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Issue 2004 - Freedom of Association
Issue 2004 - Freedom of Association
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Company ProfileCompliance ProgramFactory Data
Nordstrom, Inc. - Labor Compliance Program in Year Two1

Overview of the Program
Program Features

  1. Compliance Systems Developed in Year Two
  2. Improvements in Implementing the FLA Requirements

Overview of the Program

In 2003, Nordstrom completed the first year of its three-year initial implementation period of the FLA program. Over the course of the year, Nordstrom Product Group (NPG), which is responsible for the production of Nordstrom private-label products, applied the FLA program to the group's apparel lines. The company has furthermore committed to integrate the FLA program into the labor compliance programs that apply to footwear and gifts in coming years.

Nordstrom's Social Compliance program is the principal department within its corporate structure responsible for carrying out FLA requirements. The program administers the compliance process with respect to the Nordstrom Code of Conduct, which corresponds to the provisions of the FLA Code of Conduct. The Code is conveyed to Nordstrom's vendors, factories, and buying agents through the Nordstrom Partnership Guidelines.

The Social Compliance program is housed within the Nordstrom Product Group (NPG) division and interacts with all departments within NPG. The Division Vice President leads the Social Compliance program and reports to the Executive Vice President, Director of Supply Chain. In Year Two, the Social Compliance program was comprised of 9 staff members based at Nordstrom's US headquarters. The staff was responsible for designing the program, training, and oversight of the program worldwide. They cooperated with four "Key Agents" in Asia and the Middle East, who carried-out monitoring, remediation, and other compliance activities on behalf of Nordstrom. Nordstrom also relied on third-party monitors to conduct all monitoring visits to factories not under the scope of a Key Agent, as well as all pre-sourcing visits to new facilities. In sum, Cal Safety Compliance Corporation conducted 123 audits and Bureau Veritas conducted 66 audits on behalf of Nordstrom around the world. Click here to see where. Nordstrom conducted internal monitoring visits to 100% of its applicable facilities at least once in the reporting period.

Social Compliance staff participated in a 'cross-functional team' comprised of staff representatives from Sourcing, Production, Quality Assurance, Logistic, Customs Compliance and International Payment with a view to a more thorough integration of compliance into Nordstrom's core business model. Members of these departments also reviewed factory compliance and followed-up on remediation when they visited factories.


Features of Nordstrom's Labor Compliance Program in Year Two1

A. Compliance Systems Developed in Year Two

  • In 2003, Nordstrom evaluated its Social Compliance Program and developed a 3-year plan, which included goals for the program's growth. The plan was established and approved by all executive levels of Nordstrom. Quarterly reports were created to evaluate the Social Compliance program's progress in meeting goals.
  • The Social Compliance Program developed an information database for data collection and analysis of compliance in contract facilities. Audit reports were stored on the database, and accumulated data were used to focus future compliance activities in different countries/regions.
  • The company contracted third-party monitors to conduct full social compliance audits at all new factories prior to their addition to Nordstrom's factory base (click here to access the list of monitoring groups). According to the policy, factories are not authorized to receive purchase orders unless they have successfully completed any remediation action items identified in the pre-sourcing audit.
  • Since agents are Nordstrom's in-country representatives and are relied upon to provide specialized knowledge regarding relevant law and social norms that affect workers in applicable facilities, Nordstrom required all agents that were involved in social compliance work to participate in trainings on Nordstrom standards and basic auditing techniques. In order to become "Nordstrom Qualified Agents" (agents who took the lead with regard to social compliance issues), agents were required to participate in approximately one week of classroom and in-factory trainings sponsored by Nordstrom, and in SA8000 training within a year's time.
  • The Social Compliance program held supplier workshops in Italy, Portugal, Turkey, Brazil, US, China, India, and Macau with a total of 679 participants. The Social Compliance program also identified country-specific training needs with respect to certain areas of compliance, with plans to carry out trainings in 2004-5

B. Improvements in Implementing the FLA Requirements

In Year Two, Nordstrom completed the first year of its initial implementation of the FLA program. Improvements in its fulfillment of FLA requirements will be reported on in next year's report.


1 Please note that this section in no way seeks to capture all of the compliance activities reported to the FLA by companies. Instead, the FLA considers it an overview of company activities that will provide the reader with a better understanding of each company's approach and focus in Year Two.
Copyright 2004 by the Fair Labor Association