Commitment & Governance
At Victoria’s Secret & Co., we have a long history of maintaining rigorous labor standards for our suppliers, and we believe we can continue to play an important role in empowering workers and improving working conditions across our supply chain.
We are committed to providing superior quality merchandise and services to customers. We strongly believe the quality of our merchandise begins with the treatment of the people who create our products.
Victoria’s Secret & Co. sources all its product lines – lingerie and apparel, accessories and beauty products from more than 300 factories around the world — the vast majority of which are located in Vietnam, United States, Sri Lanka, Indonesia and China.
Our top 10 suppliers represent more than 80 percent of our production volume; we have worked with the majority of these partners for 25 years or more. We have traced 100 percent of our Tier 1 and Tier 2 supply chain for our lingerie and apparel products. We have also begun the work of tracing our Tier 3 suppliers.
Our definition of tiers is aligned with the Sustainable Apparel Coalition and Science Based Targets initiative, as follows:
|TIER 1||Finished goods manufacturing|
|TIER 2||Facilities that supply Tier 1 facilities with fabrics, trims or components
Facilities that provide processing services (e.g., embroidery, printing, laundries)
|TIER 3||Raw material processing|
|TIER 4||Raw material extraction|
Victoria’s Secret & Co. is fully committed to ensuring our products are ethically sourced. This commitment starts with our leaders and cascades throughout our organization. As part of that commitment, all associates are annually required to review and acknowledge our Associate Code of Conduct. Based on our values, this Code defines behaviors that are acceptable and those that are not.
We hold ourselves and each other accountable to our values in all that we do. In that spirit, we strongly believe that the quality of our merchandise begins with the treatment of the people who create our products. Victoria’s Secret & Co. only works with suppliers that share our commitment to ethical and responsible business practices. This commitment is embedded in the many measures by which we evaluate supplier partners and has been part of our comprehensive and proprietary approach to how we do business for decades.
Suppliers are selected based on their ability and commitment to meet our safety and quality standards as well as follow our strict ethical, labor and environmental standards.
Protecting Human Rights
Victoria’s Secret & Co. (VS&Co) is committed to respecting human rights. Our approach and activities to respect human rights is based on the principles as defined by the Universal Declaration of Human Rights (UDHR), which recognizes that “all human beings are born free and equal in dignity and rights.”
Our actions – both in our local communities and across our company – are guided by fostering inclusion, creating equity, acting with integrity and behaving ethically. VS&Co seeks to mitigate adverse human rights impacts as it relates to our associates, business partners, suppliers and customers. We are committed to operate in alignment with the principles outlined in the UN Global Compact (UNGC), the UN Guiding Principles on Business and Human Rights, the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work, the International Bill of Human Rights and the Organisation for Economic Co-operation (OECD) Guidelines for Multinational Enterprises.
Sourcing Risk Council
Victoria’s Secret & Co. has a Sourcing Risk Council, comprised of senior executives from company divisions and functions, that meets quarterly to discuss core business, sourcing, purchasing practices and approve policies as required. Executive representation includes leaders and stakeholders with expertise in the following areas:
- Company Affairs
- Compliance and Ethics
- Global Trade Compliance
- Government Affairs
- Independent Production Services (IPS)*
- Production and Sourcing
- Regulatory and Quality Assurance
The Council assesses current risks, including geopolitical, social compliance and associated supply risks and sets policies related to responsible sourcing. The Sourcing Risk Council operates under the guidance and oversight of the Board of Directors’ Audit Committee. The Chair of the Sourcing Risk Council reports to the Audit Committee on a regular basis, and the Audit Committee updates the Board of Directors.
Given the complex nature of our supply chain, we have adopted stringent measures to ensure workers in our suppliers’ facilities are treated fairly and ethically. We require our suppliers to adhere to our Supplier Code of Conduct (Code) and detailed Supplier Compliance Guidebook (Guidebook), which we update regularly. We conduct audits at supplier facilities for compliance with our Code. The Code clearly outlines our standards against forced or child labor, corruption, bribery, discrimination, harassment and abuse, unauthorized subcontracting and more. The Code must be posted in common areas by all our factories in the factory worker’s preferred language.
Victoria’s Secret & Co. suppliers are required to sign a Master Sourcing Agreement (MSA) that explicitly states that the supplier and their factories will comply with all applicable laws and Victoria’s Secret & Co. policies, including each of the policies and guidance listed below.
- Supplier Code of Conduct
To ensure that our expectations are clear, our standards are specifically outlined in our Supplier Code of Conduct.
- Sourcing Country Policy
Victoria’s Secret & Co. will not source product from any country prohibited or restricted by law as sanctioned by the Office of Foreign Assets Control of the U.S. Department of the Treasury. In addition, some countries with potential geopolitical or social risks may pose a threat to our supply chain and, as a result, require pre-approval from Victoria’s Secret & Co. executive leadership with compliance oversight. Any associate who violates this policy is subject to disciplinary action, including, but not limited to, termination of employment.
- Foreign Migrant Worker Policy
The Victoria’s Secret & Co. Supplier Code of Conduct clearly states that prison, indentured, bonded, involuntary or slave labor or labor obtained through human trafficking shall not be used. Experts report that foreign migrant workers who travel across country borders to obtain employment are most at risk for human trafficking and forced labor and, therefore, we have established a Foreign Migrant Worker Policy to ensure that we reduce the risk of human trafficking or forced labor within our supply chain. In order to use a factory that employs foreign migrant workers, the sourcing team must obtain executive approval which can only be given if the factory receives positive results on a specialized audit developed in accordance with the International Labour Organization’s handbook on Combating Forced Labour. Factories that employ foreign migrant workers are closely monitored to ensure there are no forced labor violations and that workers have freedom of movement and are treated in accordance with the law. Any associate who contracts a factory that uses foreign migrant workers without executive review and approval is subject to disciplinary action, including, but not limited to, termination of employment.
- Cotton Policy
Victoria’s Secret & Co. Is committed to ensuring the traceability of cotton in our supply chain, and we align ourselves with suppliers who share this commitment.
We updated our Cotton Policy (Policy) in January 2022, to require all cotton fiber, cotton yarn, cotton fabric and cotton products be spun in or originate from one or more of the approved countries listed on the Policy.
We expect our suppliers to undertake appropriate due diligence to confirm compliance with this Policy. Suppliers are required to retain all documentation for the origin of raw material, processing and manufacturing to ensure transparency and traceability of our cotton supply chain. Independent Production Services (IPS) will conduct chain-of-custody audits to verify cotton fiber, cotton yarn, cotton fabric and cotton product originated from or was spun in one or more of the approved countries on our list. To view the full policy, click here.
- Conflict Minerals Policy
Victoria’s Secret & Co. prohibits its suppliers from using conflict minerals which may directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo and its nine adjoining countries in accordance with the Dodd-Frank Act’s Conflict Minerals Provisions. We periodically survey suppliers to conduct reasonable country of origin inquiries regarding conflict minerals.
According to U.S. federal law (Dodd-Frank Act, Section 1502), all U.S. public companies, including VS&Co, are required to perform a country of origin (COO) investigation for any 3TG (tin, tungsten, tantalum, and gold) in their products, including whether sourcing of those metals may have benefited non-state armed groups in the Democratic Republic of Congo (DRC) or its nine adjoining countries (collectively known as the “DRC+9”). We require our suppliers to retain records related to conflict minerals supply chain inquiries for a minimum of 5 years and 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. Form SD and Conflict Minerals Reports previously filed by Victoria’s Secret & Co. can be viewed as part of our SEC filings.
- Independent Production Services (IPS)* Compliance Guidebook
IPS, a compliance function within Victoria’s Secret & Co. publishes a Compliance Guidebook (Guidebook) annually and distributes it to all of our suppliers worldwide. The Guidebook is a collection of policies and standards with which our suppliers are expected and legally obligated to comply. The Guidebook provides additional clarification to supplier partners and their factories regarding a broad range of compliance standards and requirements that we are committed to as an enterprise and expect our suppliers to follow. Included in the Guidebook are the Victoria’s Secret & Co.’s Supplier Code of Conduct, compliance standards related to forced labor and human trafficking, the cotton policy and the conflict minerals policy, among others.
The Guidebook is made available to all suppliers and associates involved in the production and purchasing process and outlines the requirements each must meet to work with Victoria’s Secret & Co.
*Independent Production Services (IPS) is a compliance function within Victoria’s Secret & Co. for over 25 years that works with suppliers to ensure goods are sourced from factories that meet or exceed Victoria’s Secret & Co.’s compliance standards. IPS is responsible for monitoring and enforcement of Victoria’s Secret & Co.‘s social compliance program and has been supporting global compliance for more than two decades, enabling improvement in working conditions, supply chain security, trade compliance and brand protection in our supply chain through monitoring, remediation, capacity building and training.