Torrid Vendor & Business Partner Code of Conduct
Torrid Holdings Inc. and its subsidiaries including, but not limited to, Torrid LLC (collectively “Torrid”) believes that the workers who produce Torrid’s merchandise should be treated fairly and with dignity and respect. To protect workers and ensure Torrid customers have confidence in these standards, this Vendor & Business Partner Code of Conduct (“Code of Conduct”) is aligned with internationally recognized principles as outlined in the International Labour Organization’s (ILO) Core Conventions, the United Nations Universal Declaration of Human Rights, and the United Nation’s Guiding Principles on Business and Human Rights.
Compliance with the terms of this Code of Conduct is expected and required of all business partners in our supply chain, including, but not limited to, vendors, suppliers, contractors, sub-suppliers, agents, factories, and farms. Torrid requires its vendors to cascade this Code of Conduct to all factories and contractors involved in producing or sourcing products for Torrid. This Code of Conduct must be posted prominently in the workplace in English and in the native languages of all employees and management. Standards equally apply to permanent, temporary and agency workers, as well as salaried, hourly paid, part-time, night and migrant workers. This Code of Conduct is meant to augment, not replace, applicable laws.
We expect all business partners involved in production for Torrid to comply with the requirements of this Code of Conduct as outlined below:
Forced Labor/Human Trafficking. Torrid strictly prohibits the use of forced labor, including bonded, indentured and involuntary prison or slave labor, as defined in the ILO Forced Labor Convention (No. 29), the Abolition of Forced Labor Convention (No. 105), and the California Transparency in Supply Chains Act (S.B. 657). Workers must work voluntarily, be informed of their employment terms and conditions in advance without misrepresentation, and be allowed to terminate employment at any time upon reasonable notice. Fees and costs associated with recruitment and obtaining employment must not be paid by workers. Withholding personal documentation or any other restriction of employees’ free movement is prohibited. Torrid expects that no entity supplying labor to Torrid, shall engage in or support human trafficking.
Child Labor. Business partners must not employ any workers younger than 15, or below the local minimum legal working age or the age for completing compulsory education, whichever is higher. Juvenile workers (ages 15-17) must not be allowed to perform hazardous work, work overtime, or work night shifts. Suppliers must have verification processes in place to ensure workers’ age.
Harassment or Abuse. Torrid expects all workers to be treated with respect and dignity. The workplace must be free from all threats or harassment, including physical, sexual, psychological or verbal harassment or abuse. The use of corporal punishment of any kind or the use of fines or wage garnishment as a punishment to workers is prohibited.
Nondiscrimination. Workers may not be discriminated against based on gender, gender identity or expression, race, religion, age, disability, sexual orientation, nationality, political opinion, social or ethnic origin, or any other protected class under relevant local laws, at any stage of the employment relationship.
Health and Safety. Business partners must provide workers with a safe, healthy, and clean work environment and prevent accidents and health injuries arising out of, or linked to, the course of work. Worksites must be structurally sound and meet fire, electrical, chemical, and other relevant safety standards. Workers must have access to clean washrooms, personal protective equipment (as applicable), potable drinking water, and break areas that are separate from the workspace. Suppliers must provide appropriate services and accommodation to workers in connection with pregnancy, nursing, and childcare as designated by applicable laws in the jurisdiction. Where provided, housing must be clean, safe, and meet the basic needs of workers, with appropriate fire, safety and first aid equipment and adequate privacy and security.
Wages. Wages paid to workers, including overtime pay, must meet or exceed those required by local law and industry standards, whichever is higher. Workers must be paid directly, in a timely manner, and have full access to pay slips which include a wage calculation for each pay period. Any overtime work must be voluntary and compensated for at a premium rate, as required by law. Torrid encourages its suppliers to pay workers a living wage.
Working Hours. Torrid requires all its business partners to follow all relevant local and national laws regarding working hours, overtime, and time off. Normal working hours, including overtime, should never exceed 60 hours per week, or the local legal limit, whichever is less. Workers must be able to refuse overtime work without threat of penalty. Workers should have reasonable rest periods within the workday and at least one rest day in every seven-day period.
Freedom of Association and Collective Bargaining. Business partners must recognize and respect the right of employees to associate, organize and bargain collectively without penalties, retaliation or interference.
Wages and Benefits. Employers must demonstrate recognition that sufficient wages are essential to meeting their employees' basic needs. Accordingly, employers shall pay employees at least the minimum wage required by local law and shall provide all legally mandated benefits.
Protection of the Environment. Business partners must comply with all applicable environmental laws and regulations and adopt measures to reduce the impact of their operations on the environment. This includes, but is not limited to, hazardous materials, air emissions, waste and wastewater discharge, and chemical use and management. This includes the manufacture, transportation, storage, disposal, and release to the environment of such materials.
Monitoring and Transparency. Torrid requires all business partners to permit Torrid and its designated agents (including third parties) to conduct periodic announced and unannounced visits to worksites and facilities of contractors to assess compliance with the social and environmental standards, via on-site audits or other forms of assessments. Written records, including production and CCTV records, must be maintained on site and in accordance with applicable laws, and in no case fewer than five (5) years. These include, but are not limited to, reviews of books and records relating to employment matters such as records of worker wage calculations and payments and hours worked (as noted above), as well as records related to worker disciplinary actions, hiring and termination of employment, and income tax withholding, where applicable. This also includes private interviews with employees.
Subcontracting. Business partners must seek Torrid’s prior written approval before engaging any subcontractor. Subcontractors must agree to comply with this Code of Conduct. Home work may not be used.
Ethical Business Practices. Torrid’s business partners must conduct their operations with honesty and transparency. Partners must fully comply with the laws of their respective countries and with the U.S. Foreign Corrupt Practices Act. Business partners must refrain from engaging in any conduct that may appear improper or result in a conflict of interest. Torrid’s business partners must not directly or indirectly offer or provide money or anything else of value to any person in order to gain an advantage in connection with Torrid business. This includes offering anything of value to unduly influence a third-party product testing body, receive advantageous terms for business deals, or affect the work or findings of a third-party or in-house auditor.
Worker Grievance Reporting and Anti-Retaliation. Torrid requires that all business partners provide a mechanism through which workers can report concerns or grievances without fear of retaliation or harassment. The mechanism should be made known to all workers at the worksite and should be available in the local language(s), including the languages of any migrant workers.
To Report Violations
Torrid LLC
Torridlegal@torrid.com
Attn. Chief Legal Officer
18501 E. San Jose Ave.
City of Industry, CA 91748
