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KOHL'S factory inspection

Product introduction：一、KOHL'S Business Partner Contract TermsKOHL'S promises to always adhere to regulations and humanitarianism in all business activities. All suppliers and contract companies (business partners) of KOHL'S must also fully comply with relevant national and local regulations in their production operations and commercial activities. All business partners must maintain a high level of business ethics and respect human rights. If the requirements of industrial standards exceed local regulatory requirements, the higher standard should prevail. Our company's standards are summarized as follows:Employee Employment Regulations: KOHL'S only engages in business dealings with business partners who respect the legitimate rights and interests of employees. Employees of these business partners are able to work voluntarily, enjoy equal treatment, receive reasonable compensation, and do not take risks in activities that may harm their health. They have freedom of association and are not subject to any form of exploitation or fraud. Salary and welfare benefits: KOHL'S business partners must pay reasonable wages to employees and provide corresponding welfare benefits in accordance with legal regulations. The standards of wages and welfare benefits shall not be lower than (a) the standards stipulated by relevant laws, and (b) the general standards of similar local production units. In addition to the compensation paid for employees' normal working hours, compensation should also be provided for their overtime work, and the amount of overtime wages should be at the rate prescribed by law. In countries without such regulations, overtime wages should be at least equal to the normal wages of workers. KOHL'S believes that wages are extremely important for meeting the basic living needs of workers. KOHL'S will seek and prioritize business partners who promise to continuously improve employee wages and benefits. Working hours and rest days: Business partners should limit employees' normal working hours and overtime hours to within the scope specified by law for relevant industries. Business partners must arrange reasonable and fixed rest periods for workers, ensuring that employees take at least one day off every seven days. Any working hours exceeding the local normal working hours must be compensated in accordance with relevant laws and regulations. Child labor: The use of child labor is strictly prohibited. Business partners must fully comply with regulations regarding work restrictions for minors, especially regarding their working hours, wages, minimum education level, working conditions, etc. The term 'minors' referred to in child labor refers to anyone under the age of 15 (or 14 if permitted by the laws of that country). In addition, if the required age for completing compulsory education in the country is greater than 15 years old, any person below the age for completing compulsory education is also considered a minor, and KOHL'S will not engage in business with business partners who use or agree to use child labor. Prisoner labor and forced labor: During the entire process of manufacturing and assembling products provided by KOHL'S, there must be no use of contracts or as collateral to force others to work. Prisoners or forced labor shall not be used for production. The so-called forced labor refers to the labor or services that workers are forced to provide involuntarily due to the threat of punishment if they do not engage in the labor. Discrimination: Hiring employees (including recruitment, salary, benefits, promotion, dismissal, and retirement) should be based on the ability of the worker, not on their personal characteristics. When recruiting workers, consideration should be given to their ability to perform the job, rather than their gender, age, sexual orientation, disability, racial characteristics, cultural or religious beliefs, and other characteristics. If business partners discriminate against certain individuals based on their gender, age, sexual orientation, physical disability, racial characteristics, cultural or religious beliefs, then KOHL'S will not develop business with these companies. Freedom of association: Workers must have the right to freely choose to join social organizations. Business partners must recognize and respect workers' right to freedom of association and collective bargaining. Workers who peacefully exercise their legal rights to join or refuse to join a certain social group shall not be threatened or harassed. Form of disciplinary action: The dignity of every worker should be respected. No worker shall be subjected to corporal punishment. Workers should be guaranteed to be physically and psychologically inviolable. Workers should not be subjected to verbal harassment, sexual harassment, or other forms of physical or mental oppression, abuse, or threat. Business partners are not allowed to use or allow the use of fines as a form of disciplinary action. Women's rights: All business partners should ensure that their female employees are treated equally in all aspects of employment. Pregnancy testing cannot be used as a condition for hiring or retaining workers. When pregnancy testing is required, workers should also be allowed to make a completely voluntary decision on whether to conduct the test. Workers should not engage in harmful activities that may disrupt fertility. Business partners cannot force workers to take contraceptive measures. Industrial health and safety: Business partners should provide a healthy, hygienic, and safe working environment for their work, in order to prevent accidents and work-related injuries among workers during the process of production facilities. Business partners must fully comply with mandatory standards related to workplace health and safety. If business partners provide residential facilities for employees, they must ensure that these residential facilities comply with mandatory health and safety standards stipulated by relevant laws. Professional ethics standards: KOHL'S adheres to its own professional ethics standards in the business field. KOHL'S also needs to ensure that its business partners adhere to appropriate professional ethics in their business activities. KOHL'S strictly prohibits bribery, kickbacks, or other forms of illegal or improper payments to any individual or entity for the purpose of obtaining or maintaining business. Supervision and Compliance: KOHL'S believes that proactive supervision should be taken to ensure that business partners comply with the terms of the contract and purchase order signed by KOHL'S. This can include screening business partners, as well as dispatching KOHL'S representatives to conduct on-site inspections of factories on a regular or irregular basis, with or without prior notice, to ensure compliance with the terms of the contract. KOHL'S requires its inspectors, contacts, and representatives to pay attention to violations of KOHL'S' Contract Terms' during inspections of factories or production facilities, and report any doubts to management. Management will follow up on the situation and propose rectification requirements. If you believe that these contract terms have not been upheld, or if you have any questions, please inform the representative of KOHL'S. Your identity will be kept confidential. 二、Precautions for Kohl's factory inspectionIntroduction to Kohl's CompanyKohl's is a well-known professional department store for families in the United States. Kohl's was founded by the Kohl family in Milwaukee in 1962 and has grown rapidly since then. Now, Kohl's stores are located in 40 states in the United States, and the number of stores is increasing every year.Kohl's sales target is mainly young mothers with young children at home, and most of its stores are located in urban areas where families live together, emphasizing shopping convenience and value for money. Kohl's department store has a children's, youth, women's, and men's product department, with a product range of men's, women's, youth, children's, bags, toys, shoes and boots, jewelry, beauty products, home clothing, dining utensils, furniture decoration, hygiene products, travel equipment, and electronic products.Kohl's factory inspectionKohl's factory inspection refers to the audit conducted by American Kohl's department store on its global suppliers, including human rights, quality, and anti-terrorism inspections.Kohl's factory inspection needs to review three projects: human rights, quality, and counter-terrorism. Quality accounts for a large proportion. KOHL's human rights inspection is generally required for every factory, and the audit results have a significant impact on orders. If there are serious problems or if several factory inspections fail, the order cannot be placed or the shipment will be affected. Quality and anti-terrorism inspections are not required for every factory, but are arranged according to customer requirements.The standard Code of Conduct used by KOHL'S human rights inspection is one of the COC inspection standards, officially known as the KOHL'S Business Partner Cooperation Terms. KOHL's human rights inspection factory has similar requirements to other American clients' human rights inspection factories, but it has its own unique features.Kohl's factory inspection precautions1. Kohl's factory inspection has a special requirement for doors. The doors inside the factory must open inward. If the factory installs movable doors or opens outward, they must be changed to open inward, otherwise Kohl's cannot accept it. The requirement for safety exits is that safety products cannot be on the same wall, can be adjacent or opposite. However, if adjacent, the straight distance between the two doors cannot be less than 5m. Within a warehouse area of 300 square meters, there must be a safety exit.2. Kohl's factory inspection requires a 100% social insurance standard in terms of social security. Some factories may claim that we have met the local minimum social security standard, and they have also obtained social security approval documents from the social security bureau. However, Kohl's does not recognize it here. 100% insurance coverage is a mandatory standard, and if it cannot be met, a qualified factory inspection report cannot be obtained.3. Kohl's factory inspection adopts the same zero tolerance standard as ICTI audit. What is zero tolerance? Only when there is no issue with the factory inspection report can it be considered approved. If there are some minor on-site issues in the factory inspection of general customers, such as incorrect position of fire extinguishers or the absence of needle blocking plates in a certain sewing machine, they can be rectified according to the photos. Just send pictures of the rectified appearance, Kohl's factory inspection is not allowed, and must be reviewed according to the on-site inspection by the auditor.4. Kohl's factory inspection date is often consulted by factories, and they often ask if the Kohl's factory inspection time is not notified and is it a surprise audit? In fact, the initial review time of Kohl's is notified, but the review and annual review time are not notified, which is a surprise review and requires the factory to be prepared at any time.Benefits of passing Kohl's factory inspectionThe current international industry not only requires enterprises to provide high-quality and affordable products, but also considers the impact of their business activities and policies on society and morality. Enterprises can prove to be very responsible in terms of social responsibility, ethics, and quality, and will gain a competitive advantage. At the same time, give stronger confidence to relevant parties of the enterprise, such as customers, investors, and consumers. We often say that only through factory inspection can enterprises obtain admission tickets to enter the market competition.三、Precautions for KOHL'S Factory Inspection Code of Conduct In accordance with Kohl’s Department Stores Terms of Engagement for Business Partners, Bureau Veritas Consumer Products Services, Pvt., Ltd. monitored Shantou Shi Chuang Gao Wan Ju You Xian Gong Si on December 16, 2011. This letter is to inform you that extremely serious violations of Kohl’s Terms of Engagement were found during the monitoring visit and reported to Kohl’s. Although any violation is deemed unacceptable, the violations in bold print require immediate corrective action. Health and Safety1. It was noted that the following exit doors were sliding:- 1 out of 2 exit doors in the assembly section on the 4/F of production building A;- 1 out of 2 exit doors in the assembly product section on the 3/F of production building A;- 1 out of 2 exit doors in the spray painting section on the 4/F of production building B;- 2 out of 2 exit doors in the mould section on the 1/F of production building B;- 3 out of 3 exit doors in the injection section of production building C. In accordance with Article 7.4.12 of the Code for Design of Building Fire Protection and Prevention (GB: 50016-2006): Evacuation doors in a building should be according to the followings:- Evacuation doors of civil buildings and factories should open in the direction of traffic. The opening direction is not restricted for a room (except for workshop type A and B) with no more than 60 occupants and average number of passengers for each evacuation door does not exceed 30;- Evacuation doors of civil buildings and factories should install outward door, double slide door, rolling door, flap door and revolving door are prohibited;- Evacuation doors of warehouse should be outward door opening in the direction of traffic. The slide door or rolling door may be installed in side wall of the first floor of warehouse. But slide door or rolling door should not used in type A and B warehouse;- Evacuation doors with access control in crowded concourses, or gate of inhabitancy buildings with locking devices, should be constructed to ensure easy opening from inside without keys or any other tools in case of fire; and marks and usage guides should be posted in prominent places. In accordance with Kohl’s Terms of Engagement: Kohl's will only utilize Business Partners who provide workers with a clean, safe and healthful work environment designated to prevent accidents and injuries arising out of, or occurring while in the course of work, or as a result of the operation of a Business Partner’s facility. All Business Partners must comply with all applicable, legally mandated standards for workplace health and safety. Kohl’s requires management to immediately replace all sliding doors with doors that open in the direction of evacuation or install a permanent device to ensure that the doors remain open during all operating hours of the factory. 2. It was noted that 1 out of 2 exit doors in the painting section on the 4/F of the production building B opened inward. In accordance with Article 7.4.12 of the Code for Design of Building Fire Protection and Prevention (GB: 50016-2006): Evacuation doors in a building should be according to the followings:- Evacuation doors of civil buildings and factories should open in the direction of traffic. The opening direction is not restricted for a room (except for workshop type A and B) with no more than 60 occupants and average number of passengers for each evacuation door does not exceed 30;- Evacuation doors of civil buildings and factories should install outward door, double slide door, rolling door, flap door and revolving door are prohibited;- Evacuation doors of warehouse should be outward door opening in the direction of traffic. The slide door or rolling door may be installed in side wall of the first floor of warehouse. But slide door or rolling door should not used in type A and B warehouse;- Evacuation doors with access control in crowded concourses, or gate of inhabitancy buildings with locking devices, should be constructed to ensure easy opening from inside without keys or any other tools in case of fire; and marks and usage guides should be posted in prominent places. Kohl’s requires management to ensure all exit doors open in the direction of evacuation. If management cannot make the doors open outward, the next best solution is to completely remove the doors from the hinges, if feasible. If this is not feasible, then a locking device must be used to keep them open during working hours. The device that is installed must be a permanent locking device to ensure the doors remain open during operating hours. 3. It was noted that the chemicals in the production sections were not posted with safety labels. In accordance with Article 14 of the Regulation For Chemical Usage Safety in Work Place: (1) In case of transferring or loading the chemicals purchased into a new container, it is required to mark clearly the descriptions of these chemicals on the newly adopted container. As to those hazardous chemicals that have been transferred or loaded into a new container, it is necessary to stick a safety precautions mark on the new container. (2) The original safety precautions mark upon those containers that contain hazardous chemicals shall not be replaced before these containers have been cleansed. Kohl's requires management to ensure safety labels (in the native language of the employees) are attached on all chemicals. 4. It was noted that the warning signs on the electricity connection boxes were painted on the boxes, which was not in compliance with the legal requirement. In accordance with Article 2-7 of Warning Sign in the Guidelines for Safety Signs and Usage (GB: 2894-2008): The electric shock warning sign should be marked on electricity devices and circuit where electric shock may happen. 6.2 The material of signs: safety signs should be made of durable material. The materials which will be deformed or deteriorated when wet and flammable material are generally should not be used. The insulation material should be used at workplace where there is risk of electric shock. Kohl’s requires management to ensure that all electricity connection boxes in the facility are clearly and properly marked with warning signs in the workers’ native language and are in compliance with the legal requirement. 5. It was noted that management had not provided regular occupational health checks to employees who were in contact with hazardous materials. In accordance with Article 32 Law of the People’s Republic of China on the Prevention and Treatment of Occupational Diseases: For the laborers that are engaged in the operations contacting the harm of occupational diseases, the employing work unit shall organize the occupational health examination of the laborers before they take the posts, when they are at the posts and when they leave the posts, the employing work unit shall inform the laborers of the examination results. The employing work unit shall afford the expenses needed for the occupational health examination. The employing work unit may not assign the laborers that haven’t gone through the pre-post occupational health examination to undertake the operations involving the harm of occupational diseases; may not assign the laborers that have occupational contraindications to undertake the operations that they shall avoid; the laborers that are found to have the health injuries related to their posts during the occupational health examination shall be transferred from their former posts and be settled appropriately; and the employing work unit may not cancel or terminate the labor contacts signed with the laborers that haven’t gone through the occupational health examination before they leave their posts. The occupational health examination shall be undertaken by the medical health institutions approved by the administrative departments of health of the people’s governments at the provincial level and above. Kohl’s requires management to provide all eligible employees with occupational health checks. Records must be maintained showing that the health checks have taken place. Health and Safety Dormitories1. It was noted that production building B was attached to the dormitory building. In accordance with Article 19 of Fire Control Law of the People’s Republic of China: Dormitories and places engaged in production, storage and sales of inflammable and explosive dangerous goods must not be located in the same building and shall keep certain distance. Dormitories and places engaged in production, storage, and sales of other goods can be located in the same building only when they are in accordance with the requirements of the State Technical Standards on Fire Control for Engineering Construction. In accordance with Kohl’s Terms of Engagement: Where applicable, Business Partners who provide residential facilities for their workers must provide safe and healthy facilities, separate from production facilities, that comply with legally mandated standards for health and safety. Kohl’s requires management to ensure all dormitories are located separate from production and warehouse facilities. 2. It was noted that the exit doors on the 3rd and 4th floors between production building B and the dormitory were rolling. In accordance with Kohl’s Terms of Engagement: Where applicable, Business Partners who provide residential facilities for their workers must provide safe and healthy facilities, separate from production facilities, that comply with legally mandated standards for health and safety. Kohl’s requires management to immediately replace all rolling doors with doors that open in the direction of evacuation or install a permanent device to ensure that the doors remain open during all operating hours of the factory. Wages and BenefitsIt was noted that 104 out of 135 employees were provided with pension, accident, unemployment, and maternity insurances in December 2011. No medical insurance was provided for employees. In accordance with the PRC Labor Law, Article 72: Employing unit and workers must participate in social insurance and pay social insurance premiums in accordance with the law. In accordance with Article 73: Labors shall enjoy social insurance benefits under the following circumstances: - Retirement; - Illness or injury; - Disability caused by work-related injury or occupational disease; - Unemployment; - Child-bearing.Therefore, according to national law, all 5 types of social insurance schemes mentioned above shall be provided for all employees of a factory. In accordance with Kohl’s Terms of Engagement: Kohl's Business Partners must pay workers wages and legally mandated benefits that comply with the higher of (a) any applicable law, or (b) to match the prevailing local manufacturing or industry practices. In accordance with Kohl’s Monitoring Program pertaining to Social Insurance coverage inChina: All employees of a factory shall be covered with accident and / or injury insurance and all female employees will be provided with maternity insurance and/or paid maternity leave. Kohl’s requires management to ensure that all employees participate in all 5 types of social insurance and receive all of their statutory welfare entitlements as stipulated by national law. Management must provide all employees with accident / injury insurance. The factory must either purchase social work related injury insurance, purchase commercial accident / injury insurance or both types of insurance can be purchased to ensure that all employees are covered. For the remaining 4 types of social insurance employees must participate as deemed required by the law. Otherwise management must obtain a Waiver that is stamped by the local authority seeking exemptions from certain kinds of social insurance and verifying that the social insurance provided meets the requirements of the local law. The Waiver must indicate the number of employees participating in each type of social insurance. Paid maternity leave must be provided to employees, if child-bearing insurance has not been implemented or if the factory has not purchased child-bearing leave from the local Social Insurance Bureau. Management must provide a valid Payment Receipt indicating the amount and type of social insurance purchased which matches the number of employees and type of insurance on the Waiver. If the number of employees increases or decreases the factory must obtain an amendment to the Waiver indicating that the insurance provided still meets the local requirements. Working Hours It was noted that:- 5 out of 5 sampled employees worked 48 to 60 hours of overtime in April 2011;- 5 out of 5 sampled employees worked 69 to 78 hours of overtime in August 2011;- 15 out of 15 sampled employees worked 54 to 68 hours of overtime in October 2011. Precautions for KOHL'S Factory Inspection Code of ConductIn accordance with Article 41 of the Labor Law of the PRC: After consultation with the trade union and employees, the employer may extend working hours due to its production or business needs, but the extended working hours shall not generally exceed 1 hour a day; in special circumstances that require an extension of working hours, the extended working hours shall not exceed 3 hours a day and 36 hours a month on condition that the health of employees is guaranteed. In accordance with Kohl’s Terms of Engagement: Kohl's expects its Business Partners to operate based on prevailing local work hours. Except in extraordinary circumstances, Business Partners shall limit the number of hours that workers may work on a regularly scheduled basis to the legal limit on regular and overtime hours established by local laws and regulations in the jurisdiction in which they manufacture. Subject to the requirements of local law, a regularly scheduled work week of no more than 60 hours and 1 day off in every 7 day period are encouraged. Partners will comply with applicable laws that entitle workers to vacation time, leave periods and holidays. Business Partners must regularly provide reasonable rest periods and 1 day off within a 7 day period. Any time worked over the norm for the area should be compensated as prescribed by the local labor laws. Working hours must be recorded by an automated timekeeping system. Whenever a worker is present in a facility, the worker’s time must be recorded and the worker properly compensated. This applies to both regular and overtime working hours and any time used for work preparations or repairs. Kohl’s requires management to ensure that overtime hours worked by all employees are within the stipulations of the law and Kohl’s Terms of Engagement. Communication and Record KeepingIt was noted that management was unable to provide wage and working hour records for November 2010 and December 2010. In accordance with Kohl’s Terms of Engagement: All Business Partners must maintain in the factories producing merchandise for Kohl’s all documentation necessary to demonstrate compliance with Kohl’s Terms ofEngagement. Kohl's requires management to maintain wage and working hour records for at least 12 months. The above findings and remediations were discussed with Mr. Yang Aiguo, Factory Manager, by the Bureau Veritas Consumer Products Services, Pvt., Ltd. monitors. Kohl’s takes violations of the type found at the facility extremely serious. We expect your management to do likewise and to take immediate corrective actions. Please forward a Corrective Action Plan to Kohl’s within 3 days upon receipt of this letter. You may either fax the Plan to Kohl’s at 262-703-6450 or e-mail the Plan to deanne.lowe@kohls.com. A second monitoring visit will be scheduled and performed by Bureau Veritas Consumer Products Services, Pvt., Ltd. for Kohl’s within 45 days of the most recent visit. Should you be found to be in continued violation of Kohl’s Terms of Engagement, Kohl's Department Stores will take the appropriate action, including the potential termination of business relations with Shantou Shi Chuang Gao Wan Ju You Xian Gong Si and its Business Partners. We thank you in advance for complying with Kohl’s Terms of Engagement.

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一、KOHL'S Business Partner Contract Terms

KOHL'S promises to always adhere to regulations and humanitarianism in all business activities. All suppliers and contract companies (business partners) of KOHL'S must also fully comply with relevant national and local regulations in their production operations and commercial activities. All business partners must maintain a high level of business ethics and respect human rights. If the requirements of industrial standards exceed local regulatory requirements, the higher standard should prevail. Our company's standards are summarized as follows:

Employee Employment Regulations: KOHL'S only engages in business dealings with business partners who respect the legitimate rights and interests of employees. Employees of these business partners are able to work voluntarily, enjoy equal treatment, receive reasonable compensation, and do not take risks in activities that may harm their health. They have freedom of association and are not subject to any form of exploitation or fraud.

Salary and welfare benefits: KOHL'S business partners must pay reasonable wages to employees and provide corresponding welfare benefits in accordance with legal regulations. The standards of wages and welfare benefits shall not be lower than (a) the standards stipulated by relevant laws, and (b) the general standards of similar local production units. In addition to the compensation paid for employees' normal working hours, compensation should also be provided for their overtime work, and the amount of overtime wages should be at the rate prescribed by law. In countries without such regulations, overtime wages should be at least equal to the normal wages of workers. KOHL'S believes that wages are extremely important for meeting the basic living needs of workers. KOHL'S will seek and prioritize business partners who promise to continuously improve employee wages and benefits.

Working hours and rest days: Business partners should limit employees' normal working hours and overtime hours to within the scope specified by law for relevant industries. Business partners must arrange reasonable and fixed rest periods for workers, ensuring that employees take at least one day off every seven days. Any working hours exceeding the local normal working hours must be compensated in accordance with relevant laws and regulations.

Child labor: The use of child labor is strictly prohibited. Business partners must fully comply with regulations regarding work restrictions for minors, especially regarding their working hours, wages, minimum education level, working conditions, etc. The term 'minors' referred to in child labor refers to anyone under the age of 15 (or 14 if permitted by the laws of that country). In addition, if the required age for completing compulsory education in the country is greater than 15 years old, any person below the age for completing compulsory education is also considered a minor, and KOHL'S will not engage in business with business partners who use or agree to use child labor.

Prisoner labor and forced labor: During the entire process of manufacturing and assembling products provided by KOHL'S, there must be no use of contracts or as collateral to force others to work. Prisoners or forced labor shall not be used for production. The so-called forced labor refers to the labor or services that workers are forced to provide involuntarily due to the threat of punishment if they do not engage in the labor.

Discrimination: Hiring employees (including recruitment, salary, benefits, promotion, dismissal, and retirement) should be based on the ability of the worker, not on their personal characteristics. When recruiting workers, consideration should be given to their ability to perform the job, rather than their gender, age, sexual orientation, disability, racial characteristics, cultural or religious beliefs, and other characteristics. If business partners discriminate against certain individuals based on their gender, age, sexual orientation, physical disability, racial characteristics, cultural or religious beliefs, then KOHL'S will not develop business with these companies.

Freedom of association: Workers must have the right to freely choose to join social organizations. Business partners must recognize and respect workers' right to freedom of association and collective bargaining. Workers who peacefully exercise their legal rights to join or refuse to join a certain social group shall not be threatened or harassed.

Form of disciplinary action: The dignity of every worker should be respected. No worker shall be subjected to corporal punishment. Workers should be guaranteed to be physically and psychologically inviolable. Workers should not be subjected to verbal harassment, sexual harassment, or other forms of physical or mental oppression, abuse, or threat. Business partners are not allowed to use or allow the use of fines as a form of disciplinary action.

Women's rights: All business partners should ensure that their female employees are treated equally in all aspects of employment. Pregnancy testing cannot be used as a condition for hiring or retaining workers. When pregnancy testing is required, workers should also be allowed to make a completely voluntary decision on whether to conduct the test. Workers should not engage in harmful activities that may disrupt fertility. Business partners cannot force workers to take contraceptive measures.

Industrial health and safety: Business partners should provide a healthy, hygienic, and safe working environment for their work, in order to prevent accidents and work-related injuries among workers during the process of production facilities. Business partners must fully comply with mandatory standards related to workplace health and safety. If business partners provide residential facilities for employees, they must ensure that these residential facilities comply with mandatory health and safety standards stipulated by relevant laws.

Professional ethics standards: KOHL'S adheres to its own professional ethics standards in the business field. KOHL'S also needs to ensure that its business partners adhere to appropriate professional ethics in their business activities. KOHL'S strictly prohibits bribery, kickbacks, or other forms of illegal or improper payments to any individual or entity for the purpose of obtaining or maintaining business.

Supervision and Compliance: KOHL'S believes that proactive supervision should be taken to ensure that business partners comply with the terms of the contract and purchase order signed by KOHL'S. This can include screening business partners, as well as dispatching KOHL'S representatives to conduct on-site inspections of factories on a regular or irregular basis, with or without prior notice, to ensure compliance with the terms of the contract.

KOHL'S requires its inspectors, contacts, and representatives to pay attention to violations of KOHL'S' Contract Terms' during inspections of factories or production facilities, and report any doubts to management. Management will follow up on the situation and propose rectification requirements. If you believe that these contract terms have not been upheld, or if you have any questions, please inform the representative of KOHL'S. Your identity will be kept confidential.

二、Precautions for Kohl's factory inspection

Introduction to Kohl's Company

Kohl's is a well-known professional department store for families in the United States. Kohl's was founded by the Kohl family in Milwaukee in 1962 and has grown rapidly since then. Now, Kohl's stores are located in 40 states in the United States, and the number of stores is increasing every year.

Kohl's sales target is mainly young mothers with young children at home, and most of its stores are located in urban areas where families live together, emphasizing shopping convenience and value for money. Kohl's department store has a children's, youth, women's, and men's product department, with a product range of men's, women's, youth, children's, bags, toys, shoes and boots, jewelry, beauty products, home clothing, dining utensils, furniture decoration, hygiene products, travel equipment, and electronic products.

Kohl's factory inspection

Kohl's factory inspection refers to the audit conducted by American Kohl's department store on its global suppliers, including human rights, quality, and anti-terrorism inspections.

Kohl's factory inspection needs to review three projects: human rights, quality, and counter-terrorism. Quality accounts for a large proportion. KOHL's human rights inspection is generally required for every factory, and the audit results have a significant impact on orders. If there are serious problems or if several factory inspections fail, the order cannot be placed or the shipment will be affected. Quality and anti-terrorism inspections are not required for every factory, but are arranged according to customer requirements.

The standard Code of Conduct used by KOHL'S human rights inspection is one of the COC inspection standards, officially known as the KOHL'S Business Partner Cooperation Terms. KOHL's human rights inspection factory has similar requirements to other American clients' human rights inspection factories, but it has its own unique features.

Kohl's factory inspection precautions

1. Kohl's factory inspection has a special requirement for doors. The doors inside the factory must open inward. If the factory installs movable doors or opens outward, they must be changed to open inward, otherwise Kohl's cannot accept it. The requirement for safety exits is that safety products cannot be on the same wall, can be adjacent or opposite. However, if adjacent, the straight distance between the two doors cannot be less than 5m. Within a warehouse area of 300 square meters, there must be a safety exit.

2. Kohl's factory inspection requires a 100% social insurance standard in terms of social security. Some factories may claim that we have met the local minimum social security standard, and they have also obtained social security approval documents from the social security bureau. However, Kohl's does not recognize it here. 100% insurance coverage is a mandatory standard, and if it cannot be met, a qualified factory inspection report cannot be obtained.

3. Kohl's factory inspection adopts the same zero tolerance standard as ICTI audit. What is zero tolerance? Only when there is no issue with the factory inspection report can it be considered approved. If there are some minor on-site issues in the factory inspection of general customers, such as incorrect position of fire extinguishers or the absence of needle blocking plates in a certain sewing machine, they can be rectified according to the photos. Just send pictures of the rectified appearance, Kohl's factory inspection is not allowed, and must be reviewed according to the on-site inspection by the auditor.

4. Kohl's factory inspection date is often consulted by factories, and they often ask if the Kohl's factory inspection time is not notified and is it a surprise audit? In fact, the initial review time of Kohl's is notified, but the review and annual review time are not notified, which is a surprise review and requires the factory to be prepared at any time.

Benefits of passing Kohl's factory inspection

The current international industry not only requires enterprises to provide high-quality and affordable products, but also considers the impact of their business activities and policies on society and morality. Enterprises can prove to be very responsible in terms of social responsibility, ethics, and quality, and will gain a competitive advantage. At the same time, give stronger confidence to relevant parties of the enterprise, such as customers, investors, and consumers. We often say that only through factory inspection can enterprises obtain admission tickets to enter the market competition.

三、Precautions for KOHL'S Factory Inspection Code of Conduct

In accordance with Kohl’s Department Stores Terms of Engagement for Business Partners, Bureau Veritas Consumer Products Services, Pvt., Ltd. monitored Shantou Shi Chuang Gao Wan Ju You Xian Gong Si on December 16, 2011. This letter is to inform you that extremely serious violations of Kohl’s Terms of Engagement were found during the monitoring visit and reported to Kohl’s. Although any violation is deemed unacceptable, the violations in bold print require immediate corrective action.

Health and Safety

1. It was noted that the following exit doors were sliding:

- 1 out of 2 exit doors in the assembly section on the 4/F of production building A;

- 1 out of 2 exit doors in the assembly product section on the 3/F of production building A;

- 1 out of 2 exit doors in the spray painting section on the 4/F of production building B;

- 2 out of 2 exit doors in the mould section on the 1/F of production building B;

- 3 out of 3 exit doors in the injection section of production building C.

In accordance with Article 7.4.12 of the Code for Design of Building Fire Protection and Prevention (GB: 50016-2006): Evacuation doors in a building should be according to the followings:

- Evacuation doors of civil buildings and factories should open in the direction of traffic. The opening direction is not restricted for a room (except for workshop type A and B) with no more than 60 occupants and average number of passengers for each evacuation door does not exceed 30;

- Evacuation doors of civil buildings and factories should install outward door, double slide door, rolling door, flap door and revolving door are prohibited;

- Evacuation doors of warehouse should be outward door opening in the direction of traffic. The slide door or rolling door may be installed in side wall of the first floor of warehouse. But slide door or rolling door should not used in type A and B warehouse;

- Evacuation doors with access control in crowded concourses, or gate of inhabitancy buildings with locking devices, should be constructed to ensure easy opening from inside without keys or any other tools in case of fire; and marks and usage guides should be posted in prominent places.

In accordance with Kohl’s Terms of Engagement: Kohl's will only utilize Business Partners who provide workers with a clean, safe and healthful work environment designated to prevent accidents and injuries arising out of, or occurring while in the course of work, or as a result of the operation of a Business Partner’s facility. All Business Partners must comply with all applicable, legally mandated standards for workplace health and safety.

Kohl’s requires management to immediately replace all sliding doors with doors that open in the direction of evacuation or install a permanent device to ensure that the doors remain open during all operating hours of the factory.

2. It was noted that 1 out of 2 exit doors in the painting section on the 4/F of the production building B opened inward.

In accordance with Article 7.4.12 of the Code for Design of Building Fire Protection and Prevention (GB: 50016-2006): Evacuation doors in a building should be according to the followings:

- Evacuation doors of civil buildings and factories should install outward door, double slide door, rolling door, flap door and revolving door are prohibited;

Kohl’s requires management to ensure all exit doors open in the direction of evacuation. If management cannot make the doors open outward, the next best solution is to completely remove the doors from the hinges, if feasible. If this is not feasible, then a locking device must be used to keep them open during working hours. The device that is installed must be a permanent locking device to ensure the doors remain open during operating hours.

3. It was noted that the chemicals in the production sections were not posted with safety labels.

In accordance with Article 14 of the Regulation For Chemical Usage Safety in Work Place: (1) In case of transferring or loading the chemicals purchased into a new container, it is required to mark clearly the descriptions of these chemicals on the newly adopted container. As to those hazardous chemicals that have been transferred or loaded into a new container, it is necessary to stick a safety precautions mark on the new container. (2) The original safety precautions mark upon those containers that contain hazardous chemicals shall not be replaced before these containers have been cleansed.

Kohl's requires management to ensure safety labels (in the native language of the employees) are attached on all chemicals.

4. It was noted that the warning signs on the electricity connection boxes were painted on the boxes, which was not in compliance with the legal requirement.

In accordance with Article 2-7 of Warning Sign in the Guidelines for Safety Signs and Usage (GB: 2894-2008): The electric shock warning sign should be marked on electricity devices and circuit where electric shock may happen. 6.2 The material of signs: safety signs should be made of durable material. The materials which will be deformed or deteriorated when wet and flammable material are generally should not be used. The insulation material should be used at workplace where there is risk of electric shock.

Kohl’s requires management to ensure that all electricity connection boxes in the facility are clearly and properly marked with warning signs in the workers’ native language and are in compliance with the legal requirement.

5. It was noted that management had not provided regular occupational health checks to employees who were in contact with hazardous materials.

In accordance with Article 32 Law of the People’s Republic of China on the Prevention and Treatment of Occupational Diseases: For the laborers that are engaged in the operations contacting the harm of occupational diseases, the employing work unit shall organize the occupational health examination of the laborers before they take the posts, when they are at the posts and when they leave the posts, the employing work unit shall inform the laborers of the examination results. The employing work unit shall afford the expenses needed for the occupational health examination. The employing work unit may not assign the laborers that haven’t gone through the pre-post occupational health examination to undertake the operations involving the harm of occupational diseases; may not assign the laborers that have occupational contraindications to undertake the operations that they shall avoid; the laborers that are found to have the health injuries related to their posts during the occupational health examination shall be transferred from their former posts and be settled appropriately; and the employing work unit may not cancel or terminate the labor contacts signed with the laborers that haven’t gone through the occupational health examination before they leave their posts. The occupational health examination shall be undertaken by the medical health institutions approved by the administrative departments of health of the people’s governments at the provincial level and above.

Kohl’s requires management to provide all eligible employees with occupational health checks. Records must be maintained showing that the health checks have taken place.

Health and Safety Dormitories

1. It was noted that production building B was attached to the dormitory building.

In accordance with Article 19 of Fire Control Law of the People’s Republic of China: Dormitories and places engaged in production, storage and sales of inflammable and explosive dangerous goods must not be located in the same building and shall keep certain distance. Dormitories and places engaged in production, storage, and sales of other goods can be located in the same building only when they are in accordance with the requirements of the State Technical Standards on Fire Control for Engineering Construction.

In accordance with Kohl’s Terms of Engagement: Where applicable, Business Partners who provide residential facilities for their workers must provide safe and healthy facilities, separate from production facilities, that comply with legally mandated standards for health and safety.

Kohl’s requires management to ensure all dormitories are located separate from production and warehouse facilities.

2. It was noted that the exit doors on the 3rd and 4th floors between production building B and the dormitory were rolling.

Kohl’s requires management to immediately replace all rolling doors with doors that open in the direction of evacuation or install a permanent device to ensure that the doors remain open during all operating hours of the factory.

Wages and Benefits

It was noted that 104 out of 135 employees were provided with pension, accident, unemployment, and maternity insurances in December 2011. No medical insurance was provided for employees.

In accordance with the PRC Labor Law, Article 72: Employing unit and workers must participate in social insurance and pay social insurance premiums in accordance with the law.

In accordance with Article 73: Labors shall enjoy social insurance benefits under the following circumstances:

- Retirement;

- Illness or injury;

- Disability caused by work-related injury or occupational disease;

- Unemployment;

- Child-bearing.

Therefore, according to national law, all 5 types of social insurance schemes mentioned above shall be provided for all employees of a factory.

In accordance with Kohl’s Terms of Engagement: Kohl's Business Partners must pay workers wages and legally mandated benefits that comply with the higher of (a) any applicable law, or (b) to match the prevailing local manufacturing or industry practices.

In accordance with Kohl’s Monitoring Program pertaining to Social Insurance coverage inChina: All employees of a factory shall be covered with accident and / or injury insurance and all female employees will be provided with maternity insurance and/or paid maternity leave.

Kohl’s requires management to ensure that all employees participate in all 5 types of social insurance and receive all of their statutory welfare entitlements as stipulated by national law. Management must provide all employees with accident / injury insurance. The factory must either purchase social work related injury insurance, purchase commercial accident / injury insurance or both types of insurance can be purchased to ensure that all employees are covered. For the remaining 4 types of social insurance employees must participate as deemed required by the law. Otherwise management must obtain a Waiver that is stamped by the local authority seeking exemptions from certain kinds of social insurance and verifying that the social insurance provided meets the requirements of the local law. The Waiver must indicate the number of employees participating in each type of social insurance. Paid maternity leave must be provided to employees, if child-bearing insurance has not been implemented or if the factory has not purchased child-bearing leave from the local Social Insurance Bureau. Management must provide a valid Payment Receipt indicating the amount and type of social insurance purchased which matches the number of employees and type of insurance on the Waiver. If the number of employees increases or decreases the factory must obtain an amendment to the Waiver indicating that the insurance provided still meets the local requirements.

Working Hours

It was noted that:

- 5 out of 5 sampled employees worked 48 to 60 hours of overtime in April 2011;

- 5 out of 5 sampled employees worked 69 to 78 hours of overtime in August 2011;

- 15 out of 15 sampled employees worked 54 to 68 hours of overtime in October 2011.

Precautions for KOHL'S Factory Inspection Code of Conduct

In accordance with Article 41 of the Labor Law of the PRC: After consultation with the trade union and employees, the employer may extend working hours due to its production or business needs, but the extended working hours shall not generally exceed 1 hour a day; in special circumstances that require an extension of working hours, the extended working hours shall not exceed 3 hours a day and 36 hours a month on condition that the health of employees is guaranteed.

In accordance with Kohl’s Terms of Engagement: Kohl's expects its Business Partners to operate based on prevailing local work hours. Except in extraordinary circumstances, Business Partners shall limit the number of hours that workers may work on a regularly scheduled basis to the legal limit on regular and overtime hours established by local laws and regulations in the jurisdiction in which they manufacture. Subject to the requirements of local law, a regularly scheduled work week of no more than 60 hours and 1 day off in every 7 day period are encouraged. Partners will comply with applicable laws that entitle workers to vacation time, leave periods and holidays. Business Partners must regularly provide reasonable rest periods and 1 day off within a 7 day period. Any time worked over the norm for the area should be compensated as prescribed by the local labor laws. Working hours must be recorded by an automated timekeeping system. Whenever a worker is present in a facility, the worker’s time must be recorded and the worker properly compensated. This applies to both regular and overtime working hours and any time used for work preparations or repairs.

Kohl’s requires management to ensure that overtime hours worked by all employees are within the stipulations of the law and Kohl’s Terms of Engagement.

Communication and Record Keeping

It was noted that management was unable to provide wage and working hour records for November 2010 and December 2010.

In accordance with Kohl’s Terms of Engagement: All Business Partners must maintain in the factories producing merchandise for Kohl’s all documentation necessary to demonstrate compliance with Kohl’s Terms ofEngagement.

Kohl's requires management to maintain wage and working hour records for at least 12 months.

The above findings and remediations were discussed with Mr. Yang Aiguo, Factory Manager, by the Bureau Veritas Consumer Products Services, Pvt., Ltd. monitors. Kohl’s takes violations of the type found at the facility extremely serious. We expect your management to do likewise and to take immediate corrective actions. Please forward a Corrective Action Plan to Kohl’s within 3 days upon receipt of this letter. You may either fax the Plan to Kohl’s at 262-703-6450 or e-mail the Plan to deanne.lowe@kohls.com. A second monitoring visit will be scheduled and performed by Bureau Veritas Consumer Products Services, Pvt., Ltd. for Kohl’s within 45 days of the most recent visit. Should you be found to be in continued violation of Kohl’s Terms of Engagement, Kohl's Department Stores will take the appropriate action, including the potential termination of business relations with Shantou Shi Chuang Gao Wan Ju You Xian Gong Si and its Business Partners. We thank you in advance for complying with Kohl’s Terms of Engagement.

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