Global Compliance

Vendor Code of Conduct

Guidebook to the Code of Vendor Conduct (PDF)

Dear Sears Holdings Vendor or Factory Partner:

The operating companies under Sears Holdings Management Corporation (Sears Holdings) have had a formal Labor Compliance or Human Rights program to help ensure that merchandise vendors and factories adhere to the requirements of the Sears Buying Policy and Kmart Code of Vendor Conduct on such issues as child labor, wages, benefits, health and safety, and factory security.

Prior to the Kmart/Sears merger, a group representing select Sears shareholders (Christian Brothers Investment Services, Dominican Sisters of Springfield, Interfaith Center on Corporate Responsibility, Sisters of Providence-Mother Joseph Province, Connecticut State Treasurer’s Office, and others) began a dialogue with Sears associates to review Sears Buying Policy. For purposes of the dialogue, the shareholders were informed by the International Labor Organization (ILO) core Labor Principles. After a number of conversations with the shareholders and the merger between Kmart and Sears, Sears Holdings agreed to revise the Sears Buying Policy and Guidelines. The revised policy is in the Sears Holdings Code of Vendor Conduct and Guidelines. We believe that the new Sears Holdings Code of Vendor Conduct and Guidelines are appropriate for Sears Holdings, its business and sourcing model, and it addresses many of the concerns raised by the shareholders.

It is our hope that the revised language helps to clarify what workplace practices and working conditions are acceptable when doing business with Sears Holdings. While we expect adherence to Sears Holdings Code and the attached Guidelines, we understand that full compliance can be challenging in some instances. In light of this, Sears Holdings will work with vendors and factories that are honest and transparent under the spirit of continuous improvement. Our goal is not to terminate non-compliant factories, but to work with the factories to remediate any noted deficiencies to the Code in an effort to achieve sustainable compliance. Companies that do not demonstrate a commitment to continuous improvement or that fail to be honest and transparent in their dealings with us, will be terminated.

Please review the Guidelines to learn more about how the Code of Vendor Conduct is interpreted and how your company can improve factory compliance levels. If you require further guidance, please feel free to contact a member of the Sears Holdings Global Compliance Department at laborc@searshc.com.

Thank you very much for your continued support.

Sincerely,

Sears Holdings Management Corporation’s Global Compliance Department

Guidebook to the Code of Vendor Conduct (PDF)