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
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.