Business and Human Rights Resource Centre

October 17, 2006

Chris Avery

Greg Regaignon

Business and Human Rights Resource Centre

235 Cucamonga Avenue

Claremont, CA 91711

Dear Chris, Greg:

Re: Wal-Mart in our Weekly Update – Invitation to respond

We appreciate the opportunity to respond to the concerns that you have highlighted regarding the factory conditions at Silver Planet Apparel Co. Ltd. “Silver Planet.”

In September 2006, Wal-Mart auditors conducted an on site audit of Silver Planet and as part of our audit process we identified violations and sought management’s commitment to rectify the violations observed. In October 2006, we revisited the factory as part of our follow-up to the audit, and we have noted the following improvements:

·  Working hours are properly recorded

·  Overtime is tracked and paid

·  Workers are compensated (paid) in accordance with Jordan’s Labor Laws

·  Excessive working hours have been addressed

·  Passports of guest workers have been released to those workers preferring to retain their own passports

Additionally, our auditors privately interviewed a representative sample of Silver Planet workers regarding the working conditions, and the workers confirmed our above findings.

Wal-Mart expands great efforts in working with our suppliers and their factory management to remediate issues of concern that we have identified in our audits. We are often asked, “Why doesn’t Wal-Mart immediately stop doing business with any factory where working conditions are substandard?” Our answer is that once we discontinue business with a particular factory, we lose our ability to influence improvement which then leads to meaningful and positive change for the workers involved. In addition, there is always a risk that if we discontinue production in a particular supplier factory, then the factory conditions may deteriorate. It is for that reason that Wal-Mart works with its suppliers and their factories to bring about positive change. Needless to say, where the factory violations are egregious, such as prison labor, Wal-Mart immediately terminates its business with the supplier factory.

The labor conditions in Jordan are complex and cannot be corrected over night; however, improvements have been observed by us. Wal-Mart is working collaboratively with other retailers and brand owners, the Government of Jordan, and the International Labor Organization to address issues of concern and to create sustainable improvements.

Regards,

Rajan Kamalanathan

Vice President of Ethical Standards