Dillard's Social Accountability Policy 2019, pg. 3

"Freedom of Association and Collective Bargaining- Each Vendor and Factory shall obtain and comply with local and national laws and regulations regarding freedom of association and collective bargaining. No employee shall be subject to harassment, intimidation or retaliation in their efforts to pursue their legal rights. All workers should be free to join associations of their own choosing, and they should have the right to bargain collectively. We do not authorize any disciplinary actions from the factory against workers who choose to peacefully and lawfully organize or join an association."

Dillard's Social Accountability Report 2019, pg. 3

"V. General Findings of Assessments Dillard’s partners with its suppliers to create CAPs that are monitored by 3rd party social compliance audit teams. Dillard’s completed two hundred forty-six (246) Social Assessments in FY2019; however, we did not place purchase orders in 27 of the audited factories for that year. Therefore, our findings were focused on the remaining two hundred nineteen (219) factories that Dillard’s did place orders in FY2019. Dillard’s Audit Firms evaluated two hundred ten (210) factories in FY2019. The remaining 9 factories were audited by other 3rd party service providers deemed acceptable:  Factories achieved level 1 rating = Thirty-Two (32)  Factories achieved level 2 or 3 rating = One hundred and Sixty-Seven (167)  Factories achieved level 4 rating = Eleven (11)  Factory is at level 5 = Zero (0) Note: A level 1 rating is the best possible rating a factory can achieve and level 5 is the lowest rating for a factory.

Factories with ratings of two or higher were required to follow up with a CAP that includes completion dates. One hundred seventy (178) factories successfully completed their first CAP as scheduled. The remaining thirty-three (33) factories were assigned a second CAP, and all but seven (7) factories completed their second CAP as scheduled. Out of the last seven (7) factories, five (5) factories completed their third CAP to an acceptable level as scheduled. Also, two (2) factories were canceled due to poor Assessment scores in Health and Safety, Working Hours, and Wages and Benefits. Dillard’s and its inspection firms work with vendors and factories to establish and monitor CAPs in an effort to bring each factory into compliance where non-conformance is found. It is Dillard’s desire to establish continuous improvements in factory conditions. Dillard’s only terminates business relations as a last resort. However, Dillard’s reserves the right to terminate business relations for any violations of its Policy."