+ANIMAL WELFARE POLICY
At J.Crew, we believe in delivering the best possible products to our customers while honoring our broader commitment to social responsibility. We continually work to ensure that we are sourcing the materials for these products responsibly, constantly keeping mind the quality of our products and the values of both our customer and our company. We aim to work with partners who are equally committed to ethical sourcing, including responsible and humane animal welfare practices in the supply chain.
We aim to work with suppliers who adopt industry-best practices that are based on the internationally recognized Five Freedoms
. The Five Freedoms are also the guiding principle behind our Animal Welfare Policy.
We require that all our suppliers adhere to the following baseline requirements for the materials allowed for use in our products, and for those who provide materials of animal origin, they must meet the standards for ethically sourced materials.
J.Crew prohibits the use of fur in our products. We define fur in accordance with the Fur Free Retailer
definition as being: “Any animal skin or part thereof with hair or fur fibers attached thereto, either in its raw or processed state or the pelt of any animal killed for the animal’s fur. ‘Animal’ includes, but is not limited to, mink, fox, rabbit, karakul lamb and raccoon dog. ‘Fur’ shall not include:
1. Such skins as are, or are to be, converted into leather or which in processing have, or shall have, the hair, fleece or fur fibers completely removed
2. Materials clipped, shorn or combed from animals, such as fleece, sheepskin or shearling
3) Leather or hair attached to skin that is typically used as leather, e.g. cowhide with hair attached
4) Synthetic materials intended to look like fur.”
Any hair, fleece or shearling used must be a byproduct of the meat industry, as outlined in our leather requirements below. We also ensure that faux fur is coming from nonanimal sources through our fiber content testing program.
J.Crew does not currently source any down for our products. If we chose to do so in the future, all down will have to be Responsible Down Standard (RDS)
certified or meet an equivalent standard for animal welfare.
All leather must be a byproduct of the meat industry.
J.Crew does not use real exotic animal skins, including but not limited to: snake, alligator, crocodile, lizard, fish or marine mammals.
J.Crew will not produce goods that contain angora or rabbit hair unless and until we can identify a source that meets our animal welfare standards.
J.Crew supports the use of wool that is sourced from humanely raised and treated sheep. We are committed to sourcing wool certified to Textile Exchange’s Responsible Wool Standard or equivalent standards, in our products where possible. We also will not produce goods that contain mohair until we can identify a source that meets our animal welfare standards.
J.Crew is the first U.S. retailer to join the Sustainable Fibre Alliance (SFA), a nonprofit international organization working with the extended cashmere supply chain to promote a global sustainability standard for cashmere production in order to preserve and restore grasslands, ensure animal welfare and secure livelihoods.
We are also members of Textile Exchange’s Responsible Cashmere Round Table, a multi-stakeholder group formed in partnership with the United Nations Development Programme (UNDP). This round table is working toward increasing market support for best practices in cashmere production and the development of a standard for farmed cashmere, which is typical of Inner Mongolia.
J.Crew prohibits the use of any protected, threatened or endangered species including, but not limited to, species appearing in:
- The Convention on International Trade in Endangered Species (CITES)
- The International Union for Conservation of Nature (IUCN) Red List as critically endangered, endangered or vulnerable
- The Endangered Species Act (ESA)
+CONFLICT MINERALS POLICY
At J.Crew Group, Inc. (J.Crew), we believe that we have a responsibility to source our products in a legal, ethical and responsible manner consistent with the highest standards. The Responsible Sourcing program at J.Crew is in place to clearly communicate our expectations to our suppliers and to monitor and improve working conditions at the facilities that manufacture products for J.Crew.
Conflict minerals are certain minerals mined in conditions that support armed conflict and human rights abuses, particularly in regions in and surrounding the Democratic Republic of the Congo (DRC). The minerals include tantalum, tin, gold and tungsten (3TG). In 2010, Congress passed the Dodd‐Frank Wall Street Reform and Consumer Protection Act. Section 1502 of the act requires that companies disclose whether minerals necessary to the functionality or production of their products originated from the conflict regions in and around the DRC. The purpose of this law is to raise public awareness about conflict minerals and promote the use of due diligence in conflict mineral supply chains in order to cut off funding to armed groups in conflict regions.
J.Crew does not source or buy minerals directly. Nevertheless, we are concerned about the reported link between mining and armed conflict and human rights abuse in conflict regions. J.Crew supports the goals and objectives of Section 1502.
As a company affected by the regulation, we have established a Conflict Minerals Program that uses a reasonable due-diligence process as suggested by the Organization for Economic Cooperation and Development (OECD) guidelines, and we are working closely with our suppliers to determine the presence of 3TG in our supply chain. We are committed to identifying the source of minerals that are required for the functionality or production of J.Crew and J.Crew-branded products and to eliminating those minerals that may have originated at conflict mines.
J.Crew expects its suppliers to fully cooperate with its requirements to ensure compliance with the Dodd‐Frank requirements. Suppliers are expected to purchase materials from legitimate sources that can trace and verify that the materials provided are not involved in funding conflict. Failure to comply with J.Crew requirements will result in reevaluation of our business relationship with the supplier.
The conflict minerals reporting requirement in Dodd‐Frank applies to any products that the company contracts to manufacture and where the minerals are necessary to the functionality of the product:
- A company is considered to be contracting to manufacture the product if it has some influence over the manufacturing of the product (including control over design or materials used in the product).
- The minerals must be necessary to the functionality or production of the product.
We have engaged with Source Intelligence®
to assist in our conflict minerals compliance program. Source Intelligence will facilitate the data collection process on behalf of J.Crew. Information provided will be collected, analyzed and stored within its secure system.
All suppliers are required to cooperate fully with J.Crew requirements relating to conflict minerals compliance. J.Crew and Source Intelligence send periodic reminders and follow up via phone and/or email with suppliers that fail to provide necessary information.
As needed, J.Crew requests assistance from related agent and/or vendor contacts to assist in collection of necessary information. Failure by a supplier to provide the necessary information may result in a temporary block of purchase orders or termination of the relationship with that supplier. If a subsupplier fails to provide necessary information, J.Crew may require that the supplier cease working with that subsupplier for J.Crew merchandise.
+VENDOR CODE OF CONDUCT
The fundamental principles of J.Crew’s Responsible Sourcing Program are outlined in our J.Crew Vendor Code of Conduct (“Code”). The Code sets forth the essential foundation upon which our program is built. While J.Crew recognizes that there are different legal and cultural environments in which our Suppliers operate throughout the world, the Code sets forth the guiding principles for our Responsible Sourcing Program, applicable to all suppliers.
J.Crew Suppliers must not employ workers younger than 15 years of age. However, if the age for completing compulsory education or the minimum working age in the country of manufacture is greater than 15, Suppliers must comply with all other applicable child labor laws and must ensure workers under the age of 18 do not perform work that may jeopardize their health or safety.
J.Crew Suppliers must not use any type of forced, bonded, compulsory or prison labor. Suppliers shall ensure that all employment is voluntary, free from violence, threats, financial penalties or coercion. There shall be no restrictions on movement, or withholding of personal documents or deposits. Suppliers must take adequate steps to ensure that workers are not trafficked or otherwise exploited.
J.Crew Suppliers must not discriminate in employment practices including recruitment, hiring, compensation, training, benefits, advancement, termination or retirement on the basis of race, color, ancestry, national or social origin, religion, gender, marital status, age, sexual orientation, gender identity or expression, disability, political opinion or any other personal characteristics or beliefs.
HARASSMENT AND ABUSE
J.Crew Suppliers must treat all workers with respect and dignity. No worker shall be subject to corporal punishment or physical, sexual, psychological or verbal harassment or abuse. Suppliers shall not use monetary fines as a disciplinary practice.
WAGE AND BENEFITS
J.Crew Suppliers must comply with all applicable laws and regulations relating to wages and benefits. Workers shall be paid at least the minimum wage or a wage that is consistent with prevailing local industry standards; whichever is higher. Overtime work shall be compensated at the premium rate as is legally required. Compensation must be provided at least monthly and should be provided without illegal or inappropriate deductions or penalties.
HOURS OF WORK
J.Crew Suppliers must comply with all applicable laws and regulations relating to hours of work. Except in extraordinary business circumstances, workers shall not be required to work more than 60 hours per week (including overtime). Suppliers shall provide workers with at least one day off every seven-day period.
FREEDOM OF ASSOCIATION
J.Crew Suppliers must recognize and respect the rights of workers to freedom of association and collective bargaining. Where such rights are not provided by law, Suppliers should take steps to provide an open means of communication with workers.
HEALTH AND SAFETY
J.Crew Suppliers must comply with all applicable laws and regulations governing workplace health and safety. Suppliers shall provide their workers with a clean, safe and healthy work environment. The same applies for dormitory facilities, where provided.
LAWS AND REGULATIONS
J.Crew Suppliers must operate in full compliance with all applicable local, national and international laws, standards and regulations relevant to the conduct of their business.
CUSTOMS AND SECURITY
J.Crew Suppliers must comply with all applicable local, national and international customs laws including those prohibiting transshipment. Suppliers shall implement security measures consistent with the recommendations set forth by the Customs Trade Partnership Against Terrorism (CTPAT).
J.Crew Suppliers must adhere to applicable local, national and international laws and regulations regarding the protection and preservation of the environment.
J.Crew Suppliers must not subcontract any portion of the manufacturing process without prior written approval from J.Crew. As a condition of approval, subcontractors shall agree to comply with the J.Crew Code of Vendor Conduct.
J.Crew is committed to working with Suppliers who are open and honest with us. J.Crew Suppliers shall maintain complete and accurate records and information so that compliance can be effectively assessed. Suppliers must not falsify or understate any aspects of their operations to J.Crew or our representatives. Suppliers must not coach employees on how to answer questions or respond to inquiries by J.Crew or our representatives.
MONITORING AND COMPLIANCE
J.Crew reserves the right to conduct announced and unannounced inspections of all manufacturing facilities. Suppliers should ensure that the requirements in this Code are understood and implemented at every level and must maintain all documentation necessary to demonstrate compliance with the J.Crew Code of Vendor Conduct. Suppliers must allow representatives of J.Crew full access to facilities, documents and workers. Suppliers shall submit an improvement plan to address any issues of noncompliance that may be found during the course of compliance inspections. J.Crew reserves the right to terminate its business relationship with any Supplier who is unwilling or unable to comply with the provisions set forth herein.
We are proud to use the AFIRM Restricted Substances List to manage chemicals in our supply chain and on our products. Click here
to learn more.
+OUR APPROACH TO SOCIAL COMPLIANCE
At J.Crew we believe that fair and decent working conditions, the freedom of opinion and expression and an adequate standard of living are basic human rights. This is why we are committed to sourcing our products in an ethical, responsible and legal manner—and expect our Suppliers to share our core values and to partner with us in our commitment to continuous improvement and in promoting better working conditions.
We do this by holding our Suppliers and ourselves accountable, by identifying issues and their root causes and by building capacity for positive change. The cornerstones of our program are our Code of Vendor Conduct, our monitoring program and capacity building efforts, as well our multi-stakeholder collaborations.
J.CREW CODE OF VENDOR CONDUCT
The J.Crew Code of Vendor Conduct is based on the International Labour Organization (ILO) conventions and other internationally recognized labor rights. We expect these standards to be followed by all factories, subcontractors, suppliers and agents who are affiliated with the production of J.Crew goods (“Suppliers”). While J.Crew recognizes that there are different legal and cultural environments in which our Suppliers operate throughout the world, the J.Crew Code of Vendor Conduct (“Vendor Code”) forms the guiding principles for our Responsible Sourcing program. By choosing to do business with J.Crew, Suppliers commit to following our policies including the Vendor Code. As such, adherence to the Vendor Code constitutes a contractual obligation between J.Crew and its Suppliers.
MONITORING FACTORY CONDITIONS
While it’s relatively simple to communicate our expectations to our Suppliers, it is more complicated to verify compliance throughout all areas of our supply chain. In order to ensure objectivity, we carefully select independent external firms to conduct both semi-announced and fully unannounced inspections of our manufacturing facilities. We also make sure that each facility will not be inspected by the same third party on a continuous basis in order to ensure integrity.
All new Suppliers are subject to inspection before any purchase orders are placed. Existing factories are inspected based on their compliance performance and overall external risk factors. A typical inspection consists of document review, private worker interviews and a walk-through of the facility to assess worker well-being and workplace health and safety. Where we may deem necessary, we also may employ additional measures such as more in-depth auditing, focused inspections, surveillance or off-site interviews, for example, depending upon the key concerns identified.
IMPROVING WORKING CONDITIONS AT FACTORIES
We believe that sustainable and positive change can only happen in partnership with our Suppliers. To this end, we provide our Suppliers with the tools they need to improve working conditions, including training and in-factory consultations. We also believe that the ability for workers to raise grievances and to collectively address issues and concerns to management are pivotal in improving working conditions. This is why we promote the establishment of worker committees at our factories through our participation in such programs as the Better Work and Fair Trade programs.
Our goal is to work to address issues of noncompliance in a cooperative manner in partnership with our Suppliers. However, in cases where a critical issue of noncompliance is identified or when a Supplier may be unwilling to meet our requirements, despite our efforts and engagement, we will terminate our business relationship where we deem necessary.
INDUSTRY COLLABORATION AND PARTNERSHIPS
Industry collaborations matter when it comes to improving overall working standards and standards of living. While we make sure to work with each of our factories, there are certain issues which only can be most effectively be addressed in a collective manner. That is why we partner with several international organizations committed to improving global labor standards and conditions.
J.Crew is a member of Fair Factories Clearinghouse (FFC), a nonprofit organization that allows participating brands to share reports and thereby increase transparency. For more information, please visit fairfactories.org
J.Crew is also a member of Business for Social Responsibility (BSR), an organization for companies committed to socially responsible business practices, and we are proud to partner with them on initiatives that are committed to improving working conditions around the world. More information on BSR can be found at bsr.org
J.Crew is a partner with Better Work, a partnership between the International Labor Organization (ILO) and the International Finance Corporation to improve social dialogue and worker engagement in supplier factories. Better Work advisers engage with suppliers to improve working conditions by building out worker committees, establishing solid grievance mechanisms and providing training to factory supervisors. We currently work with Better Work in our factories in Vietnam, Indonesia and Cambodia.
Sandblasting is a finishing process that is primarily used to achieve a worn look for denim. The method involves sand particles being applied to garments under high pressure. The use of sandblasting without proper protective equipment endangers the health of factory workers. To ensure the well-being of the workers who manufacture J.Crew products, we have banned the use of sandblasting for all J.Crew’s products.
J.Crew is aware of and takes very seriously the reports of government-sponsored forced child labor in the harvest of cotton in Uzbekistan. The use of forced child labor is inconsistent with the requirements set forth in the J.Crew’s Code of Vendor Conduct. We are firmly opposed to the use of forced child labor in the harvest of Uzbek cotton and are collaborating with a multi-stakeholder coalition to raise awareness of this very serious concern and press for its elimination. We commit to not knowingly sourcing Uzbek cotton for the manufacturing of any of our products until the government of Uzbekistan ends the practice of forced child labor in its cotton sector.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT (SB 657) AND
UK MODERN SLAVERY ACT DISCLOSURE STATEMENT 2017
The ILO Forced Labour Convention No. 29 defines “forced labor” as “work or service exacted from a person under threat of any penalty, which includes penal sanctions and the loss of rights and privileges, where the person has not offered himself/herself voluntarily.”
According to ILO data, human trafficking is the second most prevalent form of illegal trade in the world, just after the illicit drug trade and equal to the sale of illegal firearms. Sometimes referred to as modern day slavery, it is also the fastest growing illegal business in the world.
J.Crew strictly prohibits the use of any form of forced labor or the trafficking of persons across all of our company operations and in our global supply chain. In accordance with our Code of Conduct standards, business partners must not use forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise. No employee may be compelled to work through force or intimidation of any form, or as a means of political coercion or as punishment for holding or expressing political views.
For more details, please see our policies
J.CREW CODE OF ETHICS
Our J.Crew Code of Ethics and Business Conduct—the “Code of Ethics”— provides the fundamental underpinning for our ethical and compliant conduct for J.Crew associates. The Code of Ethics defines the way we do business worldwide and serves as a guide to help associates make responsible and prudent business decisions. Each of us at J.Crew is responsible for ensuring that the highest standards of conduct are upheld and encouraged. The Code of Ethics applies to all J.Crew associates and our Board of Directors. While the Code of Ethics applies to our associates and our Board of Directors, we also expect our Suppliers to behave in a manner consistent with and in furtherance of our Code of Ethics.