwork, print screens, raw materials,
• Do not store films, print screens or other artwork with VS&Co labels, accessories, or other items containing VS&Co’s intellectual
logos or trademarks at the subcontractor property.

Storage Destruction Period for Components, Artwork, Labels,

• All items that are returned from subcontractors are clearly Raw Materials or Accessories
identified and stored in a controlled area with accurate and • Discontinued components, artwork, print screens, raw
complete records unless they are immediately sent to materials, labels, accessories, or other items containing VS&Co
production intellectual property are destroyed or recycled at least quarterly

Recordkeeping Destruction Period for Samples and Finished Goods

32 IPS Supplier Compliance Guidebook

 • Samples and finished goods (including overproduction and third-party by submitting a request in RizePoint. If the request is
rejected goods) containing VS&Co intellectual property are approved by VS&Co, a certificate will be issued in the system as
destroyed or recycled at least twice a year; more frequent evidence that the goods have been approved for sale.
destructions are permitted if they are needed to control
inventory The following requirements must be met to comply with our sell-off
policy. Failure to comply with our policy may result in financial or
Destruction Process legal penalties, or it may result is loss of business with VS&Co:
• The destruction or recycling method must prevent the reuse of Sell-Off Process
the item • Sell-off requests must be submitted through the RizePoint sell-
• All destructions (by cutting, burning, etc.) are witnessed by off process
factory management with accurate and complete • Sell-off requests must be authorized by the customer, evidenced
records/photos by a Sell-Off Approval Certificate from RizePoint
• Brand Protection supports the controlled recycling of goods in a • Sell-off requests are submitted at least one year after the last
manner whereby the branding is removed, or the product is shipment of the bulk order
deconstructed • Logo Removal
NOTE: Full destruction guidelines are available by selecting the • Any logos, marketing (such as main labels, hang tags, price
Guidance icon and the “Brand Protection” link in RizePoint. tickets, etc.), artistic work or other material that may identify
goods with VS&Co is removed from finished goods with photos
before goods can be released to a sell-off buyer
• Do not deliver goods to the sell-off buyer with VS&Co logos or
Any items containing Victoria’s Secret or PINK trademarks intact
logos, or trademarks may not be sold to a third • Recordkeeping
party, they must be destroyed using the process in • All sell-off records, including buyer details, are kept at least two
Section F. years

Where to Learn More

For additional information about the Brand Protection audit
Logo Removal program and its scoring criteria, please sign into RizePoint, select
• Any logo(s), marketing (such as main labels, hang tags, price the Guidance icon, then select the “Brand Protection” link. To
tickets, etc.), artistic work or other material that may identify download step-by-step instructions for how to submit a sell-off
goods with VS&Co is removed from finished goods and request, please sign into RizePoint, select the Guidance icon, and
destroyed separately (if not incinerated) before destruction, select the “System Navigation and Procedures” link.
with complete photos/records
• Logos, marketing, and artistic works should be cut into at least
two pieces or incinerated to prevent reuse CONTACT LIST
Eastern Hemisphere
Recordkeeping Simon Pound
• All destruction records are kept at least two years Director, Operations
• Records must include the customer purchase order or factory Email: [email protected]
lot number, a description of the item, the SKU/ style number,
the quantity destroyed and the destruction date Dana Nwadike
Director, Vendor Compliance Email:
Section G: Sell-off Control [email protected]
Any items containing Victoria’s Secret or PINK logos, or trademarks
may not be sold-off and must be destroyed using the process in Western Hemisphere
section F above unless the branding can be removed or otherwise Odilia de Ciutiis
concealed. Director, Social Compliance Email:
[email protected]
The VS&Co MSA requires that suppliers and their partners use
VS&Co trademarks, copyrights or other intellectual property only as Michael Hippler
we specifically allow. When suppliers have overproduction or other Director, Compliance Audit Email:
inventory that VS&Co rejects due to inconsistencies with our quality [email protected]
standards, they may request to sell the unbranded product to a

33 IPS Supplier Compliance Guidebook

 Issue Escalation Associate Vice President, Global Compliance Investigations
Shelly Zimmerman Email: [email protected]
Vice President, Independent Production Services (IPS)
Email: [email protected] Anti-Corruption
William Hughes
Leigh Schmid Associate Vice President, Anti-Corruption &
Senior Vice President, Global Trade Compliance VS&Co & Third-Party Risk Management
President, Independent Production Services (IPS) Email: [email protected]
Email: [email protected]
Victoria’s Secret & Co . Ethics Hotline
Brand Protection U.S. & Canada Phone: (844) 575-1079
Alan Swayne Other country phone numbers can be found on the website
Web: vsco.ethicspoint.com

SUPPLIER CODE OF
CONDUCT
SUPPLIER CODE OF
CONDUCT
The Supplier Code of Conduct sets forth standards — in addition to all relevant laws, regulations and conventions — that apply to suppliers and their factories, sub-suppliers and
subcontractors. Suppliers must adhere to these standards and communicate them to all workers in all countries in which they operate.

A FAIR & RESPECTFUL OPEN & HONEST TRANSPARENCY & TRACEABILITY

Our company, subcontractors and authorized agents must be given unrestricted access to all

COMMUNICATION
workers, production facilities and dormitories, and be granted access to all relevant records
WORKPLACE related to production facilities and sub-suppliers, whether or not notice is provided in
advance.
FORCED LABOR, SLAVERY & HUMAN TRAFFICKING
Forced, prison, indentured, bonded, and slave labor as well as labor obtained
through human trafficking are prohibited throughout our supply chain. Employers
FREEDOM OF ASSOCIATION, RIGHT TO
must not require workers to provide deposits or recruitment fees. If recruitment ORGANIZE & COLLECTIVE BARGAINING
fees exist, the employer is responsible for payment of all employment eligibility and Workers’ rights to freedom of association and collective bargaining must be
recruitment fees. The employer is not entitled to retain workers’ personal identity respected, as well as rights to refrain from participating in organizations of their
documents and all workers must have freedom of movement. [ILO Conventions 29 choosing. Facilities must not interfere with, harass or intimidate workers who
and 105] lawfully and peacefully associate, organize or bargain collectively. [ILO Conventions
87, 98, 135 and 154]

CHILD LABOR
All workers shall be at least the local minimum legal working age or ILO standard, WAGES & BENEFITS
whichever is higher. The facility must take all necessary precautions to ensure that Employers must compensate workers with at least the min imum wage prescribed by
authorized young workers, under the age of 18, are protected from working local law, the prevailing industry wage or the wage negotiated in a collective
conditions that could pose a danger to their health, safety, or development. [ILO bargaining agreement, whichever is higher. Employers shall compensate all overtime
Conventions 138 and 182] work at a premium rate and provide benefits as stipulated by local laws. Suppliers
should strive to pay a wage sufficient to meet workers’ basic needs and provide some
discretionary income. Illegal or disciplinary deductions are not permitted. [ILO
DISCRIMINATION Conventions 1, 95 and 131]
Workers must be selected only on the basis of their ability to do the job. Employers
must not discriminate in employment, including hiring, compensation,
advancement, termination, or discipline, on the basis of sex, gender identity, race, WORKING HOURS
religion or belief, age, disability, illness, sexual orientation, pregnancy, marital Overtime must be limited to a level consistent with humane and productive working
status, civil partnership, nationality, political opinion, social or ethnic origin, or conditions. Workers shall not work more than 48 regular hours (or lower if required
other protected status. All workers, regardless of gender, shall receive equal pay for by local laws or local industry standards) and shall not exceed 60 hours a week on a
work of equal value. [ILO Conventions 100 and 111] regularly scheduled basis. Workers must be given at least one day off in seven. All
overtime must be voluntary. Workers must be provided with adequate breaks as
legally required. [ILO
HARASSMENT OR ABUSE Conventions 1, 14 and 30]
Workers must be treated with respect and dignity. No worker shall be subject to
humiliating or corporal punishment, and the workplace must be free from all forms
of physical, sexual, psychological, or verbal punishment, coercion, intimidation,
harassment or abuse. [ILO Convention 190]

HEALTH & SAFETY

Employers must provide a clean, safe and healthy work environment and take steps
to prevent accidents, illness and injury arising out of or occurring during the course
of work. All workers must have access at all times to sanitary facilities, which should

HEALTH & SAFETY IN be adequate and clean. Workers must be provided at no cost with all the
appropriate personal protective equipment. Where dormitories and canteens are ENVIRONMENT

THE WORKPLACE provided to workers, the same standards apply. [ILO Convention 155] Facilities should have policies and procedures in place to ensure environmental
impacts are reasonably minimized with respect to energy, air emissions, water,
waste, hazardous materials and other significant environmental risks. Facilities are
expected to make sustainable improvements in environmental performance.

34 IPS Supplier Compliance Guidebook

 SUBCONTRACTING
We do not allow unauthorized subcontracting and require all
suppliers to formally request the use of new facilities and
subcontractors. Suppliers, sub-suppliers and sucontractors
must not use any form of home working arrangement for the
manufacturing of our products.

ANTI-CORRUPTION/ANTI-BRIBERY
Suppliers must comply with all applicable anti-corruption and
anti-bribery laws, rules and regulations.

ENGLISH – UPDATED 2021

35 IPS Supplier Compliance Guidebook

©2022 Victoria’s Secret & Co .