Business ethics in the textile, clothing and footware (TCF) industries - 8

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SAP 2.60/WP.110

Business ethics in the textile, clothing and footwear (TCF) industries

By Jean-Paul Sajhau

Part 8

The codes of conduct of the major retail networks

The major retail networks are playing an increasingly important role in the TCF sectors and in particular in textiles. With their large number of sales outlets, sometimes established in several countries, they are tending to replace the traditional manufacturers and to have their TCF articles with their own logo manufactured by subcontractors. Since these enterprises generally cater for the mass market, their sourcing policies are extremely diversified although always governed by a search for low production costs. In order to maintain a good public image, without foregoing the possibility of stepping up their trade relations with subcontractors producing in the developing countries, the major retail networks have become aware of the importance of adopting a responsible ethical behaviour. They have thus adopted codes of conduct similar to those of their counterparts in the manufacturing sector. We have chosen to highlight four of the most developed of these codes: those of Wal-Mart, J.C. Penney, Sears Roebuck and Company and Woolworth.

Wal-Mart, which recently experienced some difficulties of an ethical nature in the Kathie Lee Gifford affair attributes its continued commercial success since its establishment in 1962 to the respect of three principles which form the basis of its business ethics. These principles are: to provide value and service to its customers by offering quality merchandise at low prices; corporate dedication to a partnership between employees, ownership and management; a commitment to the United States (reflected in the "Buy American commitment" campaign in which Wal-Mart undertakes to sell as far as possible products manufactured in the United States) and the communities in which its stores and distribution centres are located. In order to develop these values within the context of globalization, in 1993 Wal-Mart established a detailed code of conduct in the form of Standards for Vendor Partners, in particular those located outside the United States territory. The code is summarized below. Each business partner is required to sign a contract accepting the standards contained in the code.

Table VII. Wal-Mart -- Code of conduct for suppliers and subcontractors

Keywords Standards for Vendor Partners

Human rights Non-derogation of basic human rights.

Child labour Prohibited.
Obligatory reference to:
-- national legislation; and
-- Wal-Mart definition: children are defined as persons:
-- under the age of 15;
-- under the compulsory schooling age of the country.
Wal-Mart supports apprenticeship education programmes for young persons.

Forced or prison labour Prohibited.

Non-discrimination No discrimination on the basis of race, colour, national origin, gender, religion, disability, sexual orientation or political opinion in recruitment.

Conditions of work The minimum Wal-Mart standards are:
-- adequate medical services;
-- emergency exits;
-- safety equipment;
-- well-lit workstations;
-- clean rest-rooms;
-- adequate living quarters where necessary;
-- prohibition of any mental or physical disciplinary practices.

Hours of work and overtime -- In accordance with national legislation.
-- In accordance with local industry standards if higher.
-- Maximum of 60 hours a week plus one day of leave: annual leave.

Remuneration/wages -- In accordance with national legislation.
-- In accordance with prevailing industrial standards if higher.

Legal requirements -- For all activities compliance with national legislation is the minimum standard.
-- Preference given to trade partners respecting prevailing local industry standards.
-- United States legislation is applicable concerning:
-- import requirements into the United States;
-- the protection of intellectual property rights;
-- indication of the country of origin;
-- transport of the merchandise;
-- information on the merchandise transported.

Environment In accordance with the principles of the three "Rs": reduce, reuse and recycle.

Application -- Wal-Mart or a third party appointed by Wal-Mart will take concrete measures to implement and monitor its standards. The plants of business partners are inspected four times a year.
-- Wal-Mart has established a certificate of compliance with its ethical standards which suppliers/subcontractors must obtain to do business with Wal-Mart (the Wal-Mart vendor partner inspection and certification form).

Sanctions in the event of violation Termination of any business relationship between Wal-Mart and a trade partner which fails to respect the code.

The case of Sears, Roebuck and Company (SR) deserves special attention. This major retail group has, in its search for supply sources at the lowest cost, established a number of trade relations with China. Given the assumptions about the non-respect of human rights which affect this country, SR believed that it would be desirable to create a specific code of conduct concerning forced labour which would be applicable to its Chinese partners. Thus the ethical approach of SR is characterized by the juxtaposition of two codes of conduct, a set of Import-Buying Policy and Procedures, along with an additional code on forced labour applicable to China. These two codes are summarized below.

Table VIII. Sears, Roebuck and Company -- Codes of conduct

Keywords
Import-Buying Policy and Procedures
Policy on Goods Made by Forced Labour in China

Basic principles
Strict adherence to local laws governing working conditions and production methods and to applicable United States laws (for United States trade partners).
Prohibition of forced or convict labour.

-- Conditions of work
-- Child labour
-- Wages

In accordance with local legislation or United States legislation (for United States subcontractors).

Forced labour (legal requirements)

Compliance with United States legislation concerning the import of merchandise manufactured on the basis of forced labour.

Application
Contractual clauses

-- Reference to the code in all international purchasing agreements.

-- Inclusion of a clause in all contracts with Chinese subcontractors concerning the non-use of forced labour.

Inspection
-- Periodical visits to plants abroad by foreign buying office personnel.
-- Carrying out of unannounced inspections of the plants of Chinese subcontractors.

Reporting obligation
-- Reporting of any violation of national or United States law to the competent authority.
-- Reporting of violations to the United States Customs Service.

Communication
-- Distribution of a copy of the code to all Sears' employees and its trade partners.
-- Copies of the Import Buying Policy and Procedures must be supplied to all Sears' subcontractors in China.

Information specific to relations with China

Sears' buying office in Hong Kong, responsible for its activities with China, must:
-- supply a list of all Chinese subcontractors to Sears' trading partners and make this list available to shareholders:
-- draw up a list, which must be as comprehensive as possible, of all Chinese enterprises which use forced labour and to compare it with the above-mentioned list.

Sanctions in the event of deliberate violation
Termination of business relations
with suppliers who do not respect
the code.

Termination of trade relations with any supplier using forced labour.

Table IX. J.C. Penney -- Code of conduct applicable to its business partners

Keywords Foreign sourcing requirements

Child labour Prohibited.

Indentured labour Prohibited.

Forced or prison labour Prohibited.

Legal requirements JCP will seek suppliers who conform to the legislation applicable within the framework of their activities.

Application
-- Factory visits

Carried out by JCP associates and buying agents. The latter are required to report to headquarters any conduct with infringes the code.

-- Country of origin labelling JCP will not knowingly import merchandise which does not bear a label indicating the country in which it has been manufactured.

-- Producer's certificate Any merchandise from a foreign country must be accompanied by a certificate indicating the factory at which it was manufactured.

Sanctions in the event of violations -- Cancellation of orders.
-- Prohibition for suppliers to use subcontractors which do not respect the code.
-- Termination by JCP of any business relationship with the suppliers/subcontractors who do not respect the code.

Table X. Woolworth Corporation -- Code of conduct

Basic principles

Prohibition of:

-- forced labour as well as prison labour;

-- child labour.

Legal requirements

-- Merchandise must be in conformity with United States legislation applicable to imported articles.

Requirement included in Woolworth's standard purchase order.

-- Business partners must respect the national legislation applicable within the framework of their manufacturing and marketing activities.

Application

-- Distribution of the code to all business partners, including United States suppliers selling imported products to Woolworth.

-- Woolworth's buyers and other representatives regularly visit the enterprises of suppliers/subcontractors. Woolworth has established a training programme for officials visiting enterprises abroad to familiarize them with the application of the code of conduct in the context of different national legislations.

-- Before any payment, Woolworth requires the supplier to obtain a certificate of compliance with the application of the code. This requirement has been extended to all foreign subcontractors.

Comparative analysis of the codes of conduct

There is a constant feature in all the different elements which make up these codes: the reference to a variable number of principles concerning human rights at work. It is therefore on this fundamental aspect of the ethical codification of trade relations within the context of globalization that we have focused the first part of the comparative analysis, in relation to fundamental ILO standards. On the basis of the information available (which has not always been very exact), we have then proceeded to a comparison between the different methods for the application of these codes.

References to fundamental ILO standards

Although the codes of the selected enterprises do not make specific reference to ILO Conventions, it is clear that the content of the texts concerning the respect of human rights at work is directly inspired by the pertinent ILO Conventions. This is particularly the case as regards the elements of the codes detailing with child labour, forced labour and the principles of non-discrimination, which appear in many of these texts.

On the other hand, few codes contain specific provisions detailing with freedom of association or the right to organize and collective bargaining. This absence, which is regrettable given the importance of these fundamental rights, can be explained in various ways. First of all, some codes stipulate that trade partners must exercise their activities in accordance with national legislation. In most countries, the right to organize and freedom of association are recognized in the Constitution and stipulated in labour legislation, which moreover establishes the methods of collective bargaining.

However, it is well known that some countries provide for exceptions to these general principles. Free zones in particular have a special legal status which, in some cases, restricts, in a derogation of national legislation, certain trade union freedoms and limits the right to collective bargaining. Since a large number of subcontractors in the apparel and footwear sectors operate in these free zones, the mention, in a code of conduct, of the principles contained in Conventions Nos. 87 and 98 could cause difficulties to both the enterprise placing the orders and the subcontracting enterprise. While from a practical point of view account must be taken of existing constraints, from the strictly social ethics point of view, a different reasoning applies. If all these codes of conduct referred to these Conventions (which have furthermore been broadly ratified) certain restrictive practices would be progressively abandoned, in the same way as child labour has been abandoned in enterprises which produce TCF products for multinationals which control the strict application of their codes of conduct.

There follows a comparative table of references to human rights at work.

Methods of monitoring the application of the codes

In order to be credible, the codes of conduct must be applied in a way which leaves no doubt in the minds of observers outside the enterprise. This means that the application of the codes must be supervised by competent persons specially trained for this purpose and whose integrity cannot be questioned.

As regards the general principles making up the ethics of major multinationals, internal methods of supervision, combined with external sources of pressure, can generally be seen as guaranteeing their application within the parent company. Within the enterprise, the human resources policy established by the personnel department must take account of the ethical policy of the enterprise if it wishes to win the support of staff representatives; those responsible for the different technical departments must be made sensitive to the determination of the enterprise to preserve its image as a responsible employer with, if necessary, the general management intervening to prevent any loss of control or dispute. Outside the enterprise, trade union representatives are vigilant and pressure groups remain active, whether in the form of associations, through the media or as individual consumers.

On the other hand, the effective implementation of the codes of conduct by suppliers and subcontractors is more difficult. Multinational enterprises (producers and distributors) in the TCF sectors make use of a number of intermediaries and subcontractors in a large number of countries, some of which are located far away. The logistics required to ensure the respect of the codes are considerable and few enterprises have the necessary human means. As can be seen from the following table, it would appear, on the basis of the piecemeal information available, that most enterprises entrust their local buying agents and quality control representatives with the task of monitoring respect of the codes of conduct. Unfortunately, in a very large number of cases there is a lack of information on the specific training of these agents in the sphere of labour legislation and, more generally, human rights at work. Furthermore, although some enterprises require their suppliers to sign a document in which they undertake to apply the code of ethics of the enterprises for which they are working, this is a moral undertaking rather than a genuine method of supervision. Frequent use is made in the apparel industry of the practice of multiple subcontracting, whereby an enterprise which receives an order from a multinational enterprise in turn contracts out all or part of the order to other enterprises. In such cases, it becomes extremely difficult to try and control the entire subcontracting chain and the chances of non-respect of the elementary rights of workers increase as use is made of increasingly smaller and less structured enterprises. Attempts, albeit positive, to monitor the application of the codes must therefore be treated with all due caution and inspiration should be sought from the best organized enterprises which have trained their staff accordingly and which, because of their position in a specific market, cannot risk being accused of failing to implement their ethical principles. Recourse to external monitoring of the type introduced by The Gap in El Salvador, although difficult and expensive to implement, could also be an avenue worth exploring.

Table XII. Methods of application of codes of conduct by trade partners

Enterprise
Methods of application
Sanctions in the event of violation

Levi Strauss
In three stages:
1. Terms of engagement evaluation
Evaluation carried out by a Levi Strauss team made up of members of several technical departments -- each team includes one of the 50 inspectors trained by the enterprise in this particular task. A 20-page evaluation document reviews practices in production and working conditions. The assessment is also based on opinions about the enterprise by trade union officials and local associations. Workers are also directly concerned and unannounced visits to enterprises are sometimes carried out.
2. Terms of engagement monitoring
Selected suppliers/subcontractors are subject to periodical inspections (at least once a year; sometimes every three months), the objective of which is to resolve points of difficulty, on a partnership basis, before they become real problems.
3. Training--Sensitivization
The enterprise conducts a policy of permanent training and sensitivization to its ethical criteria. This training is provided in the first instance for inspectors responsible for the application of the code of conduct but it is also available to other employees in the group who, at one level or another, have working relations with external suppliers.

Termination of relations with business partners failing to respect the terms of engagement.

The Gap
Internal methods:
-- The plants of subcontractors are selected and inspected by a representative of the management of The Gap and/or by a commercial representative responsible for purchasing. A plant inspection certificate is issued which is a necessary condition for the payment of merchandise.
-- Business partners must sign a vendor compliance agreement under which they must apply the same subcontractor selection criteria as The Gap. The Gap does not purchase foreign products from importers who have not signed this agreement.
-- The choice of countries with which The Gap has trade relations is approved by a sourcing committee which meets four times a year to update and publish a list of approved countries.
External methods:
An independent monitoring working group set up in cooperation with:
-- The Interfaith Center on Corporate Responsibility
-- Business for Social Responsibility
-- The National Labor Committee
works towards the improvement of the codes and proposes solutions. The initial aim is the improvement of working conditions in the international subcontractor "Mandarin International" in El Salvador.

Termination of trade relations with supplier/subcontractors who do not respect the code of conduct.

Reebok (R)
Internal methods:
-- R carries out supervision in accordance with its charter, in the form of factory inspections. No information is available on the internal structure established for this supervision.
-- R applies its charter for the protection of human rights in the selection of its trade partners and ensures that the latter apply the charter.
-- R seeks partners who provide complete information on the production means used and the conditions of recruitment and work.

No information on trade sanctions in the event of a violation of the code of conduct.

Nike (N)
Internal methods:
-- For each plant, a representative of N is responsible for the day-to-day application of the Memorandum.
-- Obligation for suppliers/subcontractors to retain and to make available to N all documentation concerning ethical criteria contained in the Memorandum.
-- The Memorandum is posted up in all the plants of N's subcontractors.
-- Reference to the code in all international purchasing contracts.
Methods independent of the enterprise:
-- N reserves the right at all times to have an independent monitoring carried out of the plants of suppliers/subcontractors.

In the event of non-respect of the Memorandum, N may insist that the situation is redressed or it may cancel its trade commitments.

Sara Lee
The supervision of the application of the code by subcontractors is entrusted to the purchasing and quality control officials of Sara Lee.
No information on sanctions in the event of violation.

Phillips-van Heusen
No information is available on the internal structure set up for supervising the application of its code.
Termination of trade relations with suppliers/subcontractors who do not respect the code of conduct.

J.C. Penney (JCP)
Internal methods:
-- The inspection of plants of suppliers/subcontractors is carried out by purchasing agents. The agents carrying out these inspections report any failure to respect the code to the general management which takes appropriate measures.
-- JCP does not knowingly import goods which are not accompanied by a manufacturer's certificate indicating the manufacturing plant and certifying that the products have not been made by children or through forced labour. All merchandise must also include a certificate of origin indicating the country of manufacture.

-- Termination of trade relations with subcontractors not respecting the code.
-- Prohibition for any supplier to use the sanctioned subcontractor.

Sears, Roebuck & Co.
Internal methods:
-- Periodical and unannounced visits to the plants of suppliers by the staff of the foreign purchase office.
-- Distribution of a copy of the code to all Sears employees and its business partners.
-- Reference to the code in all international purchasing contracts. In the case of a Chinese enterprise, inclusion in the contract of a clause on forced labour.
-- Reporting to the competent authorities of any violation of national United States legislation.

Termination of trade relations with suppliers/subcontractors who do not respect the code if the violation is deliberate

Wal-Mart (W-M)
Internal enterprise methods:
-- WM or a representative appointed by WM carries out inspections on the application of ethical standards.
-- The plants of subcontractors are inspected four times a year. Plants which comply with the standards receive the Wal-Mart Vendor Partner Inspection and Certification Form.

Termination of trade relations with suppliers/subcontractors who do not respect the code

Woolworth (W)
Internal methods:
-- W agents regularly inspect the plants of foreign subcontractors.
-- Before payment of goods, the supplier/subcontractor must provide a certificate certifying compliance with the code of conduct.
-- W intends to:
-- distribute its code to all suppliers/subcontractors;
-- establish a training programme for buyers and other persons visiting foreign plants to ensure that they understand the code in the context of the applicable local legislation;
-- ensure that the code of conduct is applied by United States importers which supply the company.

No information available on sanctions in the event of violation

Updated by BR. Approved by OdVR. Last update: 28 September 2000.

Keywords	Standards for Vendor Partners
Human rights	Non-derogation of basic human rights.
Child labour	Prohibited. Obligatory reference to: -- national legislation; and -- Wal-Mart definition: children are defined as persons: -- under the age of 15; -- under the compulsory schooling age of the country. Wal-Mart supports apprenticeship education programmes for young persons.
Forced or prison labour	Prohibited.
Non-discrimination	No discrimination on the basis of race, colour, national origin, gender, religion, disability, sexual orientation or political opinion in recruitment.
Conditions of work	The minimum Wal-Mart standards are: -- adequate medical services; -- emergency exits; -- safety equipment; -- well-lit workstations; -- clean rest-rooms; -- adequate living quarters where necessary; -- prohibition of any mental or physical disciplinary practices.
Hours of work and overtime	-- In accordance with national legislation. -- In accordance with local industry standards if higher. -- Maximum of 60 hours a week plus one day of leave: annual leave.
Remuneration/wages	-- In accordance with national legislation. -- In accordance with prevailing industrial standards if higher.
Legal requirements	-- For all activities compliance with national legislation is the minimum standard. -- Preference given to trade partners respecting prevailing local industry standards. -- United States legislation is applicable concerning: -- import requirements into the United States; -- the protection of intellectual property rights; -- indication of the country of origin; -- transport of the merchandise; -- information on the merchandise transported.
Environment	In accordance with the principles of the three "Rs": reduce, reuse and recycle.
Application	-- Wal-Mart or a third party appointed by Wal-Mart will take concrete measures to implement and monitor its standards. The plants of business partners are inspected four times a year. -- Wal-Mart has established a certificate of compliance with its ethical standards which suppliers/subcontractors must obtain to do business with Wal-Mart (the Wal-Mart vendor partner inspection and certification form).
Sanctions in the event of violation	Termination of any business relationship between Wal-Mart and a trade partner which fails to respect the code.

Keywords	Import-Buying Policy and Procedures	Policy on Goods Made by Forced Labour in China
Basic principles	Strict adherence to local laws governing working conditions and production methods and to applicable United States laws (for United States trade partners).	Prohibition of forced or convict labour.
-- Conditions of work -- Child labour -- Wages	In accordance with local legislation or United States legislation (for United States subcontractors).
Forced labour (legal requirements)		Compliance with United States legislation concerning the import of merchandise manufactured on the basis of forced labour.
Application Contractual clauses	-- Reference to the code in all international purchasing agreements.	-- Inclusion of a clause in all contracts with Chinese subcontractors concerning the non-use of forced labour.
Inspection	-- Periodical visits to plants abroad by foreign buying office personnel.	-- Carrying out of unannounced inspections of the plants of Chinese subcontractors.
Reporting obligation	-- Reporting of any violation of national or United States law to the competent authority.	-- Reporting of violations to the United States Customs Service.
Communication	-- Distribution of a copy of the code to all Sears' employees and its trade partners.	-- Copies of the Import Buying Policy and Procedures must be supplied to all Sears' subcontractors in China.
Information specific to relations with China		Sears' buying office in Hong Kong, responsible for its activities with China, must: -- supply a list of all Chinese subcontractors to Sears' trading partners and make this list available to shareholders: -- draw up a list, which must be as comprehensive as possible, of all Chinese enterprises which use forced labour and to compare it with the above-mentioned list.
Sanctions in the event of deliberate violation	Termination of business relations with suppliers who do not respect the code.	Termination of trade relations with any supplier using forced labour.

Keywords	Foreign sourcing requirements
Child labour	Prohibited.
Indentured labour	Prohibited.
Forced or prison labour	Prohibited.
Legal requirements	JCP will seek suppliers who conform to the legislation applicable within the framework of their activities.
Application -- Factory visits	Carried out by JCP associates and buying agents. The latter are required to report to headquarters any conduct with infringes the code.
-- Country of origin labelling	JCP will not knowingly import merchandise which does not bear a label indicating the country in which it has been manufactured.
-- Producer's certificate	Any merchandise from a foreign country must be accompanied by a certificate indicating the factory at which it was manufactured.
Sanctions in the event of violations	-- Cancellation of orders. -- Prohibition for suppliers to use subcontractors which do not respect the code. -- Termination by JCP of any business relationship with the suppliers/subcontractors who do not respect the code.

Enterprise	Methods of application	Sanctions in the event of violation
Levi Strauss	In three stages: 1. Terms of engagement evaluation Evaluation carried out by a Levi Strauss team made up of members of several technical departments -- each team includes one of the 50 inspectors trained by the enterprise in this particular task. A 20-page evaluation document reviews practices in production and working conditions. The assessment is also based on opinions about the enterprise by trade union officials and local associations. Workers are also directly concerned and unannounced visits to enterprises are sometimes carried out. 2. Terms of engagement monitoring Selected suppliers/subcontractors are subject to periodical inspections (at least once a year; sometimes every three months), the objective of which is to resolve points of difficulty, on a partnership basis, before they become real problems. 3. Training--Sensitivization The enterprise conducts a policy of permanent training and sensitivization to its ethical criteria. This training is provided in the first instance for inspectors responsible for the application of the code of conduct but it is also available to other employees in the group who, at one level or another, have working relations with external suppliers.	Termination of relations with business partners failing to respect the terms of engagement.
The Gap	Internal methods: -- The plants of subcontractors are selected and inspected by a representative of the management of The Gap and/or by a commercial representative responsible for purchasing. A plant inspection certificate is issued which is a necessary condition for the payment of merchandise. -- Business partners must sign a vendor compliance agreement under which they must apply the same subcontractor selection criteria as The Gap. The Gap does not purchase foreign products from importers who have not signed this agreement. -- The choice of countries with which The Gap has trade relations is approved by a sourcing committee which meets four times a year to update and publish a list of approved countries. External methods: An independent monitoring working group set up in cooperation with: -- The Interfaith Center on Corporate Responsibility -- Business for Social Responsibility -- The National Labor Committee works towards the improvement of the codes and proposes solutions. The initial aim is the improvement of working conditions in the international subcontractor "Mandarin International" in El Salvador.	Termination of trade relations with supplier/subcontractors who do not respect the code of conduct.
Reebok (R)	Internal methods: -- R carries out supervision in accordance with its charter, in the form of factory inspections. No information is available on the internal structure established for this supervision. -- R applies its charter for the protection of human rights in the selection of its trade partners and ensures that the latter apply the charter. -- R seeks partners who provide complete information on the production means used and the conditions of recruitment and work.	No information on trade sanctions in the event of a violation of the code of conduct.
Nike (N)	Internal methods: -- For each plant, a representative of N is responsible for the day-to-day application of the Memorandum. -- Obligation for suppliers/subcontractors to retain and to make available to N all documentation concerning ethical criteria contained in the Memorandum. -- The Memorandum is posted up in all the plants of N's subcontractors. -- Reference to the code in all international purchasing contracts. Methods independent of the enterprise: -- N reserves the right at all times to have an independent monitoring carried out of the plants of suppliers/subcontractors.	In the event of non-respect of the Memorandum, N may insist that the situation is redressed or it may cancel its trade commitments.
Sara Lee	The supervision of the application of the code by subcontractors is entrusted to the purchasing and quality control officials of Sara Lee.	No information on sanctions in the event of violation.
Phillips-van Heusen	No information is available on the internal structure set up for supervising the application of its code.	Termination of trade relations with suppliers/subcontractors who do not respect the code of conduct.
J.C. Penney (JCP)	Internal methods: -- The inspection of plants of suppliers/subcontractors is carried out by purchasing agents. The agents carrying out these inspections report any failure to respect the code to the general management which takes appropriate measures. -- JCP does not knowingly import goods which are not accompanied by a manufacturer's certificate indicating the manufacturing plant and certifying that the products have not been made by children or through forced labour. All merchandise must also include a certificate of origin indicating the country of manufacture.	-- Termination of trade relations with subcontractors not respecting the code. -- Prohibition for any supplier to use the sanctioned subcontractor.
Sears, Roebuck & Co.	Internal methods: -- Periodical and unannounced visits to the plants of suppliers by the staff of the foreign purchase office. -- Distribution of a copy of the code to all Sears employees and its business partners. -- Reference to the code in all international purchasing contracts. In the case of a Chinese enterprise, inclusion in the contract of a clause on forced labour. -- Reporting to the competent authorities of any violation of national United States legislation.	Termination of trade relations with suppliers/subcontractors who do not respect the code if the violation is deliberate
Wal-Mart (W-M)	Internal enterprise methods: -- WM or a representative appointed by WM carries out inspections on the application of ethical standards. -- The plants of subcontractors are inspected four times a year. Plants which comply with the standards receive the Wal-Mart Vendor Partner Inspection and Certification Form.	Termination of trade relations with suppliers/subcontractors who do not respect the code
Woolworth (W)	Internal methods: -- W agents regularly inspect the plants of foreign subcontractors. -- Before payment of goods, the supplier/subcontractor must provide a certificate certifying compliance with the code of conduct. -- W intends to: -- distribute its code to all suppliers/subcontractors; -- establish a training programme for buyers and other persons visiting foreign plants to ensure that they understand the code in the context of the applicable local legislation; -- ensure that the code of conduct is applied by United States importers which supply the company.	No information available on sanctions in the event of violation