Our Approach to Sourcing and Human Rights

Our commitment to corporate social responsibility extends to our supply chain and the vendors we work with throughout the world.

Ross requires that responsible business practices be upheld and human rights be respected throughout our supply chain.

Vendors, manufacturers, and other Company business partners are required to comply with all applicable local, state, federal, and international laws relating to the manufacture and production of products sold to Ross, including laws relating to:

• Labor compensation
• Working conditions
• Child, slave, prison, or forced labor
• Environmental protection
• Product safety
• Corruption or bribery (including foreign corrupt practices)
• Building and working safety conditions similar obligations

To the extent contractors or subcontractors are involved in the production of goods supplied to Ross, vendors must require that these parties are similarly compliant with Ross’ Vendor Code of Conduct.

Ross’ standards and requirements related to sourcing and human rights are incorporated in various Company documents, including Ross’ Code of Business Conduct and Ethics, Vendor Compliance Manual, Purchase Orders, Vendor Indemnification Agreements, and Buying Agent Agreements. Ross’ standards and requirements related to human rights are also designed to comport with applicable Universal Declaration of Human Rights (UDHR) and International Labor Organization (ILO) standards. For more information, refer to our Vendor Compliance Manual and our Code of Business Conduct and Ethics, which are located in the Corporate Governance section of our website.

Responsible Sourcing

Beyond communicating our standards and requirements related to sourcing and human rights in various Company documents, Ross dedicates significant resources and drives processes to promote responsible sourcing.

The majority of the apparel, footwear, accessories, and home-related products sold in our Stores are purchased from suppliers after they have been produced and imported to other retailers’ specifications. Though Ross does not have direct control over the manufacturing processes for these products, we require suppliers to uphold our ethical standards.

Some products are ordered and imported directly through international buying agents or certain overseas vendors. For these items, we have additional processes and requirements in place to monitor and enforce compliance.

To start, we communicate our standards and requirements, and provide training to vendors, buyers, and overseas buying agents during our purchasing processes. We provide initial training to new Associates as well as ongoing training and updates to buyers and other Associates involved in our product sourcing. Further, we monitor and assess our supply chain for compliance related to product safety, labor laws, and human-trafficking concerns.

In addition, we maintain a factory audit program intended to promote compliance with our Vendor Code of Conduct, which includes adherence to local labor, safety, and environmental laws. The program employs numerous resources, including buying agent-conducted factory inspections and third-party factory audits conducted by industry-leading auditors. Additionally, on an annual basis, Ross reviews hundreds of social compliance reports and corrective action responses.

If Ross becomes aware that any vendor or its manufacturing factory is out of compliance with our requirements or procedures, we will take appropriate responsive action, which may include suspending all shipments of the vendor’s merchandise and/or terminating the business relationship.

Product Safety

Ross is committed to the sale of safe products in our Stores.

Through various vendor-facing documents, we require our vendors to provide products that comply with applicable federal, state, and local statutes, rules, and regulations (e.g., Purchase Order, Vendor Compliance Manual, and Indemnification Agreement).

Additionally, Ross references relevant legislation and safety standards when designing our buying and selling strategies. Although Ross does not buy or sell hazardous chemicals, we recognize that some consumer products may contain natural components and synthetic chemicals as ingredients. To protect the safety of consumers, including children, we require that vendors’ products comply with the Federal Hazardous Substances Act and any corresponding state laws. These laws mandate proper labeling, warning requirements, and product testing.

Children’s products are subject to rigorous requirements, including but not limited to the Consumer Product Safety Improvement Act (CPSIA). Compliance is strictly enforced by the Consumer Product Safety Commission, and Ross requires that vendors of CPSIA-impacted products confirm that they meet the Commission’s requirements.

Where Ross sources food and cosmetic products overseas, we require that suppliers submit labeling and ingredients for compliance review and that they abide by all applicable U.S. Food and Drug Administration (FDA) requirements. Additionally, we review and confirm that foreign food suppliers meet Food Safety Modernization Act requirements and corresponding regulations.

The global COVID-19 pandemic resulted in higher demand for sanitizing and disinfectant products. Products within these categories deserve heightened review as their use and inclusion of active ingredients are regulated by the FDA and the Environmental Protection Agency (EPA). Ross has processes in place to require that vendors supply products that are both safe and compliant as required by their respective agencies.

In support of our product safety commitment, we require that our vendors comply with our Vendor Compliance Manual. The Vendor Compliance Manual provides an overview of the various requirements applicable to the products we sell and references sources of additional information.

Go to our Vendor Compliance Manual for more information.

Evolving Issues

Standards and regulations regarding consumer products and supply chains are continually changing. Ross requires that all of its vendors engage in responsible business practices and uphold human rights throughout our supply chain.

As part of our annual investigation and disclosure of the existence of conflict minerals in products we sell, we require that suppliers comply with our requests to identify the source of conflict minerals incorporated in or consumed by the manufacturing of products that they provide to us and, as necessary, perform due diligence regarding the sourcing of the minerals at issue. Ross’ Conflict Minerals Disclosure is available in the Investors section of our website.

We do not specifically seek apparel or other merchandise containing animal fur. Given our opportunistic buying of already manufactured products, from time to time, products we sell may contain incidental fur.

Ross’ Code of Conduct specifically prohibits the use of any form of involuntary or forced labor by vendors and their contractors anywhere in their manufacturing or supply chain. We have zero tolerance for such violations and have taken additional, enhanced efforts intended to prevent our supply chain from including products made with forced labor. This process includes, but is not limited to, vendor communications, vendor monitoring, factory audits, and inspections.