CA Supply Chain

Five Below (hereinafter "we") is committed to upholding the highest ethical standards in global supply chain management and strictly complies with the California Transparency in Supply Chains Act. We firmly prohibit all forms of slavery, human trafficking, and forced labor in our supply chain, and strive to ensure that every link from product sourcing to distribution reflects our values of fairness, respect, and responsibility. As a retailer providing trendy and affordable products (with core offerings priced at $1-$5 and selected items above $5), we believe ethical supply chain practices are integral to delivering trustworthy shopping experiences to our customers.
Our business address: 32034 Mattson Street, Cookeville Tennessee 38501, United States. For inquiries related to this statement, please contact us via email: service@fivebelowdeals.com.

1. Core Commitment and Supplier Code of Conduct

We have established a comprehensive Supplier Code of Conduct that applies to all suppliers, regardless of their location or the value of products they provide. This Code explicitly prohibits slavery, human trafficking, child labor, forced labor, and discriminatory practices, and requires suppliers to comply with all applicable labor laws, environmental regulations, and business ethics standards in their operating jurisdictions . Before establishing cooperation with any supplier, we require them to sign and acknowledge this Code, and incorporate its obligations into formal supply contracts to ensure legal enforceability.
Our commitment extends to the entire supply chain, including raw material suppliers, manufacturers, and logistics partners. We regularly communicate our ethical requirements to suppliers and encourage them to cascade these standards to their own sub-suppliers, forming a unified ethical supply chain ecosystem.

2. Supply Chain Risk Verification

To proactively identify and mitigate risks of slavery and human trafficking, we have implemented a rigorous supplier vetting and monitoring system covering the following key measures :
  • Pre-qualification Assessment: For new suppliers, we conduct in-depth due diligence, including reviewing their business licenses, labor compliance records, and social responsibility reports. We focus on high-risk regions and industries, and require additional supporting documents to verify compliance status.
  • Regular Performance Monitoring: We track supplier compliance through periodic self-assessment questionnaires, on-site visits, and data submission requirements. Suppliers are required to promptly report any changes in their operation status or potential compliance risks, ensuring transparency in supply chain operations.
  • Risk Classification Management: We classify suppliers based on product categories, regions, and historical compliance performance. For high-risk suppliers (such as those operating in industries with higher labor risk), we implement enhanced verification measures, including more frequent audits and third-party assessments.

3. Supplier Auditing Mechanism

We conduct regular audits of suppliers to verify their compliance with our ethical standards, with audit scope covering labor practices, working conditions, and anti-slavery commitments . Our audit system includes the following key elements:
  • Audit Methods: We combine internal audits conducted by our supply chain management team with third-party audits by authorized institutions. Third-party audits are mainly carried out by Sedex-affiliated audit companies (AACs) using the SMETA audit framework, which comprehensively evaluates compliance in 11 dimensions including free employment, working hours, and occupational health . SMETA audits provide transparent data through on-site inspections, worker interviews, and record reviews, without simple "pass/fail" conclusions, focusing on continuous improvement.
  • Audit Frequency: Core suppliers are audited at least once a year, while high-risk suppliers are audited semi-annually or as needed. We also conduct unannounced spot checks to ensure the authenticity of supplier compliance status.
  • Corrective Action Process: For audit findings of non-compliance, we work with suppliers to develop a corrective action plan with clear timelines. We track the implementation progress of the plan and conduct follow-up audits to verify improvement results. For serious or repeated violations, we will take decisive measures including suspending cooperation or terminating the supply contract.

4. Certification and Compliance Confirmation

We encourage and prioritize cooperation with suppliers who have obtained internationally recognized social responsibility certifications, including SEDEX membership, BSCI certification, and WRAP certification . These certifications serve as important references for supplier compliance, but do not replace our independent verification and audit procedures. We require suppliers to provide valid certification documents and ensure that the certification scope covers the products supplied to us.
For suppliers without relevant certifications, we require them to undergo additional third-party verification to confirm their compliance with our ethical standards. All certification and verification results are recorded in our supplier management system for regular review and update.

5. Internal Accountability and Training

We have established a clear internal accountability mechanism to ensure that supply chain ethical management is effectively implemented. Our supply chain management team, procurement department, and legal team jointly assume responsibility for supply chain compliance, with specific duties including policy formulation, supplier monitoring, and audit execution. We incorporate ethical supply chain performance into employee performance evaluations to strengthen accountability awareness .
We provide regular training to relevant employees, covering content such as the California Transparency in Supply Chains Act, our Supplier Code of Conduct, risk identification skills, and audit procedures. For employees directly involved in supplier management, we offer advanced training on international labor standards and supply chain transparency practices to enhance their professional capabilities in ethical management. New employees receive mandatory training before taking up their positions to ensure consistent understanding of ethical requirements.

6. Reporting Mechanism and Continuous Improvement

We have established a confidential reporting channel for all stakeholders (including employees, suppliers, and customers) to report suspected violations of slavery, human trafficking, or other ethical issues in the supply chain. Reports can be submitted through the following channels:
  • Email: service@fivebelowdeals.com (Please mark the subject as "Supply Chain Ethical Violation Report")
  • Business Address: 32034 Mattson Street, Cookeville Tennessee 38501, United States (Formal written reports)
All reports will be handled by a dedicated team in a timely and confidential manner, with strict protection of the reporter's identity to prevent retaliation. We conduct in-depth investigations into each report and take appropriate corrective actions based on the investigation results. We will notify the reporter of the handling progress (where appropriate) while ensuring compliance with confidentiality requirements.
We regularly review and update our supply chain management policies and practices based on audit results, stakeholder feedback, and changes in relevant laws and regulations. We also actively participate in industry exchanges on ethical supply chain management to learn best practices and continuously improve our supply chain transparency and ethical standards.

7. Conclusion

Eradicating slavery and human trafficking from the supply chain is a long-term commitment that requires joint efforts from all stakeholders. Five Below will continue to strengthen supply chain management, enhance transparency, and work with suppliers to build an ethical, sustainable, and trustworthy supply chain. We welcome customer supervision and feedback, as this is crucial to our continuous improvement of supply chain ethical practices.