Program Oversight

Burlington’s Chemical Management Program is led by the Product Safety Team with support from Legal and Environmental Sustainability and in partnership with various functions, including procurement and merchandising, under the oversight of the CSR Editorial Board. We leverage outside resources as needed to provide external/market information to inform our decisions, including outside regulatory compliance counsel and industry consultants.

Our Program

Chemical Compliance Manual

Burlington is committed to eliminating hazardous chemicals from our products as part of our corporate social responsibility. Our Chemical Compliance Manual (download above) sets forth our policies, procedures and regulations related to chemical compliance, including Burlington’s Restricted Substances List (RSL). Burlington follows the threshold limits established by federal, state and local regulations for restricted chemicals and expects its vendors and suppliers to also comply with these guidelines. Burlington continually reviews and updates its RSL to keep up with the evolving regulatory restrictions that impact our product categories. The RSL is applicable to all products sold at Burlington.

Burlington will also provide its vendors with guidance on chemicals of concern. We encourage our vendors to know the chemicals that are in their products through testing so that they can identify chemicals of concern and look for suitable alternatives or alter their manufacturing processes.

Product Safety Compliance Program

All Burlington suppliers/vendors are required to comply with the terms set forth in our Code of Conduct, Product Safety and Social Compliance Manual. As described in this document, Burlington is committed to the highest ethical standards. All products supplied to Burlington are expected to comply with all applicable laws and regulations. To assist suppliers with identifying applicable laws and regulations, Burlington provides its vendors with product safety testing protocols for the primary product categories it purchases. These provide clear expectations of Burlington safety standards including regulatory requirements.

In addition, Burlington takes a strategic approach for purchasing and selling products that meet or exceed legal standards for safety. We employ heightened safety measures for product categories that present the greatest safety risk to our customers. For example, Burlington maintains rigorous requirements for vendors that supply children’s products. We require importers of children’s products to issue a Children’s Product Certificate, supported by test results from a CPSC accredited laboratory confirming compliance with all applicable standards, bans, rules, and regulations. Burlington also maintains a comprehensive food safety program and works closely with our supply chain to ensure compliance with food safety regulations, including the Food Safety Modernization Act. We require all food facilities to be audited and inspected prior to doing business with us. Burlington also takes steps to ensure the cosmetic products we sell are safe for use. Vendors are required to certify that their cosmetic products are free of any poisonous or deleterious substance and are free from prohibited or restricted ingredients. Any product that fails to comply with applicable consumer product safety regulations or creates an unreasonable risk of serious injury will be subject to our product recall process.

Burlington also takes steps to ensure the products it sells comply with all labeling requirements, including those under California’s Proposition 65 program (Prop 65). Prop 65 requires businesses ensure that Californian consumers receive clear and reasonable warnings prior to being exposed to a growing list of chemicals that have been identified as causing cancer, birth defects or other reproductive harm. We require our vendors to review the chemicals present in their products and provide a particular warning based on the listed chemicals and the method of transmission. Any product found to be in violation of this rule will be removed from the selling floor in our California stores.

Vendor Agreements

In connection with Burlington’s Product Safety Compliance Program, all new vendors who supply products to Burlington are required to complete and sign the Company’s Vendor Agreement as part of the new vendor on-boarding package. Existing vendors agree to the Company’s Purchase Order Terms and Conditions with each purchase made. By signing the Vendor Agreement form and/or accepting and fulfilling any order, vendors represent and warrant that they will comply with such Terms and Conditions as well as the Burlington Vendor Manual, Code of Conduct, Product Safety and Social Compliance Manual, Chemical Compliance Manual and that all products supplied will meet all applicable laws, rules and regulations.

Responsible Sourcing Practices

Burlington supports responsible sourcing practices, which includes compliance with the California Transparency in Supply Chain Act and the Conflict Minerals provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Vendors who manufacture products for Burlington are also required to comply with Burlington’s Terms of Commitment to Ethical Sourcing.

Hazardous Waste Program

Burlington is committed to the safe and responsible management of hazardous waste products in our stores and distribution centers. Hazardous waste includes materials and substances which pose a hazard to the environment when improperly disposed. Burlington has a comprehensive hazardous waste program to ensure the proper disposal of these products.

Our store and distribution center associates nationwide are trained to separate and properly store hazardous and regulated materials. These materials are then collected by a third party specializing in proper disposal of these materials.

Our Strategy

We have identified and will continue to identify opportunities to address the management of our chemical footprint in light of our operations.

We have been assessing operational items with our procurement team and, over the next one to two years, will evaluate ways to reduce our chemical footprint, such as looking at customer paper sales receipts and take-away cafeteria containers. During this time, we also plan to explore implementing a Green Cleaning Policy utilizing existing standards, such as EPA Safer Choice, US Green Building Council (USGBC) LEED rating system for Indoor Environmental Guidance, Green Seal, Greenguard, etc.

Over the next several years, we will pursue opportunities to reinforce our commitment to safe products and packaging with our merchandise vendors, such as

• Assessing plastic packaging for certain private label goods and evaluating ways to eliminate or deploy safer alternatives for priority chemicals of concern in that packaging
• Assessing certain private label goods and evaluating ways to address priority chemicals of concern in these products
• Encouraging vendors to develop a chemical management strategy/policy if they do not already have one
• Collecting information regarding acceptable third-party certifications for the use of safer ingredients or environmental performance, and encouraging vendors to obtain same

We will continue to explore additional steps to better understand and appropriately address how we manage our chemical footprint in light of our operations, including exploring opportunities in our product mix, enhancing training for our merchant teams, monitoring peer and vendor approaches to chemical policies, and engaging in industry-wide collaboration. We plan to provide updates on our efforts on this web page and our annual CSR Report.

Initiatives to Reduce our Chemical Footprint

We are partnering with a third-party consultant to conduct a review of our Chemical Management Program. This includes peer benchmarking, a review of third- party certifications, and an overview of possible chemicals of concern in products.

Over the last year, we made progress in reducing our operational chemical footprint in our stores and DCs by assessing and making changes in priority operational supplies including:

• Phasing out receipt papers with phenol-based coatings (e.g., BPA, BPS, BPF, BPB, BPAF) in stores nationwide to eliminate chemicals on tape handled by store Associates and customers.
• Launching a green cleaning program by moving to certified eco-friendly cleaning products, in stores, that are third-party certified under the UL-ECOLOGO program. The products are formulated to eliminate exposure to harsher chemical ingredients by contract cleaners, Associates, and customers visiting our stores. They are not only safer for people, but they are also safer for the environment. Certified eco-friendly cleaning products were approved and rolled out to all stores by the 2022 holiday season.
• Working to eliminate all single-use plastics from our cafeterias in our NJ corporate locations. Through a partnership with the Corporate Services team and our food services provider, the Sustainability team worked to procure eco-friendly alternatives to the previously used polystyrene and plastic carryout containers as well as single use plastic utensils, straws, plates, cups, and more.