Every factory producing JCPenney exclusive brand products must be approved before they can start production. A trained factory evaluator will conduct the Legal Compliance Survey starting with a plant tour. During the tour, the factory is checked for building and fire safety to determine if enough fire extinguishers are available, emergency exits are accessible, required safety equipment is available and being used, electrical outlets, wiring and junction boxes are installed correctly, isles are clear of obstructions, sanitary rest rooms are provided, etc.

Payroll records are verified to determine if the workers receive no less than the minimum wage, work overtime hours within the legal limits, payment of overtime is properly calculated, etc.

Time cards or computer reports are verified against payroll records to ensure the payroll is correct.

Workers are interviewed in private, to verify that they are being treated fairly and not being abused or harassed.