supplier name: jo y jo smeta audit type: 2–pillar...

Audit Company: SGS Bangladesh Limited Report reference: 4120742 Date: 13th October, 2016

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Supplier name: Jo Y Jo

Site country: Bangladesh

Site name: L’ Usine Fashion Ltd. (Maona)

Parent Company name (of the site): L Usine Fashion Ltd

SMETA Audit Type: 2–Pillar 4–Pillar

Date of Audit 13th October, 2016


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Audit Company Name:

SGS Bangladesh Limited

Report Owner (payee):

L’ Usine Fashion Ltd. (Maona)

Sedex Company Reference: (only available on Sedex System)

ZC 1027798

Sedex Site Reference: (only available on Sedex System)

ZS 1032499

Audit Conducted By

Commercial Purchaser

NGO Retailer

Trade Union Brand Owner

Multi–stakeholder Combined Audit (select all that apply)

Auditor Reference Number: (If applicable)

4120742

SMETA Declaration I declare that the audit underpinning the following report was conducted in accordance with SMETA best practice guidance version 5.0. Any exceptions to this are recorded here:

(1) A SMETA audit was conducted which included some or all of Labour Standards, Health & Safety, Environment and Business Ethics. The SMETA Best Practice Methodology v.5.0 Dec 2014 was applied. The scope of workers included all types at the site e.g. direct employees, agency workers, workers employed by service providers and workers provided by other contractors.

(2) The audit scope was against the following reference documents

2-Pillar SMETA Audit - ETI Base Code - SMETA Additions

o Management systems and code implementation, o Entitlement to Work & Immigration,


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o Sub-Contracting and Home working, 4-Pillar SMETA

o 2-Pillar requirements plus o Additional Pillar assessment of Environment o Additional Pillar assessment of Business Ethics

The Customer’s Supplier Code (Appendix 1)

(3) Where appropriate non-compliances were raised against the ETI code / SMETA Additions & local law and recorded as non-compliances on both the audit report, CAPR and on Sedex.

(4) Any Non-Compliance against customer code shall not be uploaded to Sedex. However, in the CAPR these

‘Variances in compliance between ETI code / SMETA Additions/ local law and customer code’ shall be noted in the observations section of the CAPR.

Any exceptions to this must be recorded here (e.g. different sample size): Auditor Name(s) (please list all including all interviewers): Mohammad Ziaur Rahman (Lead Auditor) Imran Ahmed (Member Auditor) Md. Sana Ullah Monir (Member Auditor) Interviewers - Imran Ahmed & Md. Sana Ullah Monir Date: 13

th October, 2016


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Non–Compliance Table

Issue (please click on the issue title to go direct to

the appropriate audit results by clause)

Area of Non–Conformity (Only check box when there is a non–conformity, and only in the box/es where the non–conformity

can be found)

Record the number of issues by line*:

ETI Base Code

Local Law

Additional Elements

(i.e. not part of ETI code )

NC Obs GE

0 Management systems and code implementation

1 Employment Freely Chosen

2 Freedom of Association 01

3 Safety and Hygienic Conditions 08

4 Child Labour

5 Wages and Benefits 02

6 Working Hours

7 Discrimination

8 Regular Employment

8A Sub–Contracting and Homeworking

9 Harsh or Inhumane Treatment

10A Entitlement to Work

10B2 Environment 2–Pillar

10B4 Environment 4–Pillar NA NA NA

10C Business Ethics NA NA

*Please note the table above records the total number of Non compliances (NC), Observations (Obs) and Good Examples (GE). This gives the reviewer an indication of problem areas but does not detail severities of each issue – Reviewers need to check audit results by clause.


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Summary of Findings

Summary of main findings: (positive and negative) (Please give a short summary of the main findings per clause)

Positive:

1. The factory does not engage any forced or bonded labour. In Bangladesh no prison labour are engaged outside the prison according to the law. Nothing identified during audit. Factory also does not keep any original documents from the workers, confirmed by the interviewed workers. Workers are free to leave their employer at any time giving required notices. 2. Factory treats their workers with respect and dignity; no corporal punishment, threats of violence or other forms of physical, mental, sexual, verbal harassment and abuse is practised. 3. The factory does not discriminate between workers in any manner while selection, pay, promotion and termination. Nothing identified by the documents verification and also nothing reported by the interviewed workers regarding discrimination. The pay and overtime record do not show any discriminatory incidents. 4. From the plant tour, workers interview and records review, physical verification/appearance of workers; no evidence of the use of child labour was observed. Factory checks the age before recruitment by the doctor and maintains age related documents in the workers’ personnel files. 5. First aid facility and toilet facilities have been found as per legal requirement. First aiders are well known about the first aid issues and fire fighters are well known about the operation of all fire fighting equipments and regular training is provided to them regarding this. 6. Workers are provided pure drinking water and free access on it. 7. Workers have received overtime allowance at premium rate (double of the basic). Workers are getting day off on Friday as weekly holiday. 8. All workers are provided with pay slips for each pay period which is in easily understandable language to all workers. Negative: In view of the findings raised, below non-compliances were found in the area of “Freedom of Association” “Safety and Hygienic Conditions” and “Environment” only. For other areas, no violations were noted. Freedom of Association:

1. Factory management has formed the Workers Participation Committee (WPC) selection instead of election process.

Safety and Hygienic Conditions:

1. 20% Pulley cover of linking machines found at improper position during audit working day. 1 out of 6 upper & lower pulley cover missing of auto placket machines at auto placket section.


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2 out of 2 button attached machines eye guard found at improper position with machine. 2. Workers at Jacquard section were not using ear plug during working period.

01 out of 01 ETP operator was not using necessary PPE (Mask, hand gloves, Gumboot etc.) during working period.

3. Secondary aisles were not marked in sewing section, trimming-mending section at 3rd

floor. Secondary aisles were also not marked in light checked section and trimming-mending section at 2

nd floor

4. 04 out of 04 electrician has no electrical work permit from the concerned authority. 5. Factory did not have provision for conducting periodical health check up for the workers who are working in

the hazardous areas like chemical distribution area and washing section ETP operators. 6. Facility did not identify risk of bartack, overlock and, transformer room, Gas cylinder and compressor

machine. Moreover, gas cylinder found at ground floor without any solid barrier. Facility did not provide training or communicate with the employees of boiler and generator machine on their work place and machine related risk.

7. 2 out of 2 first aid box located in the production floor did not have sufficient instruments as per law. In additional no designated first aider found for 1

st floor Jacquard section for day shift.

8. Factory has no accident / injury investigation system to find out the root cause of each accident/injury to take preventive or corrective action to prevent re-occurrence of same type of accidents.

Observation: Nil Good example:

1. Factory provides attendance bonus BDT. 300 for all. 2. Factory provides production bonus to the piece rate workers based on production amount.


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Audit Details

Audit Details

A: Report #: 4120742

B: Time in and time out (SMETA Best Practice Guidance and Measurement Criteria recommends 9.00–17.00 hrs. if any different please state why in the SMETA declaration )

Day 1 Time in: 9.55 am Day 1 Time out:5.30 pm

Day 2 Time in: NA Day 2 Time out: NA

Day 3 Time in: NA Day 3 Time out: NA

C: Number of Auditor Days Used: (number of auditor x number of days)

03 Auditors in 01 day

D: Audit type:

Full Initial Periodic Full Follow-up Partial Follow-Up Partial Other - Define

E: Was the audit announced? (AAG recommends a window of three weeks for semi–announced, this gives optimum results)

Announced Semi – announced: Window detail: 4 weeks Unannounced

F: Was the Sedex SAQ available for review?

Yes No

If No, why not? (Examples would be, site has not completed SAQ, site has not been asked to complete the SAQ.)

Not Applicable

G: Any conflicting information SAQ/Pre-Audit Info to Audit findings?

Yes No

If Yes, please capture detail in appropriate audit by clause

H: Auditor name(s) and role(s): Mohammad Ziaur Rahman (Lead Auditor) Imran Ahmed (Member Auditor) Md. Sana Ullah Monir (Member Auditor)

I: Report written by: Md. Sana Ullah Monir

J: Report reviewed by: Kanika Sarkar

K: Report issue date: 23rd

October, 2016

L: Supplier name: Jo Y Jo

M: Site name: L’ Usine Fashion Ltd. (Maona)


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N: Site country: Bangladesh

O: Site contact and job title: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance)

P: Site address: (Please include full address)

Kawya, Chonnapara, Sreepur, Gazipur, Bangladesh

Site phone: Cell: 01755607664

Site fax: +88-02-9816126

Site e–mail: [email protected]

Q: Applicable business and other legally required licence numbers: for example, business license no, and liability insurance

Trade License No: 109/2016-2017, issued by Sreepur Municipality which is valid till June 30, 2017. Factory License No: 17518/Gazipur & Category “I” issued by Bangladesh Government Authority which is valid till June 30, 2017. Fire License No: DD/Dhaka/25083/2015, issued by Bangladesh Fire Service & Civil Defence Authority which is valid till June 30, 2017.

R: Products/Activities at site, for example, garment manufacture, electricals, toys, grower

Garment manufacture (Sweater Items )

S: Audit results reviewed with site management?

Yes

T: Who signed and agreed CAPR (Name and job title)

Mr. Md. Sazzad Hossain, Asst. Manager (Compliance)

U: Did the person who signed the CAPR have authority to implement changes?

Yes

V: Present at closing meeting (Please state name and position, including any workers/union reps/worker reps):

Factory– L’ Usine Fashion Ltd. (Maona) Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Mr. Biddut Das, Asst. Manager ( HR & Admin) Mr. Mrinal Kanti Podder, Jr. Executive- Compliance Mr. Md. Monjurul Alam- Member of WPC Ms. Dipali- Member of WPC

W: What form of worker representation / union is there on site?

Union (name) Worker Committee Other (specify) None

X: Are any workers covered by Collective Bargaining Agreement (CBA)

Yes No

Y: Previous audit date: 25th November, 2015

Z: Previous audit type: SMETA 2– SMETA 4– Other


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pillar pillar

Full Initial

Periodic

Full Follow–Up Audit

Partial Follow–Up

Partial Other*

*If other, please define: Not applicable


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Audit Scope/Actual Results

Criteria Local Law (Please state legal requirement)

Actual at the Site

(Record site results against

the law)

Is this part of a

Collective Bargaining Agreement

?

A: Standard/Contracted work hours: (Maximum legal and actual required working hours excluding overtime, please state if possible per day, week and month)

Legal maximum: 8 hours per day and 48 hours per week

8 hours/ day 48 hours/ week

Yes No

NA

B: Legal Overtime hours: (Maximum legal and actual overtime hours, please state if possible per day, week and month)

Legal maximum: 2 hours per day and 12 hours per week. However, an adult worker may work for more than 8 (eight) hours in a day or 48 (forty-eight) hours in a week, provided that the total hours of work of an adult worker shall not exceed 60 (sixty) hours in any week and on the average 56 (fifty-six) hours per week in any year. Exception for 6 months; Government has exempted section 100 and 102 of the Bangladesh Labour Law-2006 publishing a Gazette notification in August 2011 as per section 324 Bangladesh Labour Law-2006 for 06 months relaxing daily overtime hours. In accordance with the Clause/Condition No. – 3 of this notification, no worker shall work more than 04 hours of overtime in any day without his/her consent.

This exemption has been extended several times

in last few years and latest extension was on

October 22, 2015 and it will be in effect from 17

April, 2015 to 16 October, 2016.

Maximum 4 hours/ day and 24 hours per week

Yes No

NA

C: Legal age of employment: (Minimum legal and actual minimum age at site)

Legal minimum: 14 years 20 Years

D: Legal minimum wage for standard/contracted hours: (Minimum legal and actual minimum wage at site, please state if possible per hr, day, week and month)

As per S.R.O. Act N-369/2013-Bangladesh Labour law 2006 section: 140(1) published on 5

th

December, 2013, the minimum wages, other benefits and conditions of service for the workers of the Garments sector. BDT. 5,300 per month (Basic BDT. 3000, House

BDT. 5300/ month (For Garments Division)

Yes No

NA


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rent 40% of the Basic which is BDT. 1,200, Medical allowance BDT. 250, Food allowance BDT. 650 & Transportation Allowance BDT. 200).

E: Legal minimum overtime wage: (Minimum legal and actual minimum overtime wage at site, please state if possible per hr ,day, week and month)

Legal minimum: 200% of the basic wage rate per hour

200% of the basic wage rate per hour

Yes No

NA

Audit Scope (Please select the code and additional requirements that were audited against during this audit)

2–Pillar Audit

10B4: Environment 4–Pillar

10C: Business Ethics

All groups of workers are included in the scope of this audit such as; Direct employees, Casual and agency workers, Workers employed by service providers such as security and catering staff as well as workers supplied by other contractors.

Note: The main focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in such depth or scope, but the audit process will still highlight any specific issues. This report provides a summary of the findings and other applicable information found/gathered during the social audit conducted on the above date only and does not officially confirm or certify compliance with any legal regulations or industry standards. The social audit process requires that information be gathered and considered from records review, worker interviews, management interviews and visual observation. More information is gathered during the social audit process than is provided here. The audit process is a sampling exercise only and does not guarantee that the audited site prior, during or post–audit, are in full compliance with the Code being audited against. The provisions of this Code constitute minimum and not maximum standards and this Code should not be used to prevent companies from exceeding these standards. Companies applying this Code are expected to comply with national and other applicable laws and where the provisions of law and this Code address the same subject, to apply that provision which affords the greater protection. The ownership of this report remains with the party who has paid for the audit. Release permission must be provided by the owner prior to release to any third parties.


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Audit Overview

Audit Overview

Management Worker Representatives

Audit attendance Senior management Worker Committee representatives

Union representatives

A: Present at the opening meeting? Yes No Yes No Yes No

B: Present at the audit? Yes No Yes No Yes No

C: Present at the closing meeting? Yes No Yes No Yes No

D: If Worker Representatives were not present please explain reasons why (only complete if no worker reps present)

N/A

E: If Union Representatives were not present please explain reasons why: (only complete if no union reps present)

In Bangladesh there is no obligation to join trade union and freedom of association and collective bargaining. For an establishment where there is no trade union, until a trade union is formed, the workers ’representatives to the Participation Committee shall run activities related to workers’ interests in the establishment concerned and workers representative should be elected by direct vote of workers (amendment 22

nd of July 2013, Labor Law 2006)

F: Site description: (Include size, location and age of site. Also include structure and number of buildings)

L’ Usine Fashion Ltd. (Maona) was established in 2008 and located at Kawya, Chonnapara, Sreepur, Gazipur, Bangladesh. The total land area of the factory is about 80000 square feet and factory has occupied 90,000 square feet area for production purpose. Factory is engaged in the manufacturing of sweater items with the wearhouse capacity of 25000 square feet area. Currently factory management is using 03 buildings and 02 shed for factory purpose. Details building description is given below-

Building no 1 (06 storied building)

Description

Remark, if any

Ground floor Knitting section, Washing section, Programmer room, Needle Distribution room

Nil

1st

floor Distribution room, Knitting section, Accessories store, Maintenance room, MIS room, Yarn controller room

Nil

2nd

floor Linking section, Trimming section, Mending section, Knitting section, Inspection room, Needle distribution

Nil


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room. 3

rd floor Sewing section, Iron section, Get up

section, Packing section, Spot removing room, Inspection room, Office room and IPE room

Nil

4th

floor Dining hall, Office room, Prayer room, Training room, Finished carton area, Inspection room, Idle machine room.

Nil

5th

floor Winding room, Auto placket room and Roof top (90% vacant)

Nil

Is this a shared building?

No Nil


Description

Remark, if any

Ground floor Reception, Day care room, Doctor & Nurse room

Nil

1st

floor Fire control panel room, Medical room Nil Roof top Totally vacant Nil Is this a shared building?

No Nil


Description

Remark, if any

Ground floor Generator room, Boiler room, Transformer room

Nil

Is this a shared building?

No Nil

Shed 01 is single storied and used as underground water reservoir and pump house. Shed 02 is used as Wastage room Shed 03 is used as ETP (Effluent Treatment Plant) Currently 998 employees are working in the factory including management. Among them 613 are male and 385 are female. In general, the employees work for 6 days in a week (Saturday to Thursday). Friday is weekly holiday. The regular working hour shift of the factory starts from 08:00 am to 05:00 pm including one hour lunch break from 01.00 pm to 02.00 pm. There are 02 shifts for Jacquard section: Shift A-08:00 am to 05:00 pm (including one hour lunch break from 01:00 pm to 02:00 pm) and shift B-: 08:00 pm to 05:00 am (including one hour comfortable break). The factory’s wage calculation period is from 1

st to 30

th/31

st of every month and factory management


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is paying wages within 7th working days after completion of the wage

period. Factory is paying monthly salary in local currency to all the employees. The factory‘s wage period is seventh working day of the following month. Time keeper and HR department are responsible for keeping the daily attendance. Note: The factory management follows “The Minimum wage Gazette Notification for RMG sector” that has published on 5th December, 2013 for garments division (cutting, printing, sewing, washing & finishing).

G: Site function: Agent Factory Processing/Manufacturer Finished Product Supplier Grower Homeworker Labour Provider Pack House Primary Producer Service Provider Sub–Contractor

H: Month(s) of peak season: (if applicable)

March to November as reported by factory management

I: Process overview: (Include products being produced, main operations, number of production lines, main equipment used)

Product: Garments Manufacturer – Sweater items Process: Winding>Knitting (Jacquard)>Linking>Trimming>Mending>Washing>Iron>PQC>Packing Equipment: Auto knitting (Jacquard) machine, Linking machine, pressing machine, boiler, generator etc.

J: Attitude of workers: (Include their attitude to management, workplace and the interview process. Both positive and negative information should be included) Note: Do not document any information that could put workers at risk

Auditors selected workers randomly from different section based on religion, caste, age and gender for interview. All of them are aware about their working hour, compensation & other benefits. Nobody feel uncomfortable & anxious during interview. They are satisfied to do work in this facility. Individual and group interview were conducted in a private place without the presence of any representative from the management. Workers are satisfied with general housekeeping of the factory in the production area. It was also noted through interview with workers that factory management is very co operative in solving their work place related issues in time. Workers are satisfied with factory’s grievance handling procedures. Further, auditors were also informed by the workers that factory does not discriminate between workers in any manner while pay or promotion or training. Factory treats all of them equally and with respect and dignity. No evidence of corporal punishment, threats of violence or other forms of physical, mental, sexual, verbal harassment and abuse was found. Factory pays their wages in time. Factory has given equal opportunity to work overtime. Overtime is voluntary. Workers stated that there are several


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channels of communication with management in this factory. No negative comment was received. Total 42 employees selected for interview. Among them 12 employees were selected for individual interview and total 30 employees in 6 groups were selected for the group interview, all the interviewees were favourable with the management.

K: Attitude of workers committee/union reps: (Include their attitude to management, workplace and the interview process. Both positive and negative information should be included) Note: Do not document any information that could put workers at risk

Workers committee representatives were comfortable with management, workplace and interview process. During opening meeting committee representatives were present and auditors clearly explained them about the audit, audit process, necessity of audit and audit criteria in local language. In the period of interview with workers committee representatives discussed their feelings to the auditors without any hesitation and confusion.

L: Attitude of managers: (Include attitude to audit, and audit process. Both positive and negative information should be included)

Management of the factory was positive and supportive during the whole audit. Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) was the key person of the compliance team and he was responsible for compliance with the Code, legal requirements, development of policies and its implementation, monitoring & control. In this backdrop, management had comprehensive knowledge, as assumed, about audit requirements and scope; e.g. ETI based code, local laws etc. The factory management was receptive, positive and extended their full co-operation throughout the audit. They made all documents readily available & in time for auditor’s verification.

Key Information

Key Information (click on the key information title to go to appropriate section of the report)

A: Do all workers (including migrant workers) have contracts of employment/employment agreements? (Go to clause 8 – Regular Employment)

Yes No

B: Are maximum standard/contracted working hours clearly defined in contract/employment agreements? (Go to clause 8 – Regular Employment)

Yes No

C: Were appropriate records available to verify hours of work and wages? (Go to clause 5 – Living Wage)

Yes No

D: Were any inconsistencies found? (if yes describe nature)

Yes Poor record keeping No Isolated incident


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(Go to Wages Table) Repeated occurrence

E: For the lowest paid production workers, are wages paid for standard/contracted hours (excluding overtime) below or above the legal minimum? (Go to clause 5 – Living Wage)

Wages found: Please indicate the breakdown of workforce according to earnings:

Below legal min Meet Above

00% of workforce earning under min wage 10 % of workforce earning min wage 90 % of workforce earning above min wage

F: % of piece rate workers: (if applicable)

45% workers are piece rated

G: Do the standard/contracted hours stated in a contract/employment agreement exceed the law or 48 hours per week? (Go to clause 6 – Working hours)

Yes No

H: If yes, what are the standard/contracted hours per week as stated in the contract/employment agreement? (Go to clause 6 – Working hours)

_____ hrs/week NA

Approx. ____% of All workers on these contacted hours NA

I: Combined hours (standard/contracted plus overtime = total hours) over 60 per week found? (Go to Working Hours Analysis)

Yes No

J: Are workers provided with 1 day off in every 7-day-period, or 2 in 14-day-period (where the law allows)?

Yes No

If ‘No’, please explain:

K: Are the correct legal overtime premiums paid? (Go to Wages Table)

Yes No N/A

Note: Factory has a policy to provide OT premium as per law and workers were aware about it.

L: Please state what actual OT is paid. (As a percentage of the workers standard rate) (Go to Working Hours Analysis)

Please give details of overtime premium as a % of standard wages: 0% 1% – 115% 116% – 124% 125% – 149% 150% – 199% 200%+

Please give details: Note: Workers who worked overtime were provided OT premium as per law and workers were aware about it.

M: Is there any night production work at the site?

Yes No

There are 02 shifts for Jacquard section: Shift A-08:00 am to 05:00 pm (including one hour lunch break from 01:00 pm to 02:00 pm) and shift B-: 08:00 pm to 05:00 am (including one hour comfortable break).


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N: % of workers living in site provided accommodation (if applicable):

N/A Factory does not provide any living accommodation for the workers as all workers live in nearby areas and there is no legal requirement as well.

O: Age of youngest worker found: (Go to clause 4 – Child labour)

20 years

P: Workers under 18 subject to hazardous work assignments? (Go to clause 3 – Health and Safety)

Yes No

No hazardous work found through the work process and no under 18’s worker observed.

% of under 18’s at this site (of total workers) 0%

Q: What form of worker representation/union is there on site? (Go to clause 2 – Freedom of Association)

Union (name) Worker Committee Other (specify) None

R: Is it a legal requirement to have a union? (Go to clause 2 – Freedom of Association)

Yes No

S: Is It a legal requirement to have a workers committee? (Go to clause 2 – Freedom of Association)

Yes No

For an establishment where there is no trade union, until a trade union is formed, the workers’ representatives to the Participation Committee shall run activities related to workers’ interests in the establishment concerned.

T: Is there any other form of effective worker/management communication channel? (Other than union/worker committee) (Go to clause 2 – Freedom of Association)

Yes No

Describe: The factory has provided suggestion & complaint box in the toilet area through which workers can give their suggestion / complaints if any. Workers can also approach the management directly for any grievances. The dropped suggestion or complaints is maintained by the factory management in a register so that they can take action accordingly.

U: Are there any External Processes? (Go to clause 8A – Sub–contracting and Home working)

Sub–Contracting Home working Other External Process No external processes

Management Systems

Management Systems:

A: Nationality of Management Bangladeshi


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B: Gender breakdown of Management + Supervisors (Include as one combined group)

Male: 70.17% Female: 29.83%

C: Majority nationality of workers 100% Bangladeshi

D: Number of workers leaving in last 12 months as a % of average total number of workers on site over the year (annual worker turnover)

03%

E: Were accurate records shown at the first request?

Yes No

F: If No, why not? NA

G: In the last 12 months, has the site been subject to any fines/prosecutions for non–compliance to any regulations?

Yes No

Please describe: NA

H: Do policies and/or procedures exist that reduce the risk of forced labour, child labour, discrimination, harassment & abuse?

Yes No

Please describe: Factory has precise a policy on force labour, child labour, discrimination, harassment and abuse. Factory management has posted all the policies in their notice board. During interview with the workers, it was found that they were aware about all the policies of the factory. No complain was noted regarding those issues from the workers end. Factory management regularly conducts internal meeting with the mid level management regarding basic compliance issues. Also during mid level management interview it was found that mid level management were aware regarding forced labour, child labour, discrimination, harassment & abuse.

I: If Yes, is there evidence (an indication) of effective implementation? Please give details.

Factory has communicated policy and procedures on risk of forced labour, child labour, discrimination and harassment & abuse with the workers through training program and also posted those policies in the notice board. No complain found from interviewed workers too. During interview, workers informed that management does not deposit employees ID card. Workers are free to leave the factory on time, workers have to provide age proof during recruitment process and factory management treat all workers equally. Workers are aware of disciplinary procedure of factory.

J: Have managers and workers received training in the standards for forced labour, child labour, discrimination, harassment & abuse?

Yes No

Please describe: Factory has communicated policy and procedures on risk of forced labour, child labour, discrimination and harassment & abuse with the workers including mid-level managers (e.g. supervisors, in charge, compliance executive etc) through training program and also posted those policies in the notice board. Both management and workers were aware about it. Last Training was provided on September 04, 2016 where participants were 25.


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K: If Yes, is there evidence (an indication) that training has been effective e.g. training records etc.? Please give details

Managers and workers have received training on the standards for forced labour, child labour, discrimination, harassment & abuse and factory preserved training records as evidence. Mid level management and workers are aware and known about the disciplinary policy and procedure of the company as well as the law. Regular training provided to the workers and mid level management regarding this. Last Training was provided on September 04, 2016 where participants were 25.

L: Are there published, anonymous and/or open channels available for reporting any violations of Labour standards and H&S or any other grievances to a 3

rd party?

Yes No

Please describe: There is an open channels for all at the factory which anybody can report to management about any act improperly or corruptly, or to accept or give a bribe or gift and health & safety issues. Factory management has placed grievance and suggestion box in the factory. Also they are maintaining grievance register to know and solve the problem.

M: If Yes, are workers aware of these channels? Please give details.

Facility has communicated this procedure through orientation training confirmed from worker interview. Last training was conducted on September 29, 2016 where participants were 19.

N: Have health and safety risks been identified e.g. through internal audits, formal risk analysis process, worker involvement etc.?

Yes No

Please describe: The factory management has conducted a formal risk analysis process of the production floor and also posted in the production floor. The factory management has conducted internal audits to find out the health and safety risks of the production floor. Last internal audit was conducted on July 23, 2016.

O: If Yes, has effective action been taken to reduce or eliminate these risks?

Factory has a system to analyze the findings of internal audit to take corrective and preventive action and preserves records. Last Risk Assessment conducted date was June 11, 2016.

P: Are accidents recorded? Yes No

Please describe: Factory maintains accident and injury register to analyze the root cause of injury and take corrective action. Moreover, company doctor and nurse are responsible for prepared to the injury analysis as well as minor injury/accidents register.

Q: Has the auditor made a simple calculation to compare capacity with workers’ work load in order to identify possible unrecorded work hours?

Yes No

Please describe: Factory has proper capacity planning to manage working hours within legal limit. During the audit time, auditors were verified capacity planning records, daily production records (different departments) against present manpower and equipments to assess whether any possibility of unrecorded working hours or not.

R: Does the site have all required land rights licenses and permissions (see SMETA

Yes, factory has all required licences available in the factory from the right authority.


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Measurement Criteria)? Trade License No: 109/2016-2017, issued by Sreepur Municipality which is valid till June 30, 2017. Factory License No: 17518/Gazipur & Category “I” issued by Bangladesh Government Authority which is valid till June 30, 2017. Fire License No: DD/Dhaka/25083/2015, issued by Bangladesh Fire Service & Civil Defence Authority which is valid till June 30, 2017.

S; Does the site have any internationally recognised system certifications e.g. ISO 9000, 14000, OHSAS 18000, SA8000 (or other social audits). Please detail (Number and date).

Nil

T: Is there a Human Resources manager/department? If Yes, please detail.

Yes No

Please describe: Facility has an independent Human Resources Department and Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) is responsible for this department.

Worker Analysis

Worker Analysis

Local Migrant Total

Permanent Temporary Agency Permanent Temporary Agency Home

workers

Worker numbers – male

613 (including

management)

0 0 0 0 0 0 613 (including

management)

Worker numbers –female

385 (including

management)

0 0 0 0 0 0 385 (including

management)

Total 998 (including management)

0 0 0 0 0 0 998 (including management)

Number of Workers interviewed

42 0 0 0 0 0 0 42


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Contractors: (Individuals supplying workers to site with the workers paid by contractors, not by site)

A: Any contractors on site? Yes No

B: If Yes, how many workers supplied by contractors

NA

C: Are all contractor workers paid according to law?

Yes No

NA

If Yes, Please give evidence for contractor workers being paid according to law:

NA

Migrant Workers: (Please see SMETA Best Practice Guidance and Measurement Criteria for definitions of migrant workers)

D: Originating Locations/Countries:

NA, No migrant workers employed by the factory.

E: Type of work undertaken by migrant workers :


F: Were migrant workers recruited through an agency? If yes, please give details.

Yes No

Please describe: NA, No migrant workers employed by the factory

If Yes, is there a contract with the agency? Provide details of agencies and contractual arrangements including any fees lodged during the recruitment process.


G: Does the site have a system for checking labour standards of agencies? If yes, please give details.

Yes No

Please describe: NA, No migrant workers employed by the factory.

H: Percentage of migrant workers in company provided accommodation:


Audit Results by Clause

0: Management systems and Code Implementation

0: Managements system and Code Implementation (click here to return to NC Table)


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0.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code. 0.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with the Code. 0.3 Suppliers are expected to communicate this Code to all employees. 0.4 Suppliers should communicate this code to their own suppliers and, where reasonably practicable, extend the principles of this Ethical Code through their supply chain.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant

procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems:

1. The factory implements and maintains systems for delivering compliance to this Code. 2. Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) is responsible for compliance with the Code.

The factory communicates their code of conduct through training program and notice board regularly including company’s own COC. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Facility Management Interview. 2. Document review. 3. Workers Interview. 4. Facility tour

Non–compliance:

Description of non–compliance: NC against ETI NC against Local Law:

No non compliance was observed on the audit day. Local law and/or ETI requirement Not applicable Recommended corrective action: Not applicable

Objective evidence observed: Not applicable

Observation:

Description of observation: None Observed Local law or ETI requirement: Not applicable



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Comments: Not applicable

Good Examples observed:

Description of Good Example (GE): None Observed


1: Employment is Freely Chosen (Click here to return to NC–table)

ETI 1.1 There is no forced, bonded or involuntary prison labour. 1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to

support the systems.

Current systems: Written policy and procedures are in place to ensure employment is freely chosen. The policy includes the following clause: The factory established a policy to ensure employment is freely chosen. The policy includes the following clause: 1. The factory does not hold any original certificate, experience certificate or any identity papers. The factory maintains photocopies of all hiring documents such as birth certificate, school leaving certificates, fitness certificate by registered doctor etc. 2. The factory does not limit the workers’ freedom. Workers are free to leave the work place and manage their own time while not on duty. If workers choose to quit their job, they are free to do so, as long as they fulfil their obligations agreed under their appointment letter/agreement.


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3. The factory has displayed overtime policy stating that over time work is voluntary. In case of need of actual work pressure, workers are asked and requested to work on voluntary basis except as required to meet urgent business needs. There are no records of such urgent business needs identified during the audit. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Policy documents 2. Worker interviews 3. Personnel files 4. Contracts to establish notice periods 5. Security guard job description

Non–compliance:

Description of non–compliance: NC against ETI NC against Local Law:

No non compliance was observed on the audit day. Local law and/or ETI requirement Not applicable Recommended corrective action: Not applicable


Observation:

Description of observation: None Observed Local law or ETI requirement: Not applicable Comments: Not applicable






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Collective Bargaining are

2: Freedom of Association and Right to Collective Bargaining are Respected (Click here to return to NC–table)

(Click here to return to Key Information)

ETI 2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. 2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities. 2.3 Workers’ representatives are not discriminated against and have access to carry out their representative functions in the workplace. 2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.



Current systems: 1. Workers can raise their concerns through workers’ representatives, complaint box, meeting and their team leader or above. 1. Verified and confirmed through records review and interview process that the facility does not discriminate any of the workers such as workers representatives also. 1. Factory has a policy where is no restriction imposing to the workers formation of trade union. 1. Workers without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. There are no restrictions by the factory or factory management to join the workers in union and to bargain collectively. The factory does not discriminate against workers who wish to join or to form the union. Factory has formed a Workers Participation Committee (WPC) as a parallel means through selection basis instead of election and arrange regular meeting in every 02 months. Last meeting of the WPC meeting was held on August 29, 2016. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Facility management interview 2. Worker interview 3. Complaint box register (Suggestions from the complain box and actions taken) 4. Workers Participation Committee formation record review and WPC meeting records review. 5. Grievance handling policy & procedure

Non–compliance:

Issue title: WPC was found selection instead of election Description of non–compliance:

Objective evidence observed:


26

NC against ETI NC against Local Law: It was noted through documents review, employee and management interview that the factory management has formed the Workers Participation Committee (WPC) selection instead of election. Local law and/or ETI requirement In accordance with section 205(6) of Bangladesh Labor law, 2013 (Amendment) published in July 22, 2013: 205(6): In an establishment where there is no trade union, representative of the workers in the Participation Committee of such establishment shall be elected in the manner prescribed by rules from amongst the workers engaged in the establishment. Recommended corrective action: It is recommended that the factory management should form the WPC (Workers Participation Committee) by election process as per law. Action By: Mr. Md. Sazzad Hossain-Assistant Manager, Compliance Time frame: 60 Days (Follow up)

Management & workers Interview and Document review.

Observation:



A: Name of union and union representative, if applicable:

NA; This is a non-unionized factory.

Is there evidence of free elections? Yes No N/A

B: If no union what is parallel means of consultation with workers e.g. worker committees?

Workers Participation Committee (WPC) has formed as a parallel means.

Is there evidence of free elections? Yes No N/A

C: Were worker representatives/union representatives interviewed

Yes No If Yes, please state how many: 02 members

1. Mr. Md. Monjurul Alam- Member of WPC 2. Ms. Dipali- Member of WPC

D: State any evidence that union/workers committee is effective? Specify date of last meeting; topics covered; how minutes were communicated etc.

1. Participation Committee (PC)) has formed through selection. 2. Last PC meetings held on August 29, 2016. 3. PC meeting minutes recorded and action taken.


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The topics covered in the WPC meeting are as follow:

I. Discussion about Eid ul Adha holiday. II. Discussion about disbursement of Eid ul Adha salary.

III. Discussion about Eid ul Adha bonus.

E: Are any workers covered by Collective Bargaining Agreement (CBA)

Yes No NA, as there is no trade union in the factory.

F: If Yes what percentage by trade Union/worker representation

__0__% workers covered by Union CBA

__0__% workers covered by worker rep CBA

G: If Yes, does the Collective Bargaining Agreement (CBA) include rates of pay

Yes No

NA




3: Working Conditions are Safe and Hygienic (Click here to return to NC–table)


ETI 3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment. 3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be repeated for new or reassigned workers. 3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. 3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers. 3.5 The company observing the code shall assign responsibility for Health & Safety to a senior management representative.



Current systems:


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Through factory tour, it was noted that:

1. Factory maintained a comfortable temperature throughout work floors. The factory maintained a comfortable temperature throughout work floors.

2. The factory posted the evacuation plans on work floors, which indicated escape routes and the location of the fire extinguishers.

3. Exit signs were found illuminated and emergency lights were installed with IPS back up. In addition, factory has also industrial graded emergency light in factory premises.

4. First aid training conducted on regular basis. The last first aid training was conducted on August 17, 2016 where the number of participants from different section was 17. First aid boxes were provided in the different floors and sections with sufficient stocks. There are total 12 numbers of first aid boxes in the factory. Currently 24 numbers of first aiders are available in the factory. First aid team was found aware & adequately trained on first aid issues.

5. Fire fighting training provided as per law. Last fire fighting training provided on September 27, 2016 where participants were 40. The factory has trained 213 fire fighters from Internally, BGMEA (Bangladesh Garments Manufacturers & Exporters Association) and Bangladesh Fire Service & Civil Defence.

6. Factory management conducts fire drill ensuring the presence of all workers on monthly basis. Last day fire drill was conducted on August 29, 2016 where total 975 persons were attended and last night fire drill was conducted on April 25, 2016 where total 109 persons were attended

7. Personal Protective Equipment (PPE) training conducted on regular basis. The last Personal Protective Equipment (PPE) training was conducted on July 07, 2016 where the numbers of participant from different section were 28.

8. Doctor room and child care room available in the factory for their employees. 9. Sufficient clean toilets segregated by gender were available at all times to workers. Currently, factory has

26 toilets for male and 30 toilets for female which is sufficient as per the requirement. 10. Pure drinking water facility was available at each floor with easy access. 11. All interviewed workers were aware about the evacuation procedure during working time. 12. Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) is responsible to look after the health and safety

issues.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Plant tour 2. Document review (Training record review, injury register, fire drill register, fire equipments checking list and

register). 3. Facility management interview 4. Worker interview

Non–compliance:

1. Issue title: Insufficient machine safety. Description of non–compliance:

NC against ETI NC against Local Law Following machine safety related issues were noted during site tour: Around 20% pulley cover of linking machines found at improper position during working. 1 out of 6 upper & lower pulley cover missing of auto placket machines at auto placket

Objective evidence observed: Plant tour Image no: 1, 2 & 3


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section. 2 out of 2 button attached machines eye guard found at improper position with machine. Local law and/or ETI requirement: In accordance with Bangladesh Labour Law 2006, section 63 “(1) In every establishment the following shall be securely fenced by the safeguards of substantial construction which shall be kept in position while the part of machinery required to be fenced are in mention or in use, namely- (a) every moving part of a prime mover, and every fly wheel connected to a prime mover; (b) the head-race and tail-race of every water wheel and water turbine; (c) any part of a stock-bar which projects beyond the head stock of a lathe; and (d) unless they are in such position or of such construction as to be as safe to every person employed in the establishment as they would be if they were securely fenced- (i) every part of an electric generator,- a motor or rotary converter, (ii) every part of transmission machinery, and (iii) every dangerous part of any machinery:” Recommended corrective action: It is recommended that factory should ensure proper safety measures for the mentioned areas. Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 30 Days (Desktop). 2. Issue title: Workers were not using sufficient PPE. Description of non–compliance:

NC against ETI NC against Local Law During plant tour following PPE related issues were noted: Approx 40% workers at Jacquard section were not using ear plug during working period. 01 out of 01 ETP operator was not using necessary PPE (Mask, hand gloves, Gumboot etc.) during working period. Local law and/or ETI requirement: In accordance with ETI Base Code 3.1 and Bangladesh Labour (Amendment) Law-2013, section-78(a-1). In accordance with Bangladesh Labour (amendment) Law 2013, Section 78 (1-a): “(1) In an applicable case, an employer shall not engage any workers in work without providing and ensuring use of personal safety equipment, and in doing so, a record book shall be maintained as designated by the owner.” In accordance with ETI Base Code 3.1: A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the


Plant tour Image no: 4 & 5


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causes of hazards inherent in the working environment. Recommended corrective action: It is recommended that the factory should ensure the awareness level for the use of PPE in all respective areas. Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 30 Days (Desktop). 3. Issue title: Insufficient aisle marking.

Description of non–compliance:

NC against ETI NC against Local Law Following aisle/passage related issues were identified during plant tour Secondary aisles were not marked in sewing section, trimming-mending section at 3

rd

floor. Secondary aisles were not marked in light checked section and trimming-mending section at 2

nd floor.

Note: Management stated that they will mark the mentioned area’s aisles after complete the floor setup. Local law and/or ETI requirement: In accordance with the Bangladesh Labor Law 2006, section-62(4): (4) In every establishment every window, door, or other exit affording means of escape in case of fire, other than the means of exit in ordinary use, shall be distinctively marked in Bangla and in red letters of adequate size or by some other effective and clearly understood sign. Recommended corrective action: It is recommended that factory management should mark aisle of the mentioned areas. Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 30 days (Desktop). 4. Issue title: Electrician’s work-permit missing. Description of non–compliance:

NC against ETI NC against Local Law It was noted through document review, electrician and management interview that the 04 out of 04 electrician has no electrical work permit from the concerned authority. However, facility has applied to the concerned authority on 19 April, 2016 Note: Facility has two shifts for Jacquard section.


Plant tour Image no: 6 & 7 Objective evidence observed:

Document review


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Local law and/or ETI requirement:

In accordance with Electricity Rules 1937, Rule no-48:

No electrical installation work, including additions, alterations, repairs and adjustments to existing installations, except such replacement of lamps, fans, fuses, switches and other component parts of the installation as in no way alter its capacity or character, shall be carried out upon the premises or on behalf of any consumer or owner for the purpose of the supply of energy to such consumer or owner except by an electrical contractor licensed by the provincial Government in this behalf and under the direct supervision of a person holding a certificate of competency issued by the provincial Government.

Recommended corrective action:

It is recommended that the factory management should obtain electrical work permit from the concerned authority.

Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 60 days (Desktop). 5. Issue title: No health check up found for the workers who are working in the hazardous areas. Description of non–compliance:

NC against ETI NC against Local Law

Factory did not have provision for conducting periodical health check up for the workers who are working in the hazardous areas like chemical distribution area and washing section ETP operators. Local law and/or ETI requirement: In accordance with ETI Base Code 3.1 and Bangladesh Labour Rules, 2015, Rules: 68(5): In accordance with the ETI base code 3.1 “A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.” Bangladesh Labour Rules, 2015, Rules: 68(5): The owner must receive the physical fitness certificate of each worker mentioned in Sub-section (4), which has to be certified by a registered Physician, at least once a year. Recommended corrective action:


Document review and management interview.


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It is recommended that factory management should take initiative for health check up. Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 60 days (Desktop). 6. Issue title: Insufficient risk assessment and related training. Description of non–compliance:


Based on site tour and management interview, following issues were noted: Facility did not identify risk of bartack, overlock and, transformer room, Gas cylinder and compressor machine. Moreover, gas cylinder found at ground floor without any solid barrier. Facility did not provide training or communicate with the employees of boiler and generator machine on their work place and machine related risk. Local law and/or ETI requirement: In accordance with ETI Base code 3.1 and Bangladesh Labor Law, 2006 (amendment 2013) of section- 78(a-3): In accordance with the ETI base code 3.1 “A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.” In accordance with Bangladesh Labour Law-2006 (amendment 2013), section- 78(a-3) “For ensuring professional health and safety for workers at workplace, each of workers shall have to be aware on the risk of the work through trainings.” Recommended corrective action: It is recommended that factory should conduct risk assessment in mentioned areas, and take actions to eliminate the risks identified. Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 30 days (Desktop). 7. Issue title: Insufficient first aid kits in first aid box Description of non–compliance:


It was noted during plant tour that 2 out of 2 first aid box located in the production floor did not have sufficient instruments as per law. Note that, the factory had kept only bandage, savlon, povisep and cotton in the first aid box. In additional no designated first aider found for 1

st floor Jacquard section for day shift.


Document review and management interview and plant tour . Picture-8


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Local law and/or ETI requirement: In accordance Bangladesh Labour Rules-2015, Rule 76 (1) (2): 1) As per Section 89(1), At least a Primary Aid Box or Cupboard/Almirah must be there in each department, section and floor. The box or cupboard must be marked with Red Crescent or Cross symbol. In addition, there shall be additional equipments as per the description of sub-section 2, 3 and 4 mentioned below, basing on the number of workers or employees. 2) If the number of workers/employees is not more than 10 in the concerned institute, department, section and floor where mechanical power is used or if the number of workers/employees is not more than 50 in the workplace where mechanical power is not used, the following equipments must be each cupboard or almirah of those workplaces: a) 6 small sterile bandages; b) 3 packets of disinfected cotton, weighing 0.5 ounce each; c) 3 medium sized disinfected bandages; d) 3 large sized sterile bandages; e) 3 large sized sterile bandages that are used in case of burns; f) 1 bottle of Hibisol or Hexasol, weighing 1 ounce; g) 1 bottle of rectified Spirit, weighing 1 ounce; h) 1 pair of scissors;addition, there shall be additional equipments as per the description of sub-section 2, 3 and 4 mentioned below, basing on the number of workers or employees. i) 1 copy of leaflet regarding primary aid; j) Analgesic and antacid type of tablets, ointments used for burnt parts, ointments for eyes and antiseptic solution appropriate for surgery and k) 3 packs of edible saline. Recommended corrective action: It is recommended that the facility should provide first aid kits in first aid box and should available first aider in the production floor during working period. Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 30 days (Desktop). 8. Issue title: No accident / injury investigation system to find out the root cause. Description of non–compliance:


It was noted through document review and management interview that factory has no accident / injury investigation system to find out the root cause of each accident/injury to take preventive or corrective action to prevent re-occurrence of same type of accidents. Local law and/or ETI requirement: In accordance with ETI Base Code 3.1 and with rule 73 of the Bangladesh Labour rules 2015:


Plant tour Picture-9


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In accordance with the ETI base code 3.1 “A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.” Authority of every institute shall preserve the record of each accident or mishap in the Register in accordance with Form-28. The authority would also accurately record the steps taken by the institute in relevant Register. 2) The recorded data as per Sub-section (1) shall be submitted to the Inspector as Half-Yearly Accident Data Report within 10 working days after expiry of 6 months over the records. Recommended corrective action: It is recommended that the factory should investigate accident/injury to find out the root cause of each accident/injury to take preventive or corrective action to prevent re-occurrence of same type of accidents. Action By: Mr. Md. Sazzad Hossain, Asst. Manager (Compliance) Time frame: 30 days (Desktop).


Document review and management interview.

Observation:

Description of observation: None Observed Local law or ETI requirement: Not applicable Recommended corrective action: Not applicable



Description of Good Example (GE): Nil

Objective Evidence Observed: Not applicable

: Child Labour Shall Not Be Used

4: Child Labour Shall Not Be Used (Click here to return to NC–table)



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ETI 4.1 There shall be no new recruitment of child labour. 4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child. 4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions. 4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards.



Current systems:

1. The factory establishes a policy that will never employ and use any child labor. 2. Factory verify the workers age through registered doctors. 3. 42 numbers of employees’ personal files were provided for review. Each employee file includes a bio-data

sheet, a recent photo and the age documentation, which is in the form of photocopied national identification card. The card lists the employee’s name, household address and the date of birth.

4. Minimum hiring age of the factory is 18 year old. Minimum wage of the worker from sample found 20 years. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Policy review 2. Document review 3. Management interview 4. Worker interview 5. Factory tour

Non–compliance:

1. Description of non–compliance: NC against ETI NC against Local Law

No non compliance was observed on the audit day. Local law and/or ETI requirement: Not applicable Recommended corrective action: Not applicable



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Observation:






5: Living Wages are Paid (Click here to return to NC–table)

(Click here to return to Key information)

ETI 5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income. 5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. 5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.



Current systems:

1. Facility management has implemented policy regarding all type of benefits like compensation, service benefit, annual leave & maternity benefit. All policy shares with the employees through training & notice board.

2. All workers are provided appointment letter during recruitment mentioning their salary structure, grade,


37

employment conditions, benefits etc. 3. Benefits such as social insurance, annual leave, casual leave, sick leave and maternity leave are provided

to workers as per law. 4. The factory do not deduct any illegal deduction from employees has been identified through document

reviewed and confirmed workers during the interviewed. However facility has deducted only provident fund from worker salary as per law.

5. Minimum wage is ensured for all workers as per their designation and grade. Minimum wage observed in the factory is BDT. 5300 for the Helper with Grade 07.

6. Overtime premium is paid as per law which is 200% of basic salary per hour. 7. Factory management paid wage to the employee within 7th working days at the end of wage period. 8. Workers of the factory are getting casual, sick and annual leave as per law. 9. Maternity leave and benefits are provided to the entitled female workers. 10. Factory management is providing all benefits to resigned workers as per law. 11. All workers are covered in group insurance of the factory. The factory management has agreement with

BGMEA (Bangladesh Garment Manufactures & Exporters Association) which is valid up to May 06, 2017. 12. Factory management is providing 5% salary increment to the workers from December, 2014 as per the

requirement of Minimum Wage gazette published in December 23, 2013 and updated their service books accordingly.


1. Document review ( wage sheet review, worker’s personal file, bonus payment sheet review, pay slip, maternity register review, wage & benefit policy etc)

2. Worker interview 3. Management interview

Non–compliance:


No non compliance was observed on the audit day. Local law and/or ETI requirement: Not Applicable Recommended corrective action: Not Applicable

Objective evidence observed: Not Applicable

Observation:

Description of observation: None Observed Local law or ETI requirement: Not Applicable Comments: Not Applicable

Objective evidence observed: Not Applicable


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Description of Good Example (GE):

1. Factory provides attendance bonus BDT. 300 for all. 2. Factory provides production bonus to the piece rate workers based on

production amount.

Objective Evidence Observed: Document review (salary sheet) and facility management & worker interview.

Wages analysis:

Wages analysis: (Click here to return to Key Information)

A: Sample Size Checked (State number of worker records checked and from which weeks/months – should be current, peak and random/low. Please see SMETA Best Practice Guidance and Measurement Criteria)

42 attendance records and payroll records from September – 2016 (Current month) 42 attendance records and payroll records from June – 2016 (peak month) 42 attendance records and payroll records from January – 2016 (Off peak month)

B: Are there different legal minimum wage grades? If Yes, please specify all.

Yes

No

The Government has announced the new pay structure which was implemented from 1

st December, 2013 for the workers of the Garments Industries. The Gazette

Notification has been published on 5th December, 2013. There are two separate

pay structures; for the garment workers (Schedule A) 1. For the workers (Schedule A):

Grade Monthly basic wage

House rent 40% of the basic

Medical allowance

Conveyance allowance

Food subsidy

Gross monthly wage

Grade 1 Tk.8500 Tk.3400 Tk.250 Tk.200 Tk.650 Tk. 13000

Grade 2 Tk. 7000

Tk. 2800

Tk.250 Tk.200 Tk.650 Tk. 10900

Grade 3 Tk. 4075

Tk. 1630

Tk.250 Tk.200 Tk.650 Tk. 6805

Grade 4 Tk. 3800

Tk. 1520

Tk.250 Tk.200 Tk.650 Tk. 6420

Grade 5 Tk. 3530

Tk. 1412

Tk.250 Tk.200 Tk.650 Tk. 6042

Grade 6 Tk. 3270

Tk. 1308

Tk.250 Tk.200 Tk.650 Tk. 5678

Grade 7 Tk. 3000

Tk. 1200

Tk.250 Tk.200 Tk.650 Tk. 5300


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Apprentice Tk. 2200

Tk. 880 Tk.250 Tk.200 Tk.650 Tk. 4180

2. For the staff level (Schedule B) employees:

Grade Monthly

basic wage

House rent

40% of the

basic

Medical allowance

Conveyance allowance

Food subsidy

Gross monthly wage

Grade 1 Tk.6500 Tk.2600 Tk.250 Tk.200 Tk.650 Tk.

10200


8100


7400


5650

Apprentice Tk.

2300 Tk.920 Tk.250 Tk.200 Tk.650

Tk. 4320

C: If there are different legal minimum grades, are all workers graded correctly?

Yes

No

N/A

If No, please give details:

D: What deductions are required by law e.g. social insurance? Please state all types:

As per section 125 of the Bangladesh Labour Law, 2006, factory may deduct wages for un-authorized absence, for fines, housing facility, advance payments, loans, income tax, provident fund, etc. However, factory is deducting only for un-authorized absence.

E: Have all of these deductions been made? Please list all deductions that have/have not been made.

Yes

No

If Yes, Please list all deductions that have been made: In this facility, is deducting only for un-authorized absence as per local labor law.

If No, please give details on any deductions which have not been made: Factory does not deduct for fines, housing facility, advance payments, loans, income tax, provident fund, etc law.

F: Industry norm for this region: (please include time period e.g. hour/week/month)

The Government has announced the new pay structure which was implemented from 1st

December, 2013 for the workers of the Garments Industries. The Gazette Notification has been published on 5

th December, 2013. There are two separate pay structures for

the garment workers. For the garment workers: Gross Salary BDT. 5300 per month (Basic BDT 3000, House rent 40% of the Basic which is BDT.1200, Medical allowance BDT. 250, Conveyance allowance. BDT.200, Food Allowance BDT.650.) For Grade 7 (Assistant operator).


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Wages table (Click here to return to Key information)

Worker Type Process Operator (Lowest paid)

Process Operator (Average paid)

Process Operator (Highest paid)

Select from individual worker records one worker from, lowest, average and highest wages and populate the boxes. Ensure comparison is made for same pay period and only uses full–time workers. See SMETA Best

Practice Guidance and Measurement Criteria for completing this:

A: Pay period: (State month selected)

September-2016 September-2016 September-2016

B: Anonymous Employee Reference/Dept.

Piece rate: General Operator / Trimming section

Fixed rate:

Helper / Mending section

Piece rate: Jr. operator

/ Trimming section

Fixed rate: Over Lock OPT / Linking

(HRS) section

Piece rate: General operator / Linking

section

Fixed rate: Jr. Operator / Knitting

section

C: Employee Gender Piece rate: Female

Fixed rate:

Female

Piece rate: Female

Fixed rate:

Male

Piece rate: Male

Fixed rate:

Male

D: Contracted/Standard working hours: (excluding OT – please include time period e.g. hour/week/month)

48 hours/ week 48 hours/ week 48 hours/ week

E: Contracted /Standard work pay rate: (excluding OT – please include time period e.g. hour/week/month)

Piece rate: BDT. 15.72/ hour

BDT. 5678 / month (Gross Salary)

BDT. 3270/ month (Basic Salary)

BDT. 4966 / month (Production Income)

Fixed rate:

BDT. 14.42/ hour BDT. 5300 / month

(Gross Salary) BDT. 3000 / month

(Basic Salary)

Piece rate: BDT. 17.82 / hour BDT. 6290 / month

(Gross Salary) BDT. 3707/ month

(Basic Salary) BDT. 11734 / month (Production Income)

Fixed rate:

BDT. 21.27 / hour BDT. 7296/ month


(Basic Salary)

Piece rate: BDT. 16.50 / hour BDT. 5908 / month


(Basic Salary) BDT. 18702 / month (Production Income)

Fixed rate:

BDT. 27.37 / hour BDT. 9070/ month


(Basic Salary)

F: Standard day overtime – Piece rate: Piece rate: Piece rate:


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hours: (please include time period e.g. hour/week/month)

20 hour/ month

Fixed rate: 26 hour/ month

20 hour/ month


20 hour/ month


G: Standard day overtime – wage: (please include time period e.g. hour/week/month)

Piece rate: BDT. 653 /month

Fixed rate:

750 hour/ month


Fixed rate:

1447 hour/ month


Fixed rate:

2080 hour/ month

H: Rest day overtime – hours: (please include time period e.g. hour/week/month)

0 hour/ month 0 hour/ month 0 hour/ month

I: Rest day overtime – wage: (please include time period e.g. hour/week/month)

0 hour/ month

0 hour/ month

0 hour/ month

J: Statutory Holiday overtime – hours: (please include time period e.g. hour/week/month)

0 hour/ month 0 hour/ month 0 hour/ month

K: Statutory holiday OT – wages: (please include time period e.g. hour/week/month)

0 hour / month 0 hour / month 0 hour / month

L: Total overtime hours: (please include time period e.g. hour/week/month)

Piece rate: 20 hour/ month

Fixed rate:

26 hour/ month


Fixed rate:

34 hour/ month


Fixed rate:

38 hour/ month

M: Incentives/Bonus/ Allowances etc.: (please include time period e.g. hour/week/month)

Piece rate: BDT. 993, BDT. 300 BDT.1136 / month

(Production bonus + Attendance bonus+

Festival Holiday)

Fixed rate: BDT. 300,BDT.00 / month Attendance bonus+ Tiffin)

Piece rate: BDT. 2347, BDT. 300

BDT.1258 / month (Production bonus + Attendance bonus+

Festival Holiday)

Fixed rate: BDT. 300 ,BDT.00/ month Attendance bonus+ Tiffin)

Piece rate: BDT. 3740, BDT. 300

BDT.1182 / month (Production bonus + Attendance bonus+

Festival Holiday)

Fixed rate: BDT. 300; BDT.00 / month Attendance

bonus+ Tiffin)

N: Gross wages: (please include time period e.g. hour/week/month)

Piece rate: BDT. 8048 / month


Piece rate: BDT. 26385/ month


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Fixed rate: BDT. 6350 / month



O: Social insurance and other deductions; please list which and amount.


( Govt. Revenue stamp)











P: Actual wage paid after deduction: (please include time period e.g. hour/week/month)


Fixed rate:

BDT. 6350 / month


Fixed rate:

BDT. 9043/ month


Fixed rate:

BDT. 11450 / month

Comments: (Please state here any specific reasons/circumstances that explain the lowest and highest gross wages)

Piece Rate: General operator (Grade 6) is getting higher salary and General Operator (Grade 6) is getting lowest salary as per minimum wage gazette (5th December 2013). Fixed Rate: Jr. operator (Grade 5) is getting higher salary and Helper (Grade 7) is getting lowest salary as per minimum wage gazette (5th December 2013).

Q: Is there a defined living wage: This is not normally minimum legal wage. If answered Yes please state amount and source of info: Please see SMETA Best Practice Guidance and Measurement Criteria.

Yes No

Please specify amount/time period: Factory did not define living wages as it is not required by law. However, factory is providing the minimum wage as Minimum Wages Gazette for Readymade Garments Sector published on December 5, 2013”.

R: Are workers paid in a timely manner in line with local law?

Yes No

S: Is there evidence that equal rates are being paid for equal work:

Yes No

Details: Through factory policy review, payroll records review and employees’ interview, it is confirmed that equal rates are being paid for equal work.

T: How are workers paid: Cash Cheque Bank Transfer Other


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If other explain:

6: Working Hours are not Excessive (Click here to return to NC–table)


ETI 6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are based on international labour standards. 6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week. 6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay. 6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause 6.5 below. 6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of the following are met:

– this is allowed by national law; – this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce; – appropriate safeguards are taken to protect the workers’ health and safety; and – The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.

6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2 days off in every 14 day period.



Current systems:

1. The factory has displayed notice regarding the working hours, overtime hours, lunch breaks, weekly & festival holidays on notice boards

2. Regular working hour of the factory is 08 hours and also ensures 01 hour lunch / rest break for all. 3. Standard working hours found 48 hours in the factory. 4. All workers are provided with written and understandable information about their employment conditions in

respect of wages before they enter employment and about the particulars of their wages. 5. Through employees’ interview it was noted that they were aware about voluntary overtime policy. As per

the company policy all overtime will be compensated at a premium rate (200%). 6. Overtime hour found within legal limit as well as the limit mentioned in ETI base code.


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7. Workers are getting one day off for every seven day period. Friday is declared as weekly holiday.


1. Employee interview 2. Payroll records 3. Job card records 4. Production records 5. Working hour and Overtime hours Policies & procedures. 6. Management interview

Non–compliance:


No non compliance was observed on the audit day. Local law and/or ETI requirement: Not applicable Recommended corrective action: Not applicable


Observation:





Objective Evidence Observed: None Observed

Working hours analysis


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Please include time period e.g. hour/week/month (Go back to Key information)

Systems & Processes

A. What timekeeping systems are used: time card etc.

Describe: Paper time keeping system.

B: Sample Size Checked (State number of worker records checked and from which weeks/months and type – should be current, peak and random/low: See SMETA Best Practice Guidance and

Measurement Criteria)

42 attendance records and payroll records from September – 2016 (Current month) 42 attendance records and payroll records from June – 2016 (peak month) 42 attendance records and payroll records from January – 2016 (Off peak month)

C: Do ALL workers have contracts/employment agreements?

Yes No

If NO, state which type of workers do NOT have contracts/employment agreements:

D: Are standard/contracted working hours defined in all contracts/employment agreements?

Yes No

If NO, please state which type of workers do NOT have standard hours defined in contracts/employment agreements.

E: Are there any other types of contracts/employment agreements used?

Yes No

If YES, Please complete as appropriate:

0 hrs Part time Variable hrs Other

If “Other”, Please define: NA

Standard/Contracted Hours worked

F: Do standard/contracted standard hours ever exceed the law or 48 hours per week?

Yes No

If YES give details and comparison (local law/48 hrs week)

G: What are the actual standard/contracted hours worked in sample (State per week/month)

Highest hours: 48 hours/ week

Lowest hours: 48 hours/ week

H: Any local waivers/local law or permissions which allow averaging/annualised hours for this site?

Yes No

If YES, Please give details

No waiver for this specific site but, Government has exempted section 100 and 102 of the


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Bangladesh Labour Law-2006 publishing a Gazette notification in August 2011 as per section 324 Bangladesh Labour Law-2006 for 06 months relaxing daily overtime hours. In accordance with the Clause/Condition No. – 3 of this notification, no worker shall work more than 04 hours of overtime in any day without his/her consent.

This exemption has been extended several times in last

few years and latest extension was on October 22, 2015

and it will be in effect from 17 April, 2015 to 16 October,

2016.

Overtime Hours

I: Actual overtime hours worked in sample (State per day/week/month)

Highest OT hours:

35 in the month of August, 2016 (Current month) 52 in the month of June, 2016 (Random month) 52 in the month of December, 2015 (Random month)

Lowest OT hours:

02 in the month of August, 2016 (Current month) 26 in the month of June, 2016 (Random month 01 in the month of December, 2015 (Random month)

J: Range of overtime hours over all workers/or as large a sample as possible. (State per week/month and details)

02 to 35 in the month of August, 2016 (Current month) 26 to 52 in the month of June, 2016 (Random month 01 to 52 in the month of December, 2015 (Random month)

K: Approximate percentage of workers on highest overtime hours

27.42%

L: Is overtime voluntary? Yes No Conflicting

Information

Please detail evidence e.g. Wording of contract/employment agreement/handbook/worker interviews/refusal arrangements:

Overtime Premiums

M: Is overtime paid at a premium? Yes No

Please give details of normal day overtime premium as a % of standard wages:

0%

1 – 115%

116 – 124%

125 – 149%

150 –199%

200%+


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Any other comments: As per law and company policy.

N: ETI Code requires a prevailing standard to give greatest worker protection. If a site pays less than 125% OT premium and this is allowed under local law, are there other considerations? Please complete the boxes where relevant. Multi select is possible.

No Consolidated pay (May be standard wages above minimum legal wage, with

no/low overtime premium) Collective Bargaining agreements Other

Please explain any checked boxes in N above e.g. detail of consolidated pay CBA or Other.

Not Applicable

Rest Days

O: Are workers provided with 1 day off in every 7–day–period, or 2 in 14–day–period (where the law allows)?

Yes No

Maximum number of days worked without a day off (in sample):

6 days

Total Hours

P: Range of total hours: (Quote highest and lowest please include time period e.g. hour/week/month)

Highest total hours

243 in the month of August, 2016 (Current month) 260 in the month of June, 2016 (Random month) 260 in the month of December, 2015 (Random month)

Lowest total hours

210 in the month of August, 2016 (Current month) 234 in the month of June, 2016 (Random month). 209 in the month of December, 2015 (Random month)

R: If more than 60 total hours per week and this is legally allowed, are there other considerations? Please complete the boxes where relevant. Multi select is possible.

Overtime is voluntary Onsite Collective bargaining allows 60+ hours/week Safeguards are in place to protect worker’s health and safety Site can demonstrate exceptional circumstances Other reasons

Please explain any checked boxes in R above

“As per Bangladesh Labour Law-2006, section-100; regular working hours of an adult worker shall not be more than 08 hours in any day and including 02 hours overtime it shall not be exceeded 10 hours in any day. As per Bangladesh Labour Law-2006, section-102; regular working hours of an adult worker shall not be more than 48 hours in a week and including


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12 hours overtime it shall not be exceeded 60 hours in any week and on the average fifty-six hours per week in any year. Exception for 6 months; Government has exempted section 100 and 102 of the Bangladesh Labour Law-2006 publishing a Gazette notification in August 2011 as per section 324 Bangladesh Labour Law-2006 for 06 months relaxing daily overtime hours. In accordance with the Clause/Condition No. – 3 of this notification, no worker shall work more than 04 hours of overtime in any day without his/her consent. Though there is a controversy with this notification as no maximum overtime ceiling is clearly defined in this notification. This exemption has been extended several times in last few years and latest extension was on October 22, 2015 and it will be in effect from 17 April, 2015 to 16 October, 2016.

Comments: (please state here any specific reasons/circumstances that explain the highest working hours)

Not applicable

7: No Discrimination is Practiced (Click here to return to NC–table)

ETI 7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.



Current systems: Through employee interview, management interview and documents review:

1. On reviewing of documentation and interview with workers, there was no case of discrimination has been identified based on gender, race, religion etc. in hiring, compensation, access to training, promotion, termination or retirement.

2. The factory provides the same pay to male/female employees. 3. The factory prohibits mandatory pregnancy testing as a condition of employment or continued employment.

All pregnant women workers are given their right to motherhood and provided with legally mandated benefits.

4. Management has separate policy on no discrimination. 5. Overtime opportunity for all workers is equal.


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6. Workers are free to raise and inform their grievance to the management directly or through the members of PC. Also sufficient complaints boxes are placed in different restricted places to raise the grievances of the workers. Complaint boxes are checked in each week and corrective actions taken if any issue raise.


1. Management interview 2. Worker interview 3. Local and national law 4. Personal files 5. Compensation records 6. Termination & retirement records 7. Training records 8. Complain register

Non–compliance:


No non compliance was observed on the audit day. Local law and/or ETI requirement: Not Applicable Recommended corrective action: Not Applicable

Objective evidence observed: (where relevant please add photo numbers)

Not Applicable

Observation:







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8: Regular Employment Is Provided (Click here to return to NC–table)


ETI 8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. 8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour–only contracting, sub–contracting, or home–working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed–term contracts of employment.



Current systems:

1. Through the interview with the workers, review of documents and interaction with the factory management it was noted that, factory has not employed any of the workers on temporary basis as well as contract basis.

2. Factory management recruits the workers through advertisement or internal reference. Workers are selected based on the result of the examination taken on working skill of workers during the recruitment process.

3. Factory management issues appointment letter and ID card to all the employees of the factory. 4. The personal files of workers are well maintained by the factory in connection with employment contract &

all required papers. 5. Service record book is maintained for all workers. 6. No illegal deduction was identified during the day of audit while checking the documents. During the

workers interview, workers also confirmed that they never faced any illegal deduction from their wages. 7. There is no subcontracting or home working from the site. 8. Workers can resign by showing reasonable notice as per law.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): 1. Management interview 2. Worker interview 3. Workers’ personal files and service books 4. Policies and procedures 5. Wage sheets

Non–compliance:


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None Observed Local law and/or ETI requirement: Not Applicable Recommended corrective action: Not Applicable


Not Applicable

Observation:







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8A: Sub–Contracting and Homeworking:

8A: Sub–Contracting and Homeworking (Click here to return to NC–table)


8A.1. There should be no sub–contracting unless previously agreed with the main client. 8A.2. Systems and processes should be in place to manage sub–contracting, homeworking and external

processing. Note to auditor on homeworking:

Report on whether it is direct or via agents. How many workers, relationship with site and what control systems are in place.



Current systems: It was verified through document review, factory tour, facility management interview and employee interview that no sub-contracting and Home-working was used by this factory. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Management interview 2. Worker interview 3. Production process of the factory 4. Policies and procedures

If any processes are sub–contracted – please populate below boxes: Nil

Process Subcontracted Process 1 Process 2

Name of factory

Address


Name of factory

Address


Name of factory

Address


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Non–compliance:

1. Description of non–compliance: NC against ETI/Additional Elements NC against Local Law

No non compliance was observed on the audit day. Local law and/or ETI /Additional Elements requirement: Not Applicable Recommended corrective action: Not Applicable


Not Applicable

Observation:

Description of observation: None Observed Local law or ETI/Additional elements requirement: Not applicable Comments: Not applicable





Summary of sub–contracting – if applicable

Summary of sub–contracting – if applicable

A: If sub–contractors are used, is there evidence this has been agreed with the main client?

Yes No

If Yes, summarise details: NA

B: Number of sub–contractors/agents used

0

C: Is there a site policy on sub–contracting?

Yes No

If Yes, summarise details: NA

D: What checks are in place to ensure no child labour is being used

NA


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and work is safe?

E: What processes are sub–contracted?

NA

Summary of homeworking – if applicable

F: If homeworking is being used, is there evidence this has been agreed with the main client?

Yes No

If Yes, summarise details:

G: Number of homeworkers Male: 0 Female: 0 Total: 0

H: Are homeworkers employed direct or through agents?

Directly Through Agents

NA

I: If through agents, number of agents

NA

J: Is there a site policy on homeworking?

Yes No

NA

K: How does site ensure worker hours and pay meet local laws for homeworkers?

NA

L: What processes are carried out by homeworkers?

NA

M: Are written agreements in place for homeworkers that include regular employment?

Yes No

NA

N: Are full records available at the site?

Yes No

NA


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o Harsh or Inhumane Treatment is allowed

9: No Harsh or Inhumane Treatment is Allowed (Click here to return to NC–table)

ETI 9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and

record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to


Current systems: 1. The factory established anti-harsh or inhumane treatment policy. The policy states that physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. 2. Workers did not report any violation on forced labour, physical, verbal abusive, disciplinary practice and any kind of sexual harassment. 3. No evidence of punitive punishment found inside factory. During interview workers confirmed that all their dues correctly paid in case they want to leave factory for better opportunity. 4. All workers are comfort with their management behaviour and the factory management treated them with respect. 5. Workers are aware of disciplinary procedure of factory. Also the mid level management are aware and known about the disciplinary policy and procedure of the company as well as the law. 6. No pressure from security guards to hold workers once they get authorized leave from management. 7. No complain regarding abuse, harassment or force labour also observed in the grievance register as well. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Management interview 2. Worker interview 3. Complain register 4. Policies and procedures

Non–compliance:


None Observed Local law and/or ETI requirement: Not Applicable Recommended corrective action: Not Applicable


Not Applicable


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Observation:

Description of observation: No non compliance was observed on the audit day. Local law or ETI requirement: Not applicable Comments: Not applicable





A: Entitlement to Work and Immigration

10. Other Issue areas: 10 A: Entitlement to Work and Immigration (Click here to return to NC–table)

Additional Elements 10A1 Only workers with a legal right to work shall be employed or used by the supplier. 10A2 All workers, including employment agency staff, must be validated by the supplier for their legal right to work by reviewing original documentation. 10A3 Employment agencies must only supply workers registered with them. 10A4 The supplier shall implement processes to enable adequate control over agencies with regards the above points and related legislation.



Current systems: Only workers with a legal right to work shall be employed or used by the factory. There are no agency staffs, employment agencies and immigration workers in the factory. The factory hires new workers by placing advertisement/notice and also through workers’ reference. All workers are hired directly. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1. Management interview 2. Worker interview 3. Employment records 4. Appointment letter


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5. Personal files

Non–compliance:

1. Description of non–compliance: NC against ETI/Additional Elements NC against Local Law

No non compliance was observed on the audit day. Local law and/or ETI /Additional Elements requirement: Not applicable Recommended corrective action: Not applicable


Not applicable

Observation:

Description of observation: None Observed Local law or ETI/Additional Elements requirement: Not applicable Comments: Not applicable


Good examples observed:




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10 B 2: Environment 2–pillar

10. Other issue areas 10 B 2: Environment 2–pillar (Click here to return to NC–table)

To be completed for a 2–Pillar SMETA Audit, and remove the following page which is 10B4 environment 4 pillar

10B2. 1 Suppliers must comply with the requirements of local and international laws and regulations including having necessary permits. 10B2. 2 The supplier should be aware of and comply with their end clients’ environmental requirements. Note for auditors and readers, This is not a full environmental assessment but a check on basic systems and management approach.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and

record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to


Current systems:

1. Factory has waste management policy regarding solid, liquid as well as hard waste. 2. Factory surrounding environment found acceptable though they have no environment clearance certificate.


1. Document review 2. Factory tour 3. Management interview

Non–compliance:

Description of non–compliance:

NC against ETI/Additional Elements NC against Local Law No non compliance was observed on the audit day. Local law and/or ETI /Additional Elements requirement: NA Recommended corrective action: NA

Objective evidence observed: NA

Observation:

Description of observation: None Observed Local law or ETI /additional elements requirement: Not applicable



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Comments: Not applicable

Good examples observed:



Worker Interview Summary

A: Were workers aware of the audit? Yes No

B: Were workers aware of the code? Yes No

C: Number of group interviews: (Please specify number and size of groups. Please see SMETA Best Practice Guidance and Measurement Criteria)

30 employees in 05 groups (5 each group)

D: Number of individual interviews (Please see SMETA Best Practice Guidance and Measurement Criteria)

Male: 06 Female: 06

E: Total number of interviewed workers (Please see SMETA Best Practice Guidance and Measurement Criteria)

Male: 26 Female: 16

F: Interviews were done in private and the confidentiality of the interview process was communicated to the workers?

Yes No

G: In general, what was the attitude of the workers towards their workplace?

Favourable Non–favourable Indifferent

H: What was the most common worker complaint?

No problem was noticed.

I: What did the workers like the most about working at this site?

Wages are always paid on time & working environment is good.

J: Any additional comment(s) regarding interviews:

Nil


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K: Attitude of workers to hours worked:

Acceptable

Agency Workers

Agency Workers (if applicable) (workers sourced from a local agent who are not directly paid by the site)

A: Number of agencies used (average):

Nil And names if available:

B: Were agency workers’ age/pay/hours included within scope of this audit

Yes No

NA

C: Were sufficient documents for agency workers available for review?

Yes No

NA

Other findings

Other Findings Outside the Scope of the Code

None Observed

Community Benefits (Please list below any specific community benefits that the site management stated that they were involved in, for example, HIV

programme, education, sports facilities)

None


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General Photo:

Main gate of the facility Name of the facility Front view of the facility

Roof top Security post point Winding section

Jacquard section Linking section Trimming section


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Mending section Light checking area Wash section

Dryer section Iron section PQC Section

Folding area Packing section Finished goods area

Accessories store Yarn store Evacuation plan


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Illuminated exit sign Fire alarm switch Fire extinguisher

Fire fighting equipments Fire alarm bell Smoke detector

Emergency light Fog light Fire hose pipe


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Fire door Fire alarm siren with visual system Fire control pannel

Fire hydrant point Demonstration of hose reel PA (Public address) System

No smoking sing Staircase Exhaust fan

Workers ID card Risk assessment posted in the production floor

ETI base code posted in the production floor


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Workers toilet (segregated by gender)

First aid box Complaint box

Drinking water facility Workers dining area Workers canteen

Medical room Child care room Notice board


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ETP Electrical sub-station Generator room

Void

Void

Boiler room

Non-Compliance Photo

NC pic-1: Pulley cover of linking machines was found in displaced condition.

NC pic-2: Upper & lower pulley cover was missing for 1 auto placket machine.

NC pic-3: Button attached machines eye guard found at improper position with machine.

NC pic-4: Jacquard section workers were not using ear plug during

NC pic-5: ETP operator were not using respective PPE during

NC pic-6: Secondary aisles were not marked in light check section,


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work. chemical handling. trimming-mending section.

NC pic-7: Secondary aisles were not marked in sewing section.

NC pic-8: Gas cylinder found at ground floor without any solid barrier

NC pic-9: Insufficient first aid kits in first aid box.

PHOTO PICTURE END.

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