Supplier Selection. In selecting suppliers, JCPenney attempts to identify reputable companies that are committed to compliance with legal requirements relevant to the conduct of their business.

Legal Requirements. JCPenney requires of its supplier strict compliance with all contract provisions, as well as all applicable laws and regulations, including those of the United states and those of the countries of manufacture and exportation.

Country-of-Origin Labeling. JCPenney will not knowingly allow the importation into the United States of merchandise that does not have accurate country-of-origin labeling.

Prison Labor. JCPenney will not knowingly allow the importation into the United States of merchandise manufactured with convict labor, forced labor or indentured labor.

Child Labor. JCPenney will not knowingly allow the importation into the United States of merchandise manufactured with illegal child labor.

Manufacturer's Certificate. To emphasize its insistence on accurate country-of -origin labeling and its particular abhorrence of the use of prison labor and illegal child labor, JCPenney requires that its foreign suppliers and its U.S. suppliers of imported merchandise, for each shipment of foreign-produced merchandise, obtain a manufacturer's certificate that the merchandise was manufactured at a specified factory, identified by name, location and country, and the neither convict labor, forced labor or indentured labor, nor illegal child labor, was employed in the manufacture of the merchandise.

Factory Visits. On visits to foreign factories, for any purpose, JCPenney associates and buying agents have been asked to be watchful for the apparent use of prison or forced labor, or illegal child labor, or indication of inaccurate country-of-origin labeling, to take immediate responsive action when necessary and to report questionable conduct in these areas to their management for follow-up and, when appropriate, corrective action.

Corrective Action. If it is determined that a foreign factory utilized by a supplier for the manufacture of merchandise for JCPenney is in violation of these foreign sourcing requirements, JCPenney will take appropriate corrective actions, which may include cancellation of the affected order, prohibiting the supplier's subsequent use of the factory or terminating JCPenney's relationship with the supplier.