Nordstrom Partner Code of Conduct
As a company, we believe the impact we have on our employees, customers, and communities extends well beyond our operations. When we think about the value we offer to the world, we know that it's critical to protect human rights and the environment, give back to the communities we serve, and create safe and fair workplaces for the people who make our products.
To achieve our goal of always providing the best-value product in the most equitable manner, we have established standards for our business suppliers to ensure we partner with suppliers that share our commitment to quality products, responsible business principles, and quality community relationships.
COMPLIANCE WITH THE PARTNER CODE OF CONDUCT: Nordstrom’s Partner Code of Conduct contains the minimum standards that must be met by all agents, vendors, service providers, manufacturers, factories, warehouses, and subcontractors ("Suppliers") that do business with Nordstrom, Inc., or any of its subsidiaries ("Nordstrom" or the "Company"). Suppliers must comply with the standards set out in this Partner Code of Conduct throughout their operations and their entire supply chain. This means a Supplier is responsible for ensuring all its suppliers, vendors, service providers, agents, warehouses, factories, and subcontractors comply with these standards Suppliers must ensure they have adequate and effective policies, procedures, trainings, and record-keeping practices in place to ensure their compliance and the compliance of their supply chains.
Supplier contracts may contain more specific provisions addressing some of the same issues detailed in this Partner Code of Conduct. To the extent there is any inconsistency between this Partner Code of Conduct and a provision of a particular Supplier contract, the more specific contract provision will control. Nordstrom will review and may terminate its relationship with any Supplier that is unable to demonstrate its compliance with the Partner Code of Conduct or contractual requirements.
COMPLIANCE WITH LEGAL REQUIREMENTS: In addition to complying with the Partner Code of Conduct, Suppliers must comply with all applicable laws and regulations of the United States, Canada and the countries in which they do business, including the country of manufacture or exportation. Suppliers must also adhere to standards outlined in Nordstrom’s Human Rights Commitment.
Recognizing that Nordstrom Suppliers are global, this Partner Code of Conduct is based on internationally recognized standards and guidance. Suppliers must also comply with applicable sections of the United Nations (UN) Guiding Principles on Business and Human Rights; Universal Declaration for Human Rights; International Labor Organization’s (ILO) Fundamental Principles and Rights at Work; and other relevant ILO conventions, UN Convention on the Rights of the Child; and the Fair Labor Standards Act (Department of Labor Monitoring Guide).
ANTI-CORRUPTION: Suppliers must comply with all applicable laws relating to bribery, money laundering, terrorist financing, and/or corruption, including, but not limited to, the U.S. Foreign Corrupt Practices Act (FCPA) and the Corruption of Foreign Public Officials Act of Canada. Suppliers must not directly or indirectly offer or give money or anything of value to any government official for the purposes of obtaining or retaining business or to secure an improper advantage (“bribe”). "Government officials" include foreign and domestic government officials, political parties or their officials, candidates for political office, or organizations and their employees if the organization is owned in whole or in part by a government. Even if making a bribe seems to be an accepted local practice in a country, it is against the law and Suppliers are prohibited from engaging in this practice.
Nordstrom also prohibits commercial bribes. Suppliers must not directly or indirectly offer or give money or anything of value to any representative of another company to secure an improper advantage.
Suppliers must keep an accurate, written accounting of all payments relating to Suppliers' engagement with Nordstrom. If requested, Suppliers must provide Nordstrom with a copy of this accounting or assist Nordstrom with any activities required by any government or agency.
CONFLICTS OF INTEREST: Suppliers must not take any action or enter into any transactions with Nordstrom employees that could create or give the appearance of a conflict of interest. A Supplier must disclose to Nordstrom if it has a family or other close personal relationship with any Nordstrom employee who has influence over the Supplier's engagement with Nordstrom. Suppliers should also refrain from giving Nordstrom employees gifts, unless they are of nominal value which is generally considered to be $100 in a calendar year. Gifts of cash or cash equivalents such as gift cards should never be given to Nordstrom employees.
PROTECTING NORDSTROM INFORMATION: Suppliers may be given access to confidential Nordstrom information as part of their engagement with Nordstrom. All information about Nordstrom that is not public should be considered confidential information. Suppliers must have appropriate security controls in place to adequately protect Nordstrom's confidential information and must not disclose it without Nordstrom's prior written consent. This includes Nordstrom's trademarks, logos and proprietary work, which may only be used to fulfill contracted services. Suppliers also must not share with anyone at Nordstrom the confidential information of any other company if the Supplier is under a contractual or legal obligation not to share that information.
GLOBAL TRADE: Suppliers must comply with all applicable laws and regulations global trade, including U.S. and Canada Customs importing laws. Suppliers must also establish programs and maintain documentation to support country-of-origin production verification and preferential trade claims. Suppliers must comply with international supply-chain security requirements and criteria per U.S. Customs Trade Partnership Against Terrorism (CTPAT), Canada Partners in Protection (PIP), or Mutual Recognition Arrangements for comparable international Authorized Economic Operators (AEO).
CHILD LABOR AND YOUNG WORKERS: Suppliers must not employ anyone under the age of 15, under the minimum age as established by applicable local law or under the age of completing compulsory education, whichever is older. Suppliers must have established procedures for age verification as part of their hiring process.
Suppliers must not expose anyone under the age of 18 to any work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety, or morals of the young worker. Suppliers must not expose anyone under the age of 18 to hazardous work, as defined by ILO Convention 182 and national hazardous work lists, where relevant. Refer to ILO Conventions 138 and 182, and the UN Convention on the Rights of the Child.
FORCED LABOR: Suppliers must ensure that all workers work on a voluntary basis and are free from exploitation. Suppliers must not use involuntary labor of any kind, including prison labor; indentured labor; bonded labor; state-sponsored forced labor; labor obtained through human trafficking, coercion or slavery; labor defined as forced labor under any United States law; or labor defined as forced by the ILO forced labor indicators and accompanying guidance.
Suppliers must ensure all products are produced in compliance with legal requirements regarding forced labor prevention, such as the U.S. Tariff Act, the U.S. Uyghur Forced Labor Prevention Act, or the U.S. Countering America’s Adversaries Through Sanctions Act.
Suppliers must not require workers to pay any fees or other payments to the Supplier or a third-party for the purpose of being hired or as a condition of employment. Suppliers must not deduct or withhold such fees from wages or otherwise pass such fees on to workers. Suppliers must not withhold identity documents, financial guarantees or other valuable items as means to bind workers to employment. Practices that restrict workers’ freedom of movement or ability to voluntarily terminate employment are prohibited. Refer to ILO Conventions 29 & 105. Please see Nordstrom’s Forced Labor Policy for more information.
HARASSMENT & ABUSE: Suppliers must treat every person with dignity and respect. Suppliers must not subject workers to corporal punishment, coercion, threats, physical, sexual, psychological, or verbal harassment, violence, or abuse. Suppliers must not use monetary fines as a disciplinary practice. Suppliers must maintain written disciplinary policies and procedures and records of disciplinary actions. Furthermore, people of all genders must be free to voice concerns to Suppliers, Nordstrom or Nordstrom-appointed staff without fear of retaliation by the Supplier. Refer to ILO Convention 190 and UN Guiding Principles 29 & 31.
WAGES & BENEFITS: Suppliers must pay all wages, overtime, and legally mandated benefits regularly, on time, with documentation and accordance with applicable laws. Suppliers must pay at least the minimum wage, the industry wage, or the wage negotiated in a collective agreement, whichever is higher. Suppliers must not deduct wages that are not provided for by applicable local law. Suppliers are encouraged to pay employees of all genders a wage that not only meets basic needs but also provides discretionary income. Refer to ILO Conventions 95 & 131.
HOURS & OVERTIME: Suppliers should not allow working hours that exceed the applicable legal limit or 60 hours per week, whichever is less. Overtime work should be voluntary and compensated at the rate required by local law. Suppliers must ensure their workers are not penalized, punished, or dismissed for refusing to work more than the regular work limits. Workers should be allowed one day off in seven. Suppliers must keep accurate time records. Suppliers must follow the U.S. Department of Labor's Preventative Measures to Avoid Receiving Hot Goods guidelines. Refer to ILO Convention 14.
HEALTH & SAFETY: Suppliers must provide safe, hygienic and healthy working conditions. This includes written standards that comply with local laws. This includes health and safety standards related to building structures and facilities, electrical safety, fire safety, chemical safety, sanitation, emergency preparedness, first aid, personal protective equipment and other safety policies. Suppliers must not expose anyone to situations that are hazardous, unsafe or unhealthy, and must provide adequate protection from exposure to such conditions and materials. Refer to ILO Convention 187.
NONDISCRIMINATION: Suppliers must not discriminate in employment practices, including recruiting, hiring and promoting qualified people of all backgrounds, regardless of sex, race, color, national origin, social or ethnic origin, caste, union membership, religion, age, marital status, partnership status, pregnancy, parental status, physical, mental, or sensory disability, political opinion, personal characteristics or beliefs, sexual orientation, gender identity or expression, or any basis protected by local law. Refer to ILO Conventions 100 & 111.
FREEDOM OF ASSOCIATION: Suppliers must respect all workers' rights to freedom of association and collective bargaining. Suppliers must respect the right of workers to organize and engage in union activities, which includes not interfering with or restraining the exercise of their rights. Suppliers must not respond to organizing or union activities by threatening, interrogating or spying on workers or retaliating against them for exercising their rights. Any action taken to intimidate, coerce, or retaliate against workers for participation in a union or other representative organization is prohibited. Where the right to freedom of association or collective bargaining is restricted under local law, Suppliers must allow workers to engage in activities that provide similar means for independent and free association and bargaining. Refer to ILO Conventions 87, 98, & 154.
GRIEVANCE MECHANISM: Suppliers must provide method for workers to raise concerns to Supplier management without fear of retaliation. Suppliers are encouraged to ensure such concerns can be raised anonymously and/or confidentially if the worker so chooses. The grievance mechanism must be accessible to all workers. Suppliers must track and record employees’ submissions and the progress of their resolution. See UN Guiding Principles 29 & 31.
ENVIRONMENT: Suppliers must comply with all applicable environmental laws and regulations in the country of operation. Nordstrom Made products cannot be resold, donated or destroyed without brand approval. Furthermore, suppliers should seek next step use alternatives to avoid destruction of unsold goods or deadstock. Waste-to-energy programs are not an alternative, with the exception of products that pose a health or safety risk. In addition, Suppliers must have policies and procedures in place to manage, track and record, and minimize environmental impacts to energy, air, emissions, waste, and water, and to safely store, prevent or mitigate releases of chemicals and hazardous materials.
CONFLICT MINERALS &THE KIMBERLEY PROCESS: Suppliers must comply with applicable laws and regulations relating to responsible sourcing, including the sourcing of Conflict Minerals and diamonds. Section 1502 of the Dodd-Frank Act relates to the responsible sourcing of Conflict Minerals, which include: tin, tantalum, tungsten and gold (collectively "3TG") mined in conditions of armed conflict and human rights abuses in the Democratic Republic of the Congo (DRC) or its adjoining countries. Under Section 1502, applicable Suppliers must confirm the source of 3TG used in their products. Suppliers must satisfy any reporting requirements they have under Section 1502 and also provide information requested by Nordstrom so that Nordstrom may satisfy its reporting obligations under Section 1502. The Kimberley Process resolution relates to the responsible sourcing of diamonds and requires that Suppliers guarantee that diamonds are conflict-free based on personal knowledge or a written guarantee provided by the supplier of the diamonds and stated on all invoices. See our Conflict Mineral Policy for more details.
ANIMAL WELFARE: Suppliers must adhere to codes of practice that meet or exceed expectations that animals are treated ethically and responsibly, based on the internationally accepted "Five Freedoms" for animal welfare. Nordstrom does not sell products made with genuine animal fur or exotic animal skins. See our Exotic Animal Skin and Fur Free for more details.
INSPECTION: Suppliers understand that Nordstrom reserves the right to audit or inspect Suppliers' practices or facilities, including Suppliers' factories, mills, warehouses, and other subcontractors, to ensure compliance with this Partner Code of Conduct. Nordstrom Made Suppliers agree that Nordstrom may conduct regular onsite inspections of all Nordstrom Made Suppliers' factories and mills. Suppliers must be transparent, maintain accurate documentation on file and allow Nordstrom representatives and designated third-party monitors to engage in announced and unannounced monitoring activities, including confidential worker interviews to be conducted with all genders.
CHANGE OF CONTROL AND SUBCONTRACTING (Nordstrom Made Suppliers Only): Nordstrom Made Suppliers must notify Nordstrom in writing if ownership, location, sale, purchase, or control of any factory that houses Nordstrom production changes. Any of the above changes requires the factory information to be updated and the factory to be audited before starting production. In addition, Nordstrom Made Suppliers must not subcontract any portion of the manufacturing process without the written approval of Nordstrom prior to starting production.
REPORTING VIOLATIONS: Suppliers must immediately report to Nordstrom any violations of the Partner Code of Conduct. Suppliers who believe that a Nordstrom employee, or anyone working on Nordstrom’s behalf, has engaged in illegal or otherwise improper conduct must also immediately report the matter to Nordstrom. Concerns should be reported by visiting or www.npg.ethicspoint.com or by calling toll-free 1.844.852.4175.